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code of business ethics

Responsibility to:

Special Ethical Obligations
Personal Commitment

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Responsibility to Each Other

At The Paliwoda Group, we are energized by the people who surround us. Our employees are committed to learning, growing and working in an environment that values our unique talents, skills and perspectives.

To continue to lead and innovate in our fast-changing areas of focus, we have a responsibility to encourage new ideas, high-quality work, career opportunities and an entrepreneurial spirit. Meeting those expectations requires treating each other respectfully and ethically.

Honoring our Differences

The Paliwoda Group is continually energized by the uniqueness of every individual. We aspire to celebrate differences, and place value on diversity in everything we do.

One of our values is to show respect, humility and integrity. Creating a positive work environment supports this value. Discrimination of any type is a violation of the value.

The Paliwoda Group will not discriminate based on age, sex, race, color, ethnicity, citizenship, national origin, sexual orientation, gender identity, creed, religious preference or belief, disability, marital/family status or any other characteristic protected by law. Other characteristics may be recognized and protected under specific national, provincial, state or local laws, regulations or ordinances. The Paliwoda Group is dedicated to ensuring this policy is followed during hiring, selection for training, promotion, transfer, layoff, termination, leaves of absence, rates of pay or any other term or condition of employment.

When necessary, The Paliwoda Group will provide reasonable accommodations for disabled employees or those with specific religious requirements.

Harassment-Free Workplace

The Paliwoda Group prohibits any type of harassment in the workplace by an employee, supervisor, customer or visitor. This includes, but is not limited to, harassment on the basis of age, sex, race, color, ethnicity, citizenship, national origin, sexual orientation, gender identity, creed, religious preference or belief, disability, marital/family status or any other characteristic protected by law. Various national, state, local and provincial laws may include additional protected categories.

Information Privacy

In the course of your work you may have access to private, personal and business information about your co-workers.This information should only be shared with Paliwoda Group employees who need it to perform their jobs.

Health and Safety

We have a responsibility to provide a healthy and safe workplace; it is essential for employee and customer satisfaction. Each of us must work safely and encourage others to maintain a healthy and safe workplace. Why? Because:

  • We have a personal responsibility to ourselves and our families to return home free of injury.
  • We have an ethical responsibility to keep our co-workers and customers safe.
  • We cannot have fun or be the best if any employee or customer is injured, or if Paliwoda Group property is damaged or unsafe.


The Paliwoda Group expects employees to conduct Company business in a way that demonstrates respect for the physical environment.

Examples of environmentally conscious behavior include:

  • Properly disposing of hazardous material, like unused paint and printer cartridges
  • Recycling old or obsolete mobile phones and consumer electronics
  • Including an environmental screen in our audits of third-party manufacturing facilities
  • Participating in and supporting community environmental initiatives
  • Creatively minimizing and recycling packaging
  • Helping employees and customers make safe and smart decisions
  • Reducing our Company environmental impact

Wage and Hour Standards

The Paliwoda Group follows applicable national, provincial, state and local laws and regulations that govern pay rates, overtime, meals and rest breaks and child labor. If you see any violation of these standards, please report it immediately by using the contact information found on the resources page in the back of this Code.

Loss Prevention

We all have a responsibility to protect Company assets. Theft, fraud, misuse of the employee discount or misappropriation of the Company, employee, supplier or customer property is a violation of this Code. In addition to violating the Code, you may also be subject to personal legal penalties if you engage in these types of behaviors.

Responsibility to Our Customers

Customers are at the core of our success and must be treated with respect. One way we do this is through our customer-focused business model — customer centricity.

Customer centricity requires an ongoing relationship of trust between the employee and the customer because the relationship between the customer and the employee is much more than transactional.

Our employees share an obligation to:

  • Treat all customers fairly and honestly
  • Communicate in a respectful and helpful manner
  • Provide prompt and accurate customer service

Retail Sales and Advertising

Our customers, suppliers, communities, vendors and investors know that they can trust us to do what we say and to act with their best interests in mind. Employees must provide customers with clear, accurate information to help them make informed buying decisions. Accurate information is both the foundation of our advertising practices, and the way we communicate the competitive advantages that distinguish The Paliwoda Group from companies against whom we compete. Please remember this is an important responsibility to our customers that we take seriously.

