A. Respect of Government and the Law

 

CE Process is committed to meeting or exceeding all laws and regulations wherever we conduct our business activities. The Company expects every employee to know the laws and policies that apply to their CE Process activities, and to conduct them with uncompromising honesty and integrity.

 

Of course, some business activity is not governed by any law, and some laws and regulations set unacceptably low standards of behavior – far lower than CE Process sets for itself. In these situations, an employee should be able to answer “yes” to the following questions before taking action:

 

• Is this action the "right thing to do?"

• Would this action withstand public scrutiny?

• Will this action uphold CE Process’s reputation as an ethical company?

 

If the answers are not an unqualified “yes,” we don’t do it.

 

B. Respect in the Workplace

 

1.  Personal Behavior in the Workplace

CE Process fundamental policy is that we will treat all of our CE Process  colleagues with respect.

 

The Company strives to provide a safe, healthful and productive work environment. This includes being free of violence for our employees, contractors, visitors, etc. Each employee has a personal responsibility to other CE Process employees and to the Company to help eliminate actions or circumstances which undermine this environment.

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1. Child Labor and Worker Exploitation Policy

CE Processdoesnotusechildorforcedlaborinanyofour global operations. We do nottolerateunacceptableworkertreatment,suchasexploitationof children, physical punishment or abuse,or involuntary servitude. We expect our suppliersandcontractors with whom we do business touphold thesamestandards.Shouldapatternofviolation of these principles become known to the Company and not be corrected, we will discontinue the business relationship.

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2. Wage and Hour Practices

CE Process pays employees a competitive wage, as benchmarked with other leading companies. Consistent with our principle of valuing personal mastery, we reward employees for improving their skills and capabilities. At a minimum, we comply with all applicable wage and hour laws, rules and regulations, including minimum wage, overtime and maximum hours.

 

3. Health, Safety and Environmental Policies

The Health, Safety and Environmental (HS&E) policies are derived from principles, values, legal requirements and regulatory requirements. Compliance with the law is a CE Process Core Value and it is the single highest priority for the Company’s HS&E programs.

 

The policy is translated into action by standards of performance (Mandatory What’s), standard operating procedures (Mandatory How To’s), and current best approaches (Voluntary System Guidance), and reinforced by mandatory annual internal audits. A regular reassessment of the standards structure promotes continuous evaluation of the system to improve performance.

CE Process applies a single performance standard to each of its worldwide manufacturing facilities. This is reinforced by training and mandatory annual internal audits. Facilities have flexibility in how they achieve the standard, so that local circumstances can be considered and costs can be controlled.

 

The Company uses internal audit scores and performance against a set of critical measures to assess how effectively sites are implementing the global standard. These measurements are endorsed by Company management and are conducted semi-annually.  Overall results are reported to Director of Technology.

 

Safety & Health Policy

CE Process is committed to having safe and healthy operations around the world to protect the life and health of its employees and the community surrounding its operations, to protect its assets, to ensure business continuity and to engender public trust. It is the responsibility of every employee to understand and be responsible for incorporating safe behavior in daily business activities.

 

We believe that success can be reached only through people.  We focus our energy to protect employees, contractors and everyone involved with the company, including suppliers and customers.

 

CE Process believes that accidents are preventable.  We integrate Safety and Health in the daily management of our business and we development our daily work with a perspective of prevention of accidents.

 

We perform identification of hazards and to manage them with appropriate risk assessments and subsequent actions to minimize danger, we establish emergency and contingency plans to deal with residual risks.

 

Our Company Safety and Health management system is based on the concept of continuous improvement.  We monitoring of safety and health performance as well as on the analysis of incidents that produce injuries and of workplace activities.

 

 

Environmental Quality Policy

CE Process has historically sought, and continues to seek, to achieve clean, safe, incident-free operation at all of our worldwide sites. This policy is assured by internally imposed standards of operation applied worldwide, which frequently go beyond the letter and the spirit of those laws and regulations that apply locally.  This commitment to responsible operation is implemented by the sites following formal environmental programs.

 

CE Process Environmental Quality Policy, which is applicable to all of the worldwide businesses, states that we will continually strive to improve the environmental quality of our products, packaging and operations around the world. To carry out this commitment at our sites and in all our operations, it is CE Process policy to:

 

• Reduce or prevent the environmental impact of our products in their design, manufacture, distribution, use and disposal whenever possible. We take a leading role in developing innovative, practical solutions to environmental issues related to our products, packaging and processes. We support the sustainable use of resources and actively encourage reuse, recycling and composting. We share experiences and expertise and offer assistance to others who may contribute to progress in achieving environmental goals.

