Operating with the highest standards of ethics and integrity defines Maxtran’s strong culture and who we are as a company. Each day, team members strengthen our culture by maintaining our good reputation, complying with all laws and regulations and following ethical practices. The Business Conduct Guidelines define our shared expectations of how we work together, serve customers and business partners, and honor our commitments to shareholders everywhere we do business globally. Each year, all team members, officers and members of our Board of Directors are required, as a condition of employment, to certify that they read, understand and comply with our Business Conduct Guidelines. This includes following the Guidelines, supporting others to do so and speaking up when there is a suspected violation. All reports are taken seriously, investigated thoroughly and addressed promptly. Those who violate the guidelines may face serious repercussions, including termination from the company. There are many resources ready to help you understand the guidelines and how to report any concerns. All of the following are available so you can choose those that best fit the situation:
• Your supervisor or manager
• Your Human Resources representative
• The Legal Department
• Environmental Health and Safety
• Security and Loss Prevention
Maxtran does not tolerate retaliation against any team member for making an inquiry, initiating a complaint or participating in an investigation. No one who, in good faith, raises an issue or concern will be subject to retaliation. We will maintain anonymity to the extent permitted by law. Any team member who believes that they may be the subject of retaliation is expected to report this immediately to the Human Resources Department or the Legal Department. People leaders play a pivotal role in reinforcing our ethical and inclusive culture by supporting the Business Conduct Guidelines. All leaders must hear team member concerns, maintain confidentiality and take appropriate action with their Human Resources Manager.
SECTION I. PERSONNEL
DIVERSITY, EQUITY AND INCLUSION
At Maxtran, we believe our differences make us stronger. Diversity, equity and inclusion (DEI) are integral to Maxtran’s success, and we are committed to fostering a welcoming environment where all team members feel safe, respected and encouraged to voice their opinions. We value all people — regardless of sex, gender, race, color, religion, national origin, age, disability, veteran status, sexual orientation, gender expression or experiences — and are committed to ensuring fair treatment, opportunity, and advancement so all team members are comfortable to share who they are and can be their best.
WORKPLACE BEHAVIOR – FREEDOM FROM HARASSMENT AND DISCRIMINATION
We are all responsible for creating and maintaining a productive work environment free from any kind of inappropriate conduct, harassment or bullying. We expect each team member to treat each other with respect and we do not tolerate harassment or discrimination. Harassment and discrimination can take many forms, including conduct that can lead to interfering with our work, diminishing a team member’s dignity or creating an intimidating, hostile or offensive work environment. Any type of harassment, including physical, sexual, verbal or other, is prohibited and can result in disciplinary actions up to and including termination, subject to applicable law.
WORKPLACE SAFETY
Our company is committed to providing a workplace that is safe and secure. Each of us helps meet that commitment by complying with relevant health and safety laws, and company policies that are designed to maintain a safe workplace. Any condition or work practice that could result in personal injury, illness, and/or damage to property, must be reported immediately to appropriate management. We have a zero-tolerance policy when it comes to acts or threats of violence, either internal or external to the workplace. Be alert on what is going on around you, observe good security practices and promptly report to management or local law enforcement, e.g. 911 or 988.
WEAPONS
Weapons of any kind or nature are prohibited in any company facility, at any company- sponsored event, or at any customer’s or vendor’s facility. Exceptions include the Executive Managers, Any and all Managing Members and any and all security personnel or others as designated by the Executive Management Team members by a majority vote. Any Weapons must be stored, carried and secured within the requirements of all applicable state laws. All persons carrying weapons must have them registered with the appropriate agency and must posses a valid license to carry said weapon legally.
SUBSTANCE ABUSE – ALCOHOL AND DRUGS
Team members are expected to perform their jobs alcohol and drug free. Being in possession of or working under the influence of drugs or alcohol can create a safety hazard and affect your judgment and performance. We recognize that on occasion, alcohol may be provided at a company sponsored event or with a business meal. You should ensure that your consumption of alcohol does not impair your performance and judgment. This policy doe not apply to Executive Managing Members.
POLITICAL ACTIVITIES
We respect and encourage all team members as individuals to engage in the political process. However, all political activities must be kept separate from work responsibilities. No company assets can be used to support political activities or to make any contributions to political parties, candidates or campaigns. If a team member engages in political activities (such as attending a campaign event or running for any elected office), it should be done on their own time using their own resources to avoid any impression that they are representing Maxtran or acting on the company’s behalf.
SECTION II. CUSTOMERS AND BUSINESS PARTNERS
BE HONEST AND FAIR IN ALL BUSINESS DEALINGS
We are all required to be honest and fair in dealings with our customers, suppliers, fellow team members, the company, competitors and other members of the business community. This means ensuring that our behavior reflects our company’s standards for ethics and integrity and that our actions are in the company’s interests.