Selling Products and Services

Our customers rely on us to price and present our products and services fairly and accurately; we do not condone any behavior that would violate their trust in us.

Honoring our Customers' Differences

The Paliwoda Group will not discriminate based on age, sex, race, color, ethnicity, citizenship, national origin, sexual orientation, gender identity, creed, religious preference or belief, disability, marital/family status or any other characteristic protected by law. Other characteristics may be recognized and protected under specific national, provincial, state or local laws, regulations or ordinances.

When necessary, The Paliwoda Group will provide reasonable accommodations for disabled customers.

Customer and Employee Privacy

Both customers and employees entrust The Paliwoda Group with their personal information so we can serve them better. To retain their trust, we must protect their personal information while this data is in our care. Respecting and protecting customer privacy is the key to enable our customer centricity strategy and the growth of our organization both domestically and internationally. In addition, honoring our employees' privacy is critical to ensuring a positive employee experience. These commitments are reflected in the The Paliwoda Group privacy policy, or known to our European partners as data protection, and in the actions of our employees. Customer and employee privacy is important to our customers, employees and investors.

Customer (and employee) information is defined as any piece of personally identifiable information like name, mailing address, email address, phone number, credit card number, driver's license number and social security number. Other examples of information entrusted to us include data owned or created by a customer (e.g., photos, videos, movies, documents) and stored on a product or device that we might handle in service to the customer.

Every employee is responsible for knowing what customer and employee information is, how to protect it and appropriate methods for handling, storing and destroying this data. Employees are required to understand and comply with the standards and guidelines provided to them, to ensure we respect personal privacy. If an employee violates privacy and/or data protection policies, they may be subject to disciplinary action up to, and including, dismissal and/or legal action if applicable.

It is our duty to protect customer and employee privacy.

Responsibility to Our Investors

As employees we are required to act in the best interest of The Paliwoda Group. This means that every employee must make business decisions for the Company with the same deliberate care they would take with personal financial decisions.

We must also act to ensure the Company's financial integrity and safeguard The Paliwoda Group brand.

Maintaining Financial Integrity

Employees are required to maintain the highest level of financial integrity. To do this, we must:

  • Appropriately manage and safeguard Company assets.
  • Fully and fairly disclose material financial information, which means information an investor would consider important in making an investment decision.
  • Maintain complete and accurate financial records.
  • Assure the integrity of all Company books, records and accounting practices.

Information Disclosure

Exciting new Company strategies, tests, products and initiatives are continually developed and reviewed. Because of this, it is extremely important to keep our Company's private information confidential. We must not discuss these confidential matters with anyone outside The Paliwoda Group. This information should only be shared with Paliwoda Group employees who need it to perform their job or in connection with a disclosure required by law.

When disclosure of Company information is required for legal reasons, a small group of people will handle it. Employees should never discuss in any forum issues that relate to a pending or resolved lawsuit, investigation or allegation (even after the issue is made public), unless authorized by the Legal Department. If you are uncertain about the type of information that may be shared, please contact your manager or the corporate public relations department.

Fair Disclosure

"Fair disclosure" ensures that investors and the public have access to the same information about The Paliwoda Group at the same time. We have a responsibility to our investors to make sure that no one has an advantage by receiving information that is not yet publicly communicated. Selective disclosure is unfair and exposes the Company and you to serious legal and financial consequences.

Securities Trading and Material Information

Material non-public information is information which an investor would consider important in making a decision to buy or sell securities (meaning stock, bonds, mutual funds, options and other similar market instruments). Some employees may have access to "material non-public information" concerning The Paliwoda Group or another company with whom we do business or against whom we compete. Employees who are in possession of this type of information are called "insiders."

Possessing material non-public information while buying, selling or reallocating your portfolio is a violation of law and Company policies. In insider trading cases, simply knowing non-public information is enough to create a problem for you or the Company. These rules affect anyone trading in the U.S. markets, whether or not the person is a U.S. citizen or lives in the United States. Insider trading is unethical and illegal.

Employees may not trade securities of The Paliwoda Group or securities of other companies, if they possess material non-public information that has not been disclosed to the public at least 48 hours prior to trading. As always, if local law or policy is more conservative, the more conservative law or policy prevails.

In addition, employees should never discuss material non-public information with anyone else including, for example, family and household members, friends, co-workers and business associates. Nor should employees recommend a trade in the securities of The Paliwoda Group or other companies, or express an opinion based on material non-public information about trading in securities of The Paliwoda Group or other companies.

