Ethics and Anti-bribery Policy
It is our policy to conduct all our business in an honest and ethical manner.
Our obligations
We have a responsibility to deal ethically with our customers and suppliers, employees and the general public. It is not enough to just avoid unethical conduct; we will always treat people that we come into contact with during the course of business with honesty, equality, respect and integrity.
Bribery and Corruption
Receiving gifts, hospitality, and financial incentives
All business decisions will be made impartially and fairly, and not on the basis of gifts, gratuities or hospitality offered. Neither PrimeSourceOPC, nor its employees, will solicit or receive favors, gifts, hospitality, loans (or other financial incentives) or other benefits (including services and discounts as well as material goods) from any supplier, customer or competitor which influence their judgment.
Giving gifts, hospitality, and financial incentives
Neither PrimeSourceOPC, nor its employees will use gifts and/or hospitality with the intention of persuading anyone to act improperly or to influence a public official in the performance of his or her duties.
The only payments PrimeSourceOPC makes to third parties are for goods and services properly provided to PrimeSourceOPC, or for legitimate charitable donations. PrimeSourceOPC will not make any payment (either direct or indirect) to secure or maintain business, or for any other purpose to any government employee or the personnel of any customer, supplier, or competitor.
Facilitation payments and kickbacks
PrimeSourceOPC does not make, and will not accept, facilitation payments or “kickbacks” of any kind.
Donations
PrimeSourceOPC does not make contributions to political parties. We only make charitable donations that are legal and ethical under local laws and practices.
Ethical and respectable business practices
Marketing practices
PrimeSourceOPC will comply with all applicable standards of advertising and will not use marketing that is misleading or inaccurate. Advertising will always be in good taste. All claims made in advertisements will be fully supported by the necessary evidence.
Competition law
PrimeSourceOPC will comply with all competition and trade laws. All PrimeSourceOPC customers will be treated fairly, and no preferential trade terms or other treatment will be extended to any customer in violation of any law. PrimeSourceOPC absolutely prohibits consultations or any other engagement with competitors regarding prices, customers, or territories.
Environmental protection
PrimeSourceOPC believes that everyone has a responsibility to protect the environment and human health. No individual employed by PrimeSourceOPC will knowingly buy for use at PrimeSourceOPC, or dispose of, other than in accordance with the law, any chemical or other substance which is illegal.
Reporting practices and financial information
PrimeSourceOPC will record and report all necessary information, including accounting records promptly, accurately and in a complete format. All records will be retained as necessary.
All accounts and records should conform to accepted accounting principles and to all applicable laws and regulations.
Product integrity
Strict product integrity is necessary for PrimeSourceOPC to achieve its quality objectives and to maintain its reputation for quality products. PrimeSourceOPC will never willfully conceal defective work or material, falsify records, or make false certification or claims regarding its products.
Health and safety
Responsibilities to employees
PrimeSourceOPC believes that all of its employees should have a safe work place and equal opportunities for promotion and advancement. PrimeSourceOPC will comply with all health, safety, and other similar laws and regulations. PrimeSourceOPC is committed to maintaining safe working conditions in our facility.
All PrimeSourceOPC employees will enjoy a work environment free from harassment and discrimination. PrimeSourceOPC does not tolerate acts of discrimination or harassment. In particular, PrimeSourceOPC will not:
- unlawfully discriminate against anyone based on, for example, race, sex, age, sexual orientation, pregnancy, political affiliation, union membership, marital status, nationality, ethnic background, religion or disability; or
- violate a person’s dignity by engaging in harassment or abuse (on any grounds in any form), corporal punishment, mental or physical coercion, or the threat of any such treatment.
Human rights and ethical trading
PrimeSourceOPC is committed to human rights and ethical trading in its business activities and employment practices.
PrimeSourceOPC will comply with all local laws and regulations, instructions of competent authorities or appropriate local industry practices in relation to working conditions, including hours, wages and benefits (including minimum wages) and overtime hours.
PrimeSourceOPC does not tolerate or engage in illegal labor practices, in particular we do not:
- knowingly employ persons under 18 years old;
- use forced labor or involuntary prison labor;
- require anyone to hand over government-issued identification, passports, or work permits to PrimeSourceOPC as a condition of employment (except temporary handover for identification confirmation or government formalities);
- knowingly employ any persons below the age for completing compulsory schooling in accordance with local laws.
Ed Daniels
President, PrimeSourceOPC, LLC.
Updated: October 2021