INTERPLEX
CODE OF BUSINESS CONDUCT
Our Values
At Interplex Holdings Pte. Ltd. and our subsidiaries (collectively known as “Interplex” or “Company”), we believe that acting with integrity is not only the right thing to do but it also protects our Company and enables us to fulfill our obligations to our stakeholders. We believe that being successful is not only important but how we achieve our success is crucial.
Our Code of Conduct (“Code”) is the fundamental basis for our daily activities. Our Code, together with our Company policies, help our Employees to comply with laws and regulations, to make the right decisions and to take the right actions.
Our Code of Conduct (“Code”) is the fundamental basis for our daily activities. Our Code, together with our Company policies, help our Employees to comply with laws and regulations, to make the right decisions and to take the right actions.
Our Responsibilities
Our directors, officers, employees and other temporary staff worldwide (“Employees”) are expected to understand this Code and other Company policies and to comply with the same.
Our Employees are encouraged to raise any good faith compliance question or concern or any suspected violation of the Code involving our Company. The first step is to speak with a line manager or if that is not possible, the Employee may contact any of the following representatives:
To report compliance concerns, Employees may also reach out directly through the Company’s 24-hour, toll-free helpline which is operated by NAVEX Global, an independent third party (www.interplex.ethicspoint.com). More information relating to the Company’s helpline is available at https://interplex.com/corporate-social-responsibility/whistleblowing/. Reports will be reviewed diligently for actual or potential violations of this Code, other Company policies or other unlawful or unethical conduct.
We do not tolerate retaliation against anyone who raises a concern about a violation of the law, this Code or our Company policy in good faith or assists with an investigation. Confidentiality will be maintained at all times and information will only be disclosed on a need-to-know basis. Any Employee who engages in retaliation or who makes an allegation he or she believes to be false will be in violation of this Code.
Managers are required to raise and escalate to appropriate management members any concerns brought to their attention and those who ignore violations, or who fail to detect or correct them, could face disciplinary action. If a report to the management members is not appropriate, the reporting Employee should reach out to Interplex Legal Department (Corp.Legal@interplex.com) and/or the Senior Legal and Compliance Counsel which should report to the Board of Directors directly as necessary.
Failure by an Employee to comply with our Code, or our Company policies or the law may result in disciplinary action, up to and including dismissal or termination of contract or assignment.
Our Code is organized into 4 sections as follows:
Our Employees are encouraged to raise any good faith compliance question or concern or any suspected violation of the Code involving our Company. The first step is to speak with a line manager or if that is not possible, the Employee may contact any of the following representatives:
- Members of the Board of Directors
- Senior Leadership and Managers in the organization
- Human Resources (for employment, benefits and workplace issues)
- Legal Department (Corp.Legal@interplex.com) and/or the Senior Legal and Compliance Counsel (for interpretation of this Code and guidance about how to conduct business on behalf of Interplex in compliance with the law)
- Finance (for advice on this Code or Company policies related to financial, company controls and accounting matters)
- Information Technology (for concerns regarding cybersecurity or data incidents, potential or actual system and data breaches and inadvertent disclosures)
- Quality (for concerns regarding quality, safety and regulatory compliance of our products)
- Supply Chain Management (for concerns regarding safety, efficacy and regulatory compliance of our supply chain processes)
- Security, Safety and Health (for concerns relating to environment, workplace security, safety and health)
To report compliance concerns, Employees may also reach out directly through the Company’s 24-hour, toll-free helpline which is operated by NAVEX Global, an independent third party (www.interplex.ethicspoint.com). More information relating to the Company’s helpline is available at https://interplex.com/corporate-social-responsibility/whistleblowing/. Reports will be reviewed diligently for actual or potential violations of this Code, other Company policies or other unlawful or unethical conduct.
We do not tolerate retaliation against anyone who raises a concern about a violation of the law, this Code or our Company policy in good faith or assists with an investigation. Confidentiality will be maintained at all times and information will only be disclosed on a need-to-know basis. Any Employee who engages in retaliation or who makes an allegation he or she believes to be false will be in violation of this Code.