AVOID CONFLICTS OF INTEREST
All team members are expected to always make decisions based on sound business judgment and in the best interest of Maxtran. A conflict of interest can exist when a personal interest, relationship or opportunity for personal gain interferes with your duties and responsibilities to the company. This includes offering gifts that compromise the business judgment of others or accepting gifts that can influence your professional objectivity. Simply put, team members must not use their position or the company for their own personal benefit. Here are some questions to ask:
• Does it interfere with the work I do for the company?
• Am I using company resources, relationships or assets for my own personal gain?
• Could it appear to be a conflict of interest to someone else?
• Does it compete with the company’s interests?
ANTI-CORRUPTION, IMPROPER PAYMENTS AND BRIBES
Maxtran is committed to honest and fair business practices that are consistent with the highest ethical and legal standards. Team members are prohibited from offering, providing, receiving or accepting bribes or anything of value to gain business, establish business relationships, influence decisions in the company’s favor or for any other reason. Team members must also avoid customary practices that could create the appearance of a bribe. The simple rule is do not offer, pay, receive or accept a bribe to anyone, anytime, anywhere. Our company is committed to compliance with all applicable laws and regulations including but not limited to, the U.S. Foreign Corrupt Practice Act (“FCPA”), the U.K. Bribery Act, and other laws and regulations that relate to corruption, bribery, money laundering, or support for terrorism. All team members involved in international transactions must consult the trade compliance policies for proper guidance on all import and export transactions and follow the international trade and export control laws. Country prohibitions, boycotts and embargoes, denied parties and restricted goods requirements must be followed before engaging in international transactions.
OUR ENVIRONMENT
We work to improve our environmental performance across our entire value chain from our suppliers through our operations and to our customers. Team members are expected to be good stewards of the environment
RESPONSIBLE SOURCING
Maxtran is committed to a responsible supply chain that includes conformity with all applicable rules and standards related to sourcing, manufacturing and labor, including the International Labor Organization (ILO) convention and its forced labor indicators. We expect our suppliers to source responsibly and to ban the use of forced labor in any of their operations. Team members must ensure we adhere to internal sourcing policies for the selection and evaluation of our suppliers.
COMPETITION AND ANTITRUST
We do not take any action that would prevent or inhibit fair and open competition. Treating our customers, suppliers and competitors fairly is the way Maxtran does business. To ensure that we comply with fair competition laws that promote competition in a free market:
• Do not discuss Maxtran’s business with competitors including: – Economic terms – Pricing – Market plans
• Do not enter agreements with competitors that include: – Arrangements to fix prices – Arrangements to fix territories or divide customers – Arrangements to prevent other competitors from entering the market
• Do not make false or misleading statements or comments about our competitors or their products or services.
• Make sure all statements are accurate and complete.
SECTION III. CONDUCTING BUSINESS WITH GOVERNMENT, HEALTHCARE AND EDUCATION-BASED CUSTOMERS
Maxtran values its federal, state, local government, healthcare and education-based customers. Serving these customers is a public trust and involves a variety of procurement and ethical laws and regulations. Our company conducts business with these customers in strict compliance with these requirements. In addition, we will never take any action that would create even the appearance of a conflict of interest. Our company strictly prohibits giving any gifts or gratuities to any government, healthcare, or education customer. Team members serving any of these customers are expected to know and follow all procurement and ethics laws and regulations in all countries where we operate In addition, all U.S. team members who work with these customers are expected to know and follow Maxtran’s Code of Ethics for Doing Business with Government, Healthcare and Education-based Customers. Any questions or concerns should be raised with the Legal Department.
INTELLECTUAL PROPERTY
Maxtran’s competitive strength is powered by our intellectual property – creative solutions and proprietary processes that solve customer problems and make it easy for them to work with us. Intellectual Property can take many forms — such as inventions, new products and functionality, ideas, copyrightable works (such as software, websites, publications and marketing materials), trademarks (including images, symbols, logos, brand names and tag lines), domain names, business and technical confidential information, and trade secrets. The assets are valuable to the company, and we protect our intellectual property through patents, trademarks, trade secret protection, and by taking precautions to prevent inappropriate disclosure, use, or loss of such information. We enforce our rights, and we respect the intellectual property rights of others.
SAFEGUARDING DATA PRIVACY AND CONFIDENTIAL INFORMATION AND TRADE SECRETS
Maxtran recognizes the importance of team members, customer and supplier personally identifiable information (PII) that helps us fulfill orders and serve our customer and provide benefits to our team members. When we collect, process and/or store PII we are committed to protecting it consistent with globally recognized privacy principles. All team members play a key role in keeping this data safe and Maxtran provides training on how to collect, use, share, store and destroy PII in an appropriate manner. Additionally, we all have an obligation to ensure that the company’s confidential information and trade secrets are properly protected. Confidential information and trade secrets include all non-public information that, if disclosed, might be of use to competitors, or the disclosure of which might be harmful to the company, including but not limited to pricing strategies, corporate strategic and marketing plans, financial information, customer information and lists, team member records, supplier and logistics information, databases, software and all other proprietary information and data. To protect all company information and assets, team members must follow the Team Member Handbook that provides guidance for creating, using or disclosing intellectual property, including confidential information and trade secrets. Precautions include:
• Follow company processes and only access systems for which you are authorized to ensure you are not inadvertently putting the company at risk.
