Corporate Responsibility

Anti-Harassment
We promote freedom of expression and open communication. But we expect all employees to follow our code of conduct. They should avoid offending, participating in serious disputes and disrupting our workplace. We also expect them to foster a well-organized, respectful and collaborative environment. All employees should respect their colleagues. We won’t allow any kind of discriminatory behavior, harassment or victimization. Employees should conform with our equal opportunity policy in all aspects of their work, from recruitment and performance evaluation to interpersonal relations. Our company is committed to providing a work environment where all employees can work productively, free from harassment, which is illegal under both state and federal law, and will not be tolerated.

This policy applies to: all phases of employment and to the conduct of managers, supervisors, coworkers, suppliers, and customers.

1. Prohibited Behaviors

Prohibited harassment includes:
• Any offensive or unwelcome conduct –verbal or physical- that is based on a membership in a protected class.
• Discrimination or discriminatory comments based on a person’s race, color, religion, gender, national origin, age, disability, genetic information, or any other characteristic protected by state or federal law.
• Unsolicited or unwelcome contact that has sexual overtones. This includes but not limited to:
o Written contact, such as obscene letters
o Verbal contact, such as obscene comments/questions, jokes about gender-specific traits, whistling, or addressing an individual with a term of endearment not of that individual’s choosing.
o Physical contact, such as intentional touching, blocking movement, or coercing sexual contact
o Visual contact, such as leering at another person, displaying sexually suggestive posters/magazines/videos.
o Using personal or company issued electronic equipment, including but not limited to computers, e-mail, Facebook, Twitter, MySpace, text messages, mobile phones, or other mobile devices as a means to harass anybody who is related to the Company’s workplace.
• Unwelcome sexual advances or repeated unwelcome flirtations
• Using sexual behavior to influence career, salary, or work environment of another employee. Examples includes but not limited to:
o Offering or implying the promise of an employment-related reward (e.g. raise) in exchange for sexual favors or submission to sexual conduct.
o Threatening, implying, or taking a negative employment action (e.g. termination, denial of a leave of absence) if a sexual advance is rejected.

2. Harassment by Non-employee

The Company will take all reasonable steps to prevent or eliminate harassment by non-employees, such as customers and suppliers, who are likely to have workplace contact with our employees.

Anti-Bribery
Bribery is the offering, promising, giving, accepting or soliciting of an advantage as a reward for action which is illegal or a breach of trust. This includes accepting anything of material value to gain a commercial, contractual, regulatory or personal advantage.
It is our code to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption. We are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate and implementing and enforcing effective systems to counter bribery.
We will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which we operate. However, we remain bound by laws of the United States of America, including the The Foreign Corrupt Practices Act of 1977, in respect of our conduct.