Managers are required to raise and escalate to appropriate management members any concerns brought to their attention and those who ignore violations, or who fail to detect or correct them, could face disciplinary action. If a report to the management members is not appropriate, the reporting Employee should reach out to Interplex Legal Department (Corp.Legal@interplex.com) and/or the Senior Legal and Compliance Counsel which should report to the Board of Directors directly as necessary.
Failure by an Employee to comply with our Code, or our Company policies or the law may result in disciplinary action, up to and including dismissal or termination of contract or assignment.
Our Code is organized into 4 sections as follows:
I. Our Business
We are committed to complying with all laws and regulations, whether local, national or regional that apply to our Company. Violations of law can result in significant harm to our Company including financial penalties, criminal proceedings and damage to our business relationships and reputation. It is therefore every Employee’s responsibility to be familiar with and follow the applicable laws, regulations and Company policies that govern the business activities in which the Employee engages.
Anti-corruption or Anti-bribery Laws
Many countries have strict laws covering bribery, corruption and similar kinds of fraud by companies, their employees and third parties such as consultants and agents. These laws include the Singapore Prevention of Corruption Act, the U.K. Bribery Act, the U.S. Foreign Corrupt Practices Act, the PRC Criminal Law, and the PRC Anti-Unfair Competition Law. We do not tolerate corruption of any kind whether relating to private individuals, government officials, private companies or public organizations and we require compliance with all anti-bribery and corruption laws in all markets and jurisdictions in which we operate.Anti-Money Laundering
Money laundering involves the concealment of the origin of money gained through illegal activities such as terrorism, fraud or bribery. We are committed to complying with applicable laws prohibiting money laundering and terrorism financing. We strive to maintain business relationships only with reputable customers, suppliers and companies whose business activities comply with legal requirements and whose financial resources are of legitimate origin. Employees are expected to report any payment or other unusual customer transaction that seems inappropriate or suspicious to Interplex Legal Department (Corp.Legal@interplex.com) and/or the Senior Legal and Compliance Counsel.Antitrust and competition laws
Many countries have laws concerning antitrust and unfair competition. These laws are designed to promote free and fair competition among businesses. Such laws generally prohibit (a) arrangements with competitors that restrain trade in some way such as price fixing, bid rigging, predatory pricing, (b) abuse of intellectual property rights, and (c) use of market power to unfairly disadvantage competitors. Violation of antitrust and unfair competition laws can expose our Company and individual Employees to criminal penalties, large fines and civil lawsuits. Employees are expected to comply with both the letter and spirit of all applicable antitrust and competition laws.Data Protection
Many countries have laws governing the storage and use of personal information or personal identifiable information. Such information includes information such as names, home addresses, phone numbers, salary or wage information, terms and conditions of employment, personnel file information or anything else which can be attributed to an individual person. We collect, process and use personal information or personal identifiable information only to the extent permitted by laws, regulations and our internal guidelines and policies.Accuracy of Company and Public Records
Our business records (including financial statements) must be accurate, fair and complete. Employees are expected to be familiar with and to comply with Company’s internal controls and policies and to ensure that our Company’s financial records and reports comply with all applicable laws and generally accepted accounting principles.II. Our People
As a global organization with Employees from many different nationalities and from all walks of life, we recognize and value the rich and diverse culture Employees bring to our Company. We believe that an atmosphere of fairness, mutual respect, cooperation and equal opportunity will allow our Employees to thrive
All Employees shall disclose, in writing, any personal, business, familial or social ties with any former or incumbent government officials to the Interplex Legal Department (Corp.Legal@interplex.com) and/or Senior Legal and Compliance Counsel. Further, if there is any other actual, potential or perceived personal conflicts of interest, the Employees shall disclose, in writing, to Interplex Legal Department (Corp.Legal@interplex.com) and/or the Senior Legal and Compliance Counsel.
