BUSINESS ETHICS POLICY
Atom Adhesives’ Business Ethics Policy, which is embodied in the following standards, is a guide to ethical decision-making. We are committed to uncompromising integrity in all that we do and in the way in which we relate to each other and to people outside the company. While the standards in this policy are mainly based on laws, they also reflect the values which define us and our Company. We must constantly strive to avoid any circumstances which may create a conflict, or the appearance of a conflict, between our personal interests and those of the company. Each of us is personally responsible for making sure that our business decisions and actions comply at all times with the spirit as well as the letter of this policy. All supervisory and management employees, including all officers and directors of the company, have a special responsibility to lead according to the standards in this policy, in both words and action. Our supervisory and management employees are also expected to adhere to and promote our “open door” policy. This means that they are available to anyone with ethical or other concerns, questions or complaints. We also maintain a confidential “hotline” that we can call in those circumstances, the details of which are set out at the end of this Policy. All concerns, questions and complaints will be taken seriously and handled promptly, confidentially and professionally. No retaliation will be taken against any employee for raising any concern, question or complaint in good faith.
COMPLIANCE WITH LAWS, RULES AND REGULATIONS
It is the company’s policy to be a good “corporate citizen.” Wherever we do business, employees and directors of the company are required to comply with all applicable laws, rules and regulations. Employees are also responsible for honoring and abiding by the contracts that we have entered into with other parties, including intellectual property licenses (e.g., custom adhesive applications, special formulations, ….etc. related to products used in our business), confidentiality agreements, contracts with our customers and suppliers, and undertakings and other commitments we may have with government authorities. The standards in this policy must of course be interpreted in the context of applicable law and practice of the countries where we operate, as well as good common sense. Any suspected or actual violation of any applicable law, rule or regulation or our contractual obligations or undertakings should be reported immediately to the General Counsel.
The health of our planet and its people is of the utmost importance to our mission. All products manufactured by Atom Adhesives are sourced from DRC conflict-free areas and are EICC compliant.
Information is a valuable corporate asset. All employees and directors have an obligation to safeguard confidential information about the company and confidential information that our suppliers and customers have entrusted to us. Generally speaking, confidential information is information that has not been disclosed to the general public or that gives our business an advantage over our competitors or could expose us to harm or liability if released prematurely or inappropriately. For a more detailed explanation of the definition of “confidential information” and the proper treatment of such information, please see the Company’s Policy and Procedure on Confidential Information. Employees and directors who are unsure about whether information should be treated as confidential must consult with their immediate supervisor or the General Counsel.
Atom Adhesives is committed to having its employees deal fairly and honestly with the company’s customers, suppliers, competitors & other employees.
Doing business in an honest and fair manner with our customers means we must earn their business based on competitive pricing, the quality of our products and services, and our ability to fulfill our contractual commitments. For example, where our products or services must meet customer specifications, employees are prohibited from using false data or manipulating data in such a way as to suggest compliance with these specifications when compliance has not been achieved. Employees responsible for customer invoicing are required to reflect accurately on invoices the purchase price of the products and other contract terms.
Doing business in an honest and fair manner with our suppliers means that employees responsible for buying or leasing materials and services on behalf of the company must do so objectively. We choose to deal with our suppliers on the basis of the price, quality and desirability of their goods and services. Employees must not accept or seek out any benefit from a supplier or potential supplier that would compromise their judgment or create an appearance that their judgment would be compromised. In addition, it is against company policy to prohibit suppliers from trading with our competitors in order to continue or expand their relationship with us. Seek the advance advice and approval of the General Counsel before entering into any exclusive supply relationship with our suppliers.
The company recognizes that its employees are its most valuable resource. The company values the contributions that each employee makes and is committed to treating every employee with dignity and respect. This includes preserving the confidentiality of employee records in compliance with applicable law and refraining from unwarranted intrusions into employees’ privacy.
It is company policy to compete aggressively for new and existing business based on our superior product quality, innovation, technical competence, marketing support and service, and competitive pricing. Accordingly, false, misleading, or disparaging statements or innuendo about our competitors, their products or their services, or false or misleading statements about our company and its products and services, will not be tolerated. All comparisons of our products and services with those of our competitors, and all claims about our products and services, must be accurate and factually supported.
Employees are strictly forbidden from using any illegal or unethical methods to gather competitive intelligence. This includes stealing confidential or trade secret information of our competitors, or attempting to induce former or current employees of competitors to disclose such information through misrepresentation or other means. Anyone with even the slightest concern about the legality of information he or she possesses, or the means by which it was gathered, should consult with the General Counsel.