Ethics Policy

STATEMENT OF POLICY

The purpose of this policy is to state the Company’s position on operating with the highest ethical standards through complying with both the letter of the law and the spirit of the law as well as treating those we do business with internally and externally fairly, with openness, candor and respect.

ADMINISTRATION

The Executive Team is responsible for the administration of this policy.

Whistleblowers, which could include employees, vendors, operating partners, etc., may confidentially report possible violations of law, Company policy or concerns about workplace safety or conduct to PECOcares@pecopallet.com.

PECO will investigate all reported instances of questionable or unethical behavior and take appropriate corrective action, including disciplinary action, when it is warranted. Confidentiality will be maintained throughout the investigation process to the extent possible under the circumstances. No employee will be retaliated against for making any complaint and/or raising genuine ethics concerns in good faith under this policy.

APPLICATION

This policy applies to the Company at every location, our partners, vendors and to all levels of employees.

The successful business operation and reputation of our Company is built upon the principle of fair, honest and transparent dealings with our customers, suppliers, our ownership, and ourselves. Our reputation for integrity and excellence requires observance of the spirit and letter of all applicable laws and regulations, as well as the rigor of holding ourselves personally accountable to the highest standards of conduct and integrity. Compliance with this policy of Business Ethics and Conduct is the responsibility of every employee.

As part of PECO’s Open Door Policy (HR-118), if a situation should arise where it is difficult to determine the proper course of action, the matter should be discussed openly with your immediate supervisor, Human Resources or any other member of management for advice and consultation.

Gifts, Gratuities and Business Courtesies

Our policy expressly addresses the prohibition of PECO employees giving and/or the acceptance of gratuities from a vendor, supplier, customer or service agency with whom PECO does business or is considering for future business. Gratuities may involve gifts, money, loans, trips, meals, lodging, special favors or other forms of remuneration relating to PECO business. This policy stands as protection against PECO being compromised in our business dealings. Acceptance of favors or gifts interferes with objective decision making and judgement and, in some cases, violates the law. Therefore, the following applies:

  • PECO employees will not offer gratuities or other inducements to customers, potential customers, suppliers, or any government officials of any country.
  • PECO employees should politely but firmly refuse or return gratuities or other inducements of a market value greater than $50.00 and is offered by those with whom we do business as described above regardless of the circumstances or intent.
  • Employees may accept unsolicited gifts, other than money, that conform to the reasonable ethical practices of the marketplace, including:
  • Flowers, fruit baskets and other modest presents that commemorate a special occasion.
  • Gifts of nominal values such as calendars, pens, mugs, caps and t-shirts (or other novelty, advertising or promotional items).

Bribery and Corruption

We must avoid any relationship, influence or activity that might impair, or even appear to impair, our ability to make objective and fair decisions when performing our jobs; we ask our suppliers to not engage in the act of bribery or corruption, and abstain from engaging in any behavior that may impair, or even appear to impair objective and fair decisions.

Confidentiality

To operate effectively in a competitive business environment, PECO Pallet must protect information about all aspects of its business operations. To facilitate this important objective, all current employees of PECO Pallet, Inc. have a signed Non–Compete and Confidentiality Agreement in their employee record and new employees are required to sign this agreement as a condition of employment with PECO.

During the course of your association with PECO, you will be made privy to confidential information concerning financial data, marketing or business plans, customer and supplier lists, business partners, prospects, contracts, and other legal documents. We require that you keep such information confidential both during and after your employment with PECO Pallet. Unauthorized use or disclosure of any such information to any person or entity is strictly prohibited. Employees who violate or disregard the Non–Compete and Confidentiality Agreement will be subject to disciplinary action up to and including termination of employment. Employees who violate this agreement after leaving PECO are subject to legal action.

Public Communications

It is against Company policy for employees to disclose confidential information about the Company to anyone, except where disclosure is authorized or legally mandated. This policy is important not only to preserve Company confidences, but also to protect the Company, its related entities, its employees, business partners, investors and family members.

To guard against the disclosure of material nonpublic information to an external source such as the press, other media, or industry analyst, our policy designates certain employees as Company “Spokespersons”: the Chief Executive Officer, or Chief Financial Officer. The Spokespersons are the only individuals authorized to disclose information about the Company to such sources.

Our policy applies to communications in all forms of media, including print (such as newspapers, magazines and journals), television, radio, social media such as Facebook or LinkedIn and all other electronic media (such as websites, blogs, newsletters, etc.). Employees should take extra precautions when posting on Linked In or similar sites where your profile includes PECO Pallet and your views may be associated as PECO’s views.

Child Labor, Anti-Slavery and Anti-Human Trafficking

PECO has always led its business with integrity, focused on complying with all applicable laws and regulations. Consistent with these principles, PECO observes high ethical standards in the conduct of its business. Our Values of Safety, Integrity, Trust and Excellence, reflect our commitment to establishing and maintaining relationships internally with ourselves, but equally with vendors, suppliers and other third parties. Our supply base must be committed to the same ethical standards as we are at PECO, and not linked to activities that would be considered abusive or exploitive, including human trafficking and slavery in compliance with the Ethical Trading Initiative (ETI) and the International Labor Organization (ILO) Conventions. Suppliers also must comply with the State of California Transparency in Supply Chains Act (SB 657).

We strictly prohibit employees, subcontractors and subcontractors' employees from engaging in sex trafficking, using force, fraud or coercion to subject a person to involuntary servitude or obtaining labor from a person through threat of harm. We will take immediate action to correct any violation of this policy. Anyone working for us or doing business with us must immediately report any activity covered by this policy to your manager and to the appropriate law enforcement agency. If you see something, say something. Please utilize the company’s reporting process as stated above.

Health, Safety and Environmental Laws

It is PECO’s policy to comply with OSHA (USA) and CCOHS (Canada) standards, all applicable laws and regulations at all times wherever we operate and to take all practicable steps to promote health, safety and environmental protection. It is PECO’s goal to prevent adverse effects on health, safety and the environment. PECO is committed to quality, safety, and continuous improvement in environmental protection. Our commitment includes providing our employees the training, awareness, equipment and resources necessary to meet our safety goal. Further, our management is committed to supporting a Safety Always mentality in our day-to-day activities.

Any violation of this policy or failure to comply may result in disciplinary action, up to and including termination of employment or vendor relationship.




PECO Pallet Company Policy HR-1100
Business Ethics and Conduct
Effective Date: January 1, 2020

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