Our ethics policy is simple: we must each conduct all of our activities with the highest level of integrity and ethics, complying with the letter and the spirit of all applicable laws and regulations. In other words, we should avoid doing anything that may be, or even appear to be, illegal or unethical. All employees will always deal fairly and honestly with our vendors, customers, competitors, and each other.
Understand this Code: We all have a responsibility to make sure our ethics and business practices’ program works. To fulfill this responsibility, you are required to read this Code thoroughly and become familiar with it. If you do not understand something in this Code, seek out assistance from your supervisor.
Comply with this Code, IDC Policies, and the Law: Each employee must comply with the spirit and the letter of this Code, IDC policies, and all applicable laws and regulations. For employees this is a condition of continued employment. Failure to comply will result in disciplinary action, which may include immediate termination for cause.
Communicate Actual or Suspected Violations: We should all be alert and sensitive to situations that could result in violations of this Code, IDC policies, or the law. Each employee has an obligation to report any conduct that may be a violation.
Generally, these matters should be raised first with your immediate supervisor. This may provide valuable insights or perspectives and encourage resolution of problems within the appropriate area. However, if you are uncomfortable bringing this matter up with your supervisor, or you do not believe the supervisor has dealt with the matter properly, you should raise the matter with our Compliance Officer, who is our General Counsel and Chief Financial Officer or our Senior Vice President of HR and HS&E. All inquiries, however reported, will be handled on a confidential, “need-to-know” basis.
Regardless of how a report is made, no employee will suffer any retaliation of any kind for reporting in good faith a violation or suspected violation of this Code, IDC policy, or the law. In addition, no employee will suffer any retaliation for filing any complaint with any government agency or for exercising any legal right.
Violations of this Code or with the laws and regulations applicable to IDC’s business will subject an employee to appropriate corrective disciplinary action, up to and including termination for cause. In addition, any violations may also violate foreign, federal, state, or local laws and could subject an employee to individual civil or criminal prosecution, with accompanying potential damages, fines, and imprisonment.
Below are summaries of key IDC policies relating to ethics and business practices. Compliance with these policies is a condition of each employee’s continued employment. These are summaries only, and you should consult the Employee Handbook for full disclosure.
Conflicts of interest arise when there is opportunity for personal gain beyond the usual rewards of employment or when an employee’s interests collide with IDC’s interests. Each employee must avoid doing anything that compromises or appears to compromise his judgment or that places or appears to