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Promoting a Professional Workplace


The Company believes it promotes a positive workplace environment through the following:


  • Background investigations and reference checks - These investigations, which include verifying a candidate's education, employment history, criminal record, and professional references, are performed for individuals being considered for employment.
  • Delegation of Responsibility - Management has developed policies and procedures to ensure that employees to whom significant responsibility has been delegated have the necessary skills and experience.
  • Effective HR-related practices, such as training and regular performance evaluations.
  • Management and development - The Company has a Human Resources department that promotes the management and development of effective human resources programs.

Ethics Hotline Program
We continously monitor and enforce compliance with our Code of Ethics and Corporate Responsibility and other corporate policies through confidential and non-confidential reporting mechanisms. An anonymous hotline, mail, and email are the primary means for reporting fraud or ethics violations in a confidential manner. Face-to face meetings are also encouraged with the Company's General Counsel.


  • All issues are sorted and categorized (legal, ethics or other) by the Ethics & Compliance Officer, who reports to the General Counsel. All calls of a legal nature are handled by General Counsel.
  • These reporting procedures have been made available to all employees of the Company.

"Whistleblower" Policy
All information reported by our employees is reviewed by the General Counsel, HR Department and/or our Compliance Officer and follow-up investigations are conducted, as appropriate. The General Counsel ensures that there is no retaliation against any employee who has utilized our reporting mechanism to come forward with concern about their co-workers, supervisor or management.

Deterrence, Detection, & Remediation of Fraud
Our anti-fraud program and internal controls have been implemented throughout the Company and they are considered an entity-level control which management relies upon to establish the Company's "tone at the top" relative to fraud and financial reporting. The program and controls address each element of the Internal Control-Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission, generally known as the COSO framework. Accordingly, it is tested at Corporate, at Level 1 locations, and Level 2 locations selected for entity-wide testing and the use of an internal control questionnaire.

We evaluate the effectiveness of our anti-fraud program through a detailed analysis of specific organizational policies and procedures. Through discussions with management, each part of our Ethics Program is compiled and reviewed for appropriateness and availability to appropriate personnel.