NORDAM Corporate Ethics and Compliance Program

Standard for Ethical Business Conduct, adopted by our Board of Directors, summarizes the standards that must guide our actions. While covering a wide range of business practices and procedures, these standards cannot and do not cover every issue that may arise, or every situation where ethical decisions must be made, but rather set forth key guiding principles that represent Company policies and establish conditions for employment at the Company.

 

One of our Company’s most valuable assets is our reputation for integrity, professionalism and fairness. We should all recognize that our actions are the foundation of our reputation and adhering to this Code and applicable law is imperative.

Ethics and Compliance Policy Statement: It is the policy of NORDAM that its employees shall at all times conduct business with the highest ethical standards and comply with the letter and spirit of all laws that apply to NORDAM’s business activities to avoid even the appearance of impropriety. NORDAM expects its employees to understand and comply with this policy at all times in carrying out their duties; there may be serious consequences for NORDAM and the individual employee for violations of the law and of NORDAM’s policies, procedures and guidelines.

 

Integrity is one of the three highest corporate values, the two others being excellence and innovation. High legal and ethical standards are the foundation of our public acceptance and also serve as the basis for our relationships with one another. Therefore, the integrity of our dealings with one another – regardless of our positions – is a matter of considerable importance to us at NORDAM. This Manual sets forth the minimum ethical standards applicable to our business conduct.

Policies, procedures and guidelines applicable to our business operations are included on the Company’s intranet site and in the NORDAM Policy Manual.

The Ethics Officer is responsible for the direction and oversight of ongoing compliance under the Program. The Ethics Committee is responsible for advising the Ethics Officer and assisting in the development and implementation of the Program.

To promote compliance with applicable laws, rules, and regulations, the Company conducts mandatory compliance training for its employees.

The Company encourages all employees, officers, and directors to report any suspected violations promptly and will thoroughly investigate any good faith reports of violations. The Company will not tolerate any kind of retaliation for reports or complaints regarding misconduct that were made in good faith. Open communication of issues and concerns by all employees without fear of retribution or retaliation is vital to the successful implementation of the Code and the future success of NORDAM.

 

The Company maintains a phone-based reporting mechanism through which employees can submit an anonymous report or seek guidance without fear of retaliation. This reporting system can be accessed by calling 866-549-4983 in the US, 0-800-89-0011 in the UK, and 001-800-462-4240 in Mexico.

In validating that the Program serves as an effective tool in detecting and preventing unlawful or unethical conduct by employees, the Company takes reasonable steps to ensure that the compliance program is followed, including monitoring and auditing to detect criminal conduct and to evaluate periodically the program’s effectiveness.

 

Audits may be conducted as part of an investigation or as a proactive means of monitoring compliance in areas of actual or potential risk.

Enforcement standards are publicized in the Company’s Code of Business Conduct and Ethics, the Compliance Manual, and the Employee Guidelines, all accessible on the Company’s intranet site.

 

It is the policy of NORDAM to (i) take steps to prevent and detect criminal and other unlawful conduct, (ii) cooperate with any governmental investigation, and (iii) in the event the law or NORDAM’s policies are violated, to take the necessary steps to identify the persons responsible and to take appropriate actions, including disciplinary action, up to and including termination.

All reports of alleged non-compliance and violations will be responded to appropriately to investigate the offense and to prevent further similar offenses. Violations that involve illegal behavior will be reported to the appropriate government authorities.

We reserve the right to make changes to this Program at any time. To request additional information regarding the Company’s compliance program, contact:

Phone: 918 401 5816
E-mail: compliance@NORDAM.com