• Meet or exceed the requirements of all environmental laws and regulations. We use environmentally sound practices, even in the absence of governmental standards. We cooperate with governments in analyzing environmental issues and developing cost-effective, scientifically based solutions and standards.

• Continually assess our environmental technology and programs and monitor progress toward environmental goals. We develop and use state-of- the-art science and product life cycle assessment, from raw materials through disposal, to assess environmental quality.

• Ensure every employee understands and is responsible and accountable for incorporating environmental quality considerations in daily business activities.

 

1. Conflict of Interest

Business, Financial and Personal Relationships

All employees are obligated to act at all times solely in the best interests of the Company. A conflict of interest arises when an employee has a personal relationship or financial or other interest that could interfere with this obligation, or when they use their position with the Company for personal gain. The Company requires that employees disclose all potential conflicts of interest and those they promptly take actions to eliminate the conflict when the Company requests them to do so.

 

Gifts, Entertainment and Gratuities

We conduct our business on the basis of the superior value of goods and services we buy and sell. Our policy on gifts, entertainment and gratuities is designed to preserve and maintain CE Process reputation as a global enterprise, which acts with integrity and bases decisions only on legitimate business considerations. Receiving gifts, entertainment or other gratuities from people with whom we do business is generally not acceptable because  doing  so could imply an obligation on the part of the Company and potentially pose a conflict of interest.

 

Improper Use of Company Assets

The Company does not permit improper use of Company assets. Improper use occurs when an employee uses Company property or information for personal gain or advantage, or for the advantage of others outside the Company, such as friends or family members. Improper use also occurs when Company property or technology is used for more than limited or incidental personal use or used in violation of other Company policies.

 

1. Employee Privacy

CE Process respects employee privacy and dignity. We will only collect and retain personal information from employees that is required for the effective operation of the Company or as required by law. We will keep that information confidential and release it only to those who have a legitimate need to know.

 

C. Respect in the Marketplace

 

1.Product Safety

CE Process ensures the safety of our products, packages and operations for our employees, customers and the environment. We consider this to be a requirement for conducting responsible business, and an essential element of building and maintaining public trust in our products. We carefully evaluate the safety of all products and before they go to market, using well-established risk assessment methods to understand both hazards and potential exposures. These evaluations are a mandatory part of the company’s product development process, and begin during the early stages of a product’s design. The same safety standards are used everywhere we sell or make products. As a guide, we administer our product safety programs by following these policies and principles:

 

• The Company’s products and packages will be safe for costumers and the environment when used as intended.

• The Company will seek to ensure that our operations are safe for our employees, neighbors and the environment.

• The Company will meet or exceed all applicable legislative and regulatory requirements with respect to product safety.

• The Company will provide interested parties with relevant and appropriate factual information about the safety of our products.

 

2.Bribery and Improper Business Dealings

Commercial Bribery

Commercial bribery is illegal and subject to criminal penalties in many countries, including the United States. Any personal payment or bribe to individuals employed by CE Process customers or suppliers, or receipt of a bribe or personal payment by CE Process employees is strictly prohibited. Even in locations where such activity may not, technically speaking, be illegal, it is absolutely prohibited by Company policy. CE Process competition for business is conducted fairly and on the merits of our products and services.

 

Improper Payments to Government Officials the Company prohibits improper payments to

government officials. Improper payments are direct or indirect payments, whether in cash or in other things of value (such as lavish entertainment), to a government official or political party in order to influence acts or decisions, to receive special treatment or personal gain, or to obtain or retain business. While certain minor payments to certain non-U.S.  Government officials made to expedite or secure the performance of certain routine government actions may not violate the law, employees must obtain the approval of the Legal Division prior to making such payments and any payments must be reported to appropriate Company Tax personnel. All employees must abide by the U.S. Foreign Corrupt Practices Act, as well as local laws concerning bribery.

 

Money Laundering and Product Diversion Avoidance Money laundering is an attempt by individuals or organizations to hide the proceeds of their crimes or to make those proceeds look legitimate. Diversion occurs when products sold by the Company are distributed into markets or sold to customers other than originally intended in violation of a contract, law or regulation. The Company forbids knowingly engaging in transactions that facilitate money laundering or result in unlawful diversion.

 

3. Fair Dealing with Suppliers and Customers

CE Process’s  success depends on building productive relationships with our suppliers and customers based on integrity, ethical behavior and mutual trust.