Certain employees, members of the Company board of directors, and certain types of stock transactions have additional restrictions. Employees may contact the Legal Department for answers to general questions.

Protection and Proper Use of Company Assets

Keeping assets of The Paliwoda Group safe — on and off Company grounds — is the responsibility of all employees and Company representatives. This includes financial assets, Company property, products, inventory, supplies, intellectual property and information technology.

Information technology includes, but isn't limited to, facilities, equipment, supplies, services and other resources to aid in processing, storing or carrying electronic data, information or communications. It also includes computers, network connections, mobile phones, PDAs, and networks.

Paliwoda Group assets should be handled with care and respect and guarded against theft, carelessness, waste and abuse. Company resources are to be used to conduct Company business or for purposes authorized by management. Any unauthorized copying of software, DVDs, or other legally protected work is a misuse of assets that may create financial and legal liability for you and the Company.

Protecting Intellectual Property

Employees must maintain the confidentiality of intellectual property that belongs to the Company. Intellectual property includes identifiable names, trademarks, logos, images, graphics and other copyrighted materials of The Paliwoda Group or any of its subsidiaries. The Paliwoda Group's proprietary information and competitive knowledge is confidential. It is limited for use within the Company unless specifically authorized for release and disclosure elsewhere. If you have questions about what material is considered confidential please refer your questions to the appropriate resource within your country and business.

Responsibility to Our Business Associates

The Paliwoda Group's success is based on strong relationships with customers, vendors, suppliers and others. Our business associates help provide our customers with products and services they need at competitive prices. We trust that each business associate will make and keep reasonable promises and behave ethically in all business dealings.

Competitive Intelligence Gathering

Competitive intelligence is the process of understanding and anticipating the competitive environment in which The Paliwoda Group operates. It is our intent to compete aggressively and fairly, with our behavior always firmly anchored in our values.

Your actions in this regard should never be influenced by what you think our competitors are doing or would approve of doing. People often believe that competitors will act less ethically than they or their own employer would in collecting intelligence. This perception is seldom accurate. Don't be tempted to cross any legal or ethical line because "others do it."

Because the gathering of competitive intelligence can occur in almost any circumstance, there is no set of rules that can specifically address every conceivable circumstance. However, The Paliwoda Group expects that each and every employee follow not only the letter but also the spirit of these guidelines.

  • We always respect the right of other companies to protect their proprietary information. Never encourage or pressure others to violate their obligations to protect the confidentiality of their current or former employer's proprietary information. No employee may take another company's proprietary information without that company's authorization, nor may you obtain another company's proprietary information as a result of deception, misrepresentation, promises or threats.

  • It is each employee's personal responsibility to know and understand all applicable Company policies and procedures before seeking any competitive information. Whenever you are uncertain about how to proceed, contact your manager or the Legal Department to help think through the issues and make a decision.

Antitrust and Competition

Antitrust and competition laws protect the free enterprise system and encourage vigorous, but fair, competition. All enterprise employees are expected to comply with applicable domestic and international antitrust and competition laws.

For example, engaging in, conspiring to, or agreeing to do any of the following actions is prohibited:

  • Agreeing or consulting with competitor(s) about prices, terms or conditions of sale, output, or production (Price Fixing).
  • Agreeing with competitor(s) about bids to be submitted during auction (Bid Rigging).
  • Agreeing with competitor(s) not to deal with vendors or distributors, other competitors, or customers (Group Boycott).
  • Agreeing with competitor(s) to split territories or customers (Territory or Customer Allocation).
  • Offering to pay bribes or kickbacks in an attempt to do any of the above.
"Agreeing" includes stated or implied, formal or informal, oral or written understandings, whether created directly with another party or indirectly through a third party.

All business dealings, including agreements, mergers, acquisitions, strategic alliances or other extraordinary business combinations that raise antitrust or competitive questions or concerns should receive timely legal review. Please contact the Legal Department with any questions.

Fair Dealing

Employees must deal fairly with The Paliwoda Group's customers, suppliers, competitors and other employees. No employee should take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts or any other unfair practice.