Non-discrimination and preventing harassment
We provide equal opportunities for Employees and applicants for employment. Our employment decisions are based on business needs, qualifications, skills and competency to perform the job. We are committed to providing and maintaining a work environment where Employees are treated with dignity and respect. We have a zero-tolerance policy against harassment, including sexual harassment, and discrimination.Conflicts of Interest
We expect Employees when performing their work responsibilities to act in the best interest of the Company and to avoid any situation where their personal interests may conflict with those of our Company. A conflict of interest occurs when an Employee’s personal, social, financial or other activities or relationships interfere or have the appearance of interfering with his/her objectivity or loyalty to the Company. Employees are required to disclose to their managers any situation that presents the possibility of a conflict of interest before taking any action.All Employees shall disclose, in writing, any personal, business, familial or social ties with any former or incumbent government officials to the Interplex Legal Department (Corp.Legal@interplex.com) and/or Senior Legal and Compliance Counsel. Further, if there is any other actual, potential or perceived personal conflicts of interest, the Employees shall disclose, in writing, to Interplex Legal Department (Corp.Legal@interplex.com) and/or the Senior Legal and Compliance Counsel.
Gifts, Entertainment and Hospitality
We recognize that there may be in our day-to-day business activities, instances where we may offer and receive customary business amenities (like meals and entertainment) and gifts to build goodwill and strengthen working relationships. Any gift or entertainment offered must be reasonable and modest and consistent with ethical, cultural and professional practice and in accordance with our policies. Employees are expected to exercise care and good judgment when involved in the offering or receipt of any entertainment or gift to avoid the appearance of impropriety in both the amount and type of gift or entertainment offered or received.Safe and healthy work environment
We strive to maintain a safe and healthy work environment for Employees and visitors to our office premises and manufacturing facilities. We comply with all applicable health and safety laws and regulations in the locations where we operate. Employees and visitors are required to comply with our Company workplace policies and procedures where applicable and to always put environment, health and safety first.III. Protecting Our Assets
Use of Company assets
We provide our Employees with assets and resources such as computers, phones, information systems and software, funds, facilities, intellectual property and other company property necessary for them to do their jobs. Employees are personally responsible to safeguard and protect the assets entrusted to them and to use the assets with care and only for legitimate business purposes only. Incidental personal use of such assets and resources by Employees is permitted provided such use is limited in duration, does not violate our Code, Company policies or the law.Intellectual property and Confidential Information
Our intellectual property and our confidential information are important Company assets and must always be safeguarded and protected. Intellectual property includes copyrights, patents, trademarks, brand names and logos, research and development, ideas, inventions and trade secrets. “Confidential Information” includes any information that is not generally known to the public and would, if disclosed, put the Company at a competitive disadvantage or be beneficial to our competitors. Common examples of Confidential Information are financial data, pricing information, marketing strategies, costs, processes and technical data. Employees are to maintain confidentiality of information entrusted to them, except when disclosure is authorized and under the auspice of a confidentiality or other suitable agreement approved by Interplex Legal Department or is legally mandated.We may also be required in the normal course of our business to access and use assets belonging to others such as their intellectual property, proprietary and confidential information, or tools. Employees are required to fully understand and follow the terms and agreements with such other party and to use such assets only to the extent permitted.
IV. Our Community
We are good corporate citizens and we uphold the laws that govern our business in all of our areas of operations. We are mindful of our responsibilities to the communities and the environment where we do business.
Interplex Legal Department (Corp.Legal@interplex.com) and/or the Senior Legal and Compliance Counsel must be notified if a government official solicits a political or charitable contribution in connection with any government action related to the Company.
Environmental Protection
We respect the environment by complying with all applicable environmental laws in the countries where we do business. It is our goal to protect the environment and conserve resources in all countries in which we operate. Wherever possible, we strive to dispose waste and recycled waste appropriately.Political Contributions
We are politically neutral and we do not make political contributions to any individual or organization in any country in which we operate. Employees are however free to support community, charitable and political organizations and causes of their choice on their own time and resources. Employees must be careful not to give the impression that Interplex supports or endorses any political party, campaign or policy issue which Employees are personally involved in. Employees may not make political contributions on behalf of the Company. In case of any doubt, Employees should reach out to Interplex Legal Department (Corp.Legal@interplex.com) and/or Senior Legal and Compliance Counsel.Interplex Legal Department (Corp.Legal@interplex.com) and/or the Senior Legal and Compliance Counsel must be notified if a government official solicits a political or charitable contribution in connection with any government action related to the Company.
Working with Suppliers
Our relationships with our suppliers are important to our success. Suppliers are carefully selected based on how well their products or services fit our needs, the supplier’s reliability, their commitment to ethical business practices and the commitments they make in terms of price, delivery and quality.
15 August 2022
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