• Do not discuss company business in public places and where you could be overheard.
• Ensure you are always in personal possession of your company issued electronic devices and that your passwords are complex, changed frequently, and limited to work systems.
• Do not transfer Maxtran information from protected company systems to USB or portable hard drives or to personal online file sharing services.
• Immediately report any loss or compromise of company systems or confidential information. Contact the Privacy Office, Information Security, or Legal department if you have questions regarding disclosure of information.
EXTERNAL COMMUNICATIONS AND SOCIAL MEDIA
Maxtran has a strong and respected reputation of being a trusted partner to our customers, team members and communities. To ensure we are speaking with one voice in support of our purpose – all team members must contact Corporate Communications and Public Affairs before communicating on behalf of the company. This includes media interviews, speaking engagements, social media as well as authoring articles, videos or podcasts. Team members are encouraged to share and repost public information approved by the company on social media and interact with our accounts. To strengthen and demonstrate our welcoming culture, we all have a responsibility to be respectful and ensure our statements don’t negatively impact the company or others.
Helpful tips:
• Do not post proprietary or confidential information.
• While you are always welcome to engage in productive discussions of team member-related topics such as the terms and conditions of employment, or otherwise participating in activity protected by the National Labor Relations Act or other employment and labor laws, ensure posts that express your personal opinion are not used to represent that of the company.
• At Maxtran, we win as one team. Do not use social media or post anything online that would harass, intimidate or threaten another team member, their family or violate the company’s Equal Employment Opportunity Policy, Workplace Behavior Policy or Workplace Violence Prevention Policy.
• Refer to Maxtran’s social media Policy and contact the Communications and Public Affairs team with any questions. If you become aware of an actual or potential conflict with our principles, you have the obligation to immediately report it through one of our many reporting channels.
SECTION IV. HUMAN RIGHTS PRINCIPLES
At Maxtran, the way we conduct business is as important as the products and services we provide. The principles set forth in this statement reflect Maxtran's philosophy about the way we will conduct our business on a global basis. They are applicable to all Maxtran employees worldwide and are approved and monitored regularly by Partners senior management. Diversity and Nondiscrimination: Maxtran respects and values diversity in its workforce, its customers, its suppliers, and the global marketplace. Maxtran will strive to create an inclusive environment for all team members and will comply with all applicable laws of the countries in which we do business. It is Maxtran policy to provide equal employment opportunities for all persons, regardless of race, creed, color, religion, sex, national origin, age, mental or physical disability, domestic partnership status, sexual orientation, gender identity, gender expression, veteran status, marital status or citizenship status, and to ensure that all employment practices such as recruiting, hiring, transfers, promotions, training, compensation, benefits, layoffs, and terminations are equally applied. Harassment Prohibition: All Maxtran employees are expected to treat their coworkers, and employees of Maxtran's customers and suppliers with dignity and respect. Maxtran will not tolerate harassment of employees by managers or co-workers, on or off-site. Maxtran strives to maintain a working environment free from ethnic, religious, racial, or sexual harassment. All complaints of harassment will be promptly investigated and treated with appropriate confidentiality. Child or Forced Labor: Maxtran will not employ anyone younger than the minimum employment age established by the respective country or local jurisdiction. In the event no minimum employment age is established, employees will not be younger than the age of compulsory education; or if no minimum age for compulsory education is established, employees will not be younger than age 14, and workers under the age of 18 should not perform hazardous work. Maxtran also expects its suppliers to comply with these standards when placing contingent workers on assignment with Maxtran. Maxtran will not allow prison, indentured, bonded, military, slave or any other forms of forced labor in our operations, and forbids harsh or inhumane treatment, including corporal punishment or the threat of corporal punishment. Working Hours and Minimum Wages: Working hours will follow all applicable laws and regulations. Maxtran requires employee compensation to comply with all applicable wage and compensation requirements as defined under applicable labor laws for regular work, overtime, maximum hours, piece rates, and other elements of compensation and employee benefits. Safety and Security: Maxtran will seek to provide a safe and secure business environment for the protection of our employees, products, materials, equipment, systems and information. Maxtran will minimize employee exposure to potential safety hazards by identifying, assessing, and minimizing risks by developing and implementing plans and procedures. Freedom of Association/Collective Bargaining: Maxtran will adhere to the applicable laws regarding the right to affiliate with lawful organizations without interference.
Written 6/23/2023-Revision 2