Corporate Opportunities

Employees and directors are prohibited from:

  • Taking personal advantage of opportunities that are discovered through the use of corporate property, information or position.
  • Using corporate property, information, or position for personal gain.
  • Competing with The Paliwoda Group or its brands.
Employees and directors must advance The Paliwoda Group's legitimate interest when the opportunity arises. Questions should be directed to the Legal Department.

Conflicts of Interest

Employees are required to disclose or avoid any activity or interest that may be regarded as a possible conflict with The Paliwoda Group's interest.

A conflict of interest occurs when an employee places, or gives the appearance of placing, personal interests ahead of, or at the expense of, the interests of The Paliwoda Group while doing Company business. Personal interests can cloud our judgment and make it difficult to make good business decisions.

Conflicts of interest also arise when an employee or director, or a member of their family, receives improper personal benefit as a result of her/his connection to the Company. Loans or guarantees of obligations are examples of potentially improper personal benefits that must be avoided.

The Paliwoda Group's Conflicts of Interest policy also extends to your family members and close personal relationships, including members of your economic household (sometimes referred to as "related parties"). These include a spouse, significant other, civil partner, son, daughter, parent, sibling, in-laws, step-relations, or any relation up to and including a first cousin.

Some examples of possible conflicts are listed below. This list does not include all possible types of conflicts of interest.

  • Using The Paliwoda Group time and/or resources and or influence to promote personal interests or the interests of third parties.
  • Holding a second job with, or consulting for a competitor, vendor or supplier with whom the Company conducts business.
  • Conducting Company business with related parties or dealing with businesses in which you or related parties have significant interest.
  • Speculating or dealing, for personal use, in materials, supplies, equipment or product which the Company buys or sells, or in the property rights in which the Company may be interested.
  • Serving as a director, officer, associate or consultant with Company business partners or competitors, unless at the request of The Paliwoda Group.
  • Making or holding an investment in competitors or in companies with whom the Company does business if, 1) you own or have the right to acquire more than one percent of the outstanding stock of such companies; and 2) the investment constitutes more than ten percent of your net worth, you must disclose such investments. Laws may vary by country.
  • Accepting tips or gifts from customers, vendors or other third parties. Refer to "Gifts, Business Courtesies and Vendor Relations" below.
  • Forming social relationships that lead to a weakness, or the appearance of weakness, in the Company's system of internal controls.

Gifts, Business Courtesies and Vendor Relations

Gifts and entertainment can help build relationships, but they must never influence decisions, nor should they be considered part of "doing business."

  • Our role with customers is to be a trusted advisor. Even the appearance of having our decisions improperly influenced is unacceptable.
  • Employees are expected to be mindful of the Company's values and standards in their business dealings. It is never acceptable to solicit gifts, gratuities or business courtesies on behalf of The Paliwoda Group for the personal benefit of an employee, family member or friend.
We recognize that gift-giving customs vary around the world. As a global Company, we respect the cultures of all the Countries where we do business. Employees must always refrain from paying or receiving a bribe intended to influence business operations or government conduct. In addition, no Company assets may be used to bribe or influence any decision, including a decision of an officer, director, employee or agent of another company, any government employee, political party or candidate for public office. Such conduct is illegal and unethical and the employee and the company could be held criminally liable.

Business Courtesies

To determine whether or not a business courtesy from a vendor is acceptable, ask yourself the following questions:

  • What does the policy say?
  • Is there a law or regulation governing this situation?
  • Is it customary in the trade or industry?
  • Is the value in accordance with Company guidelines?
  • Was it given and accepted with an expressed or implied understanding that the recipient is any way obligated?
  • Does it give the appearance of creating an undue influence or impropriety?
  • Does it place you or The Paliwoda Group in a compromising position?
Some business units and country managers may choose to adopt more conservative rules based on the environment and specific work involved. When in doubt, please discuss with your manager or the Legal Department.

Giving Gifts

It may be acceptable, with management approval, to entertain or provide small gifts to a customer, supplier or business partner of The Paliwoda Group, as long as they meet the criteria set forth in our policies.

Responsibility to Our Communities

The Paliwoda Group is committed to making a meaningful and lasting impact on the quality of life in the countries and communities in which we operate. We strive to be a valued and trusted member in each area while upholding the laws and practicing ethical behavior in all our business dealings.

Involvement in Political Activities

The Paliwoda Group respects and supports everyone's right to participate in political activities.