 

Treating Suppliers Appropriately

Our suppliers are valued partners in the success of our business. Our relationships with them must be characterized by honesty and fairness. Suppliers are selected on a competitive basis based on total value, which includes quality, service, technology and price. Terms and conditions defining our relationship with suppliers are communicated early in the supplier selection process and agreements to such terms and conditions, or any acceptable modifications, are reached before work begins. Included in these standard terms and conditions are CE Process policies regarding payment terms, confidentiality, the use of intellectual property, worker health, safety and labor practices, and environmental requirements.

 

Supplier Diversity

Supplier Diversity is a fundamental business strategy for CE Process.  Our customers and suppliers become more and more diverse every day, so our success depends on our ability to understand diverse costumers’ needs and to work effectively with customers and suppliers around the world. Diversity is the uniqueness that everyone – from suppliers to employees to corporate officers – brings to fulfill CE Process’s  Purpose, Values and Principles. We will continue to expand and build our Supplier Diversity results.

 

Treating Customers Appropriately

CE Process recognizes that our customers have individual needs and expectations representing unique opportunities for mutual success. The Company treats all customers equitably and does not give any customer an unfair advantage over another competing customer. The Company does not discriminate by customer size, type, channel, or business strategy.

 

 Treating Competitors Appropriately

The Company’s goal is to win consumers for its products by virtue of the products’ quality and value, and not by creating unfair disadvantage for its competitors.

 

Fair Competition

We believe in competing fairly because we all benefit from fair, free and open markets. We compete strictly on the merits of our products and services and make no attempts to restrain or limit trade.

 

Specifically,

• We never discuss such matters as prices, pricing strategies, product or marketing plans, or terms of sale with competitors. Should a prohibited subject come up during the course of a trade association or other meeting, we must leave the meeting and inform our leadership or legal counsel.

• We do not enter into agreements with our competitors concerning prices, production volumes, customers or sales territories.

• We do not link purchase of one product to another or compel suppliers to buy from us to retain their CE Process business.

• We do not disparage the products or services of a competitor.

• We collect competitive information through proper public or other lawful channels but do not use information that was obtained illegally or improperly by others, including through misrepresentation, invasion of property or privacy, or coercion.

 

Advertising/Promotion Policies

A basic operating principle of the Company is honesty. Neither deceptive advertising nor questionable promotional activity can ever be justified. These are vital tenets of our dedication to consumers and essential to gaining and keeping their continuing loyalty to our brands.

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CE Process observes standards of commercial fairness in devising, using and selecting advertising and promotions, so our products succeed based on their own quality and performance and our reputation as a company, rather than by false or deceptive statements or comparisons.

 

4. Confidentiality and Consumer Privacy

Confidentiality

The Company requires employees to keep the Company’s confidential information confidential. Confidential information means:

 

• Non-public information known to employees  as a result of their position with the Company that might be of use to competitors or harmful to the Company if disclosed; and

• Non-public and personally identifiable information they obtain from other employees, customers or consumers.

 

Costumer Privacy

The intent of CE Process’s Privacy Policy is to create an environment of knowledge, confidence and trust that encourages costumers to exchange information with CE Process. That environment enables us to better understand and meet their needs, while reflecting our stewardship of their data.

 

CE Process believes in protecting the privacy of personal information. We strive to treat information provided by an individual as that individual’s, which has been entrusted to CE Process. We inform people about the use and handling of data they provide us. This includes informing costumers about the information we collect, what we do with it, and the choices costumers have concerning further uses of the information.

 

5. Communicating with the Media

Providing clear and accurate information to the media and general public maintains integrity in our relationships with the public. Because thisis so important, all CE Process business units have designated external relations or communications function responsible for communicating product information and Company positions on a range of issues.

 

D.Respect in Society and Our Communities

 

1.Community Relations

CE Process and its employees have a long-standing commitment to being good citizens and neighbors in all the places where we do business around the world.  We believe we have a responsibility to society to use its resources – money, people and energy – wisely.

 

2.Support of Universal Human Rights

CE Process is committed to universal human rights, particularly those of employees, communities in which we operate, and parties with whom we do business. To that end, CE Process practices and seeks to work with business partners who promote the following standards:

 

• Equal opportunity for employees at all levels and no discrimination or harassment based on any personal characteristics unrelated to job performance;

• A safe and healthy workplace protecting human health and the environment;

Working with governments and communities to improve the educational, cultural, economic and social well-being of those communities

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