To meet social responsibilities and to achieve success in the marketplace, we and our agents are to uphold the highest standards of ethics including:

1) Business Integrity 

The highest standards of integrity are to be upheld in all business interactions. We shall have a zero tolerance policy to prohibit any and all forms of bribery, corruption, extortion and embezzlement. All business dealings should be transparently performed and accurately reflected on our business books and records. Monitoring and enforcement procedures shall be implemented to ensure compliance with anti-corruption laws.


2) No Improper Advantage 

Bribes or other means of obtaining undue or improper advantage are not to be promised, offered, authorized, given or accepted. This prohibition covers promising, offering, authorizing, giving or accepting anything of value, either directly or indirectly through a third party, in order to obtain or retain business, direct business to any person, or otherwise gain an improper advantage.


3) Disclosure of Information 

Information regarding our labor, health and safety, environmental practices, business activities, structure, financial situation and performance is to be disclosed in accordance with applicable regulations and prevailing industry practices. Falsification of records or misrepresentation of conditions or practices in the supply chain are unacceptable.


4) Intellectual Property 

Intellectual property rights are to be respected; transfer of technology and know- how is to be done in a manner that protects intellectual property rights; and, customer information is to be safeguarded.


5) Fair Business, Advertising and Competition 

Standards of fair business, advertising and competition are to be upheld. Appropriate means to safeguard customer information must be available.


6) Protection of Identity and Non-Retaliation 

Programs that ensure the confidentiality, anonymity and protection of supplier and employee whistleblowers (any person who makes a disclosure about improper conduct by an employee or officer of a company, or by a public official or official body) are to be maintained, unless prohibited by law. We should have a communicated process for their personnel to be able to raise any concerns without fear of retaliation.


7) Responsible Sourcing of Minerals 

We shall have a policy to reasonably assure that the tantalum, tin, tungsten and gold in the products we manufacture does not directly or indirectly finance or benefit armed groups that are perpetrators of serious human rights abuses in the Democratic Republic of the Congo or an adjoining country. We shall exercise due diligence on the source and chain of custody of these minerals and make our due diligence measures available to customers upon customer request.


8) Privacy 

We are to commit to protecting the reasonable privacy expectations of personal information of everyone we do business with, including suppliers, customers, consumers and employees. We are to comply with privacy and information security laws and regulatory requirements when personal information is collected, stored, processed, transmitted, and shared.

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