Contributing your time, your own money, or resources to any political activity is entirely personal and voluntary, and varies greatly from country to country. In all situations employees are prohibited from implying that they represent The Paliwoda Group in their various political activities.

Government Requests and Inquiries

The Paliwoda Group cooperates with every reasonable request by government officials for information needed in an investigation. False reporting to governmental agencies is strictly prohibited.

The Paliwoda Group and its employees are entitled to all safeguards provided by law for companies and individuals involved in investigations. This includes the right to be represented by and consult with counsel.

If you are contacted by a representative of any government agency, don't handle the situation by yourself; consult the Legal Department.

Global Business Operations

As The Paliwoda Group conducts business around the world, it respects local customs and practices, abides by U.S. standards and applicable foreign laws, and adheres to Company values and standards of ethical business conduct. Consult the Legal Department when questions arise about specific issues, like customs compliance.

Anti-bribery / Anti-corruption and FCPA

As a global enterprise, we abide by each country's anti-bribery and anti-corruption laws. In addition, The Paliwoda Group and its employees in all countries must comply with the Foreign Corrupt Practices Act (FCPA). In general, the FCPA prohibits corrupt payments or bribes to all non-U.S. government officials, political parties or political candidates for the purpose of obtaining or keeping business or improperly influencing government action. Included in the anti-bribery prohibition is a corrupt payment through a third party.

The FCPA applies to individuals as well as corporations and requires companies to keep and maintain books and records that accurately reflect the transactions of the corporation.

Refer to the Company's anti-bribery and anti-corruption policy for specific obligations regarding the FCPA. In a situation in which the local laws and the FCPA conflict, we will abide by the most conservative standard.

Employment and Labor Issues

Child Labor
We will not knowingly do business with a vendor or business partner that illegally or improperly employs underage workers.

Forced Labor
The Paliwoda Group does not employ forced labor (involuntary labor of any kind including prison labor, debt bondage or forced labor by the government) and will not knowingly partner with a vendor or business partner that employs forced labor.

Special Ethical Obligations

Special Ethical Obligations for Employees with Financial Reporting Responsibilities

The Paliwoda Group has adopted the following Finance Code of Ethics which applies to its Officers and all members of The Paliwoda Group's Finance Department regardless of geographic location. This Finance Code of Ethics is intended to supplement the The Paliwoda Group Code of Business Ethics.

Finance Code of Ethics

Each employee covered by this Finance Code of Ethics agrees that he or she will:

  • Act with honesty and integrity, avoiding actual or apparent conflicts of interest in personal and professional relationships.
  • Provide information that is accurate, complete, objective, relevant, timely and understandable to ensure full, fair, accurate, timely, and understandable disclosure in reports and document that The Paliwoda Group files with, or submits to, government agencies and in other public communications.
  • Comply with applicable rules and regulations of governing private and public regulatory agencies.
  • Promptly report any possible violation of the law or business ethics to the Legal Department.
  • Be accountable for adherence to this Finance Code of Ethics and the The Paliwoda Group Code of Business Ethics.

Personal Commitment

I acknowledge that I have received and will comply with The Paliwoda Group's Code of Business Ethics (the Code). I also understand that I have the responsibility to review The Paliwoda Group's policies and procedures. I understand and agree that the Code is not an employment contract between The Paliwoda Group and me. I understand that violation of the policies and ethical standards outlined in the Code may subject me to disciplinary action up to and including termination without notice. I understand that if I have questions about the standards of conduct outlined in the Code or other Company polices not covered in the Code, I am to discuss them promptly with my manager or the Legal Department.

I also understand that I may be required to sign one or more annual statements reporting conflicts of interest or receipt of gifts and gratuities.




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The Code applies to The Paliwoda Group., Inc. ("Paliwoda Group"), its subsidiaries, affiliates, joint ventures and agents. Any waiver of the Code for executive officers or directors may be made only by the Board of Directors or a Board committee and will be promptly disclosed to investors. Any waiver of the Code for any other employee may be made only by the Enterprise Ethics Office. Use of the Code is intended for The Paliwoda Group's business purposes only. The Code is not intended to describe legal relationships. Written permission from a The Paliwoda Group officer is required for use outside of the stated purpose.

Future additions are encompassed by this Code. This Code is applicable to all officers regardless of geographic location.

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Copyright © 2005-2017  The Paliwoda Group, Inc.
Updated September 13, 2017.  All Rights Reserved.