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Accounting and Auditing Matters The unethical systematic recording and analysis of the business and financial transactions associated with generally accepted accounting practices. (Examples include: misstatement of revenues, misstatement of expenses, misstatement of assets, misapplications of GAAP principles, wrongful transactions.)
Antitrust Activity Oral or written agreements, arrangements or understandings with other business parties to fix prices; boycott specific suppliers or customers; allocate products, territories or markets; or exchange competitively sensitive information; as well as discussions regarding price, trade allowances or rebates, costs, competition, marketing plans or studies, production plans and capabilities or any other confidential information.
Conflict of Interest A conflict of interest is defined as a situation in which a person, such as a public official, an employee, or a professional, has a private or personal interest sufficient to appear to influence the objective exercise of his or her official duties. (Examples include: inappropriate vendor relations, bribery, misuse of confidential information, inappropriate customer relations)
Disclosure of Confidential Information Unauthorized and unlawful disclosure of corporately owned intellectual property or trade secrets, as well as employee, customer or consumer information, marketing and other corporate databases, marketing plans, business proposals and strategies.
Discrimination or Harassment Uninvited and unwelcome verbal or physical conduct directed at an employee because of his or her sex, religion, ethnicity, or beliefs. (Examples include: bias in hiring, bias in assignments, wrongful termination, bias in promotions, bias in educational decisions, unfair compensation, inappropriate language).
Embargo Laws and Anti-Terrorist Laws Violations of United States law and/or company policy prohibiting certain transactions (and facilitation of transactions) with countries, entities (including but not limited to banks) and persons determined by the United States to be sponsors of terrorism or other violations of human rights, including shipment of product to a county against which the United States has imposed a trade embargo.
Environmental Protection, Health or Safety Law Violation of any environmental law, regulation, corporate policy or procedure with respect to the handling and disposal of hazardous materials or the health and safety of other individuals.
Falsification of Contracts, Reports or Records Falsification of records consists of altering, fabricating, falsifying, or forging all or any part of a document, contract or record for the purpose of gaining an advantage, or misrepresenting the value of the document, contract or record.
Fraud/Embezzlement To appropriate (as property entrusted to one's care) fraudulently to one's own use. (Examples include: bookkeeping errors, misapplication of funds, and mishandling of cash)
Gifts and Entertainment Refers to the inappropriate offering, solicitation or accepting of items of more than nominal value from vendors, customers or other third parties in a capacity as an employee of the Company.
Illegal Payments to US and Non-US Government Personnel The unlawful payment or benefit to any local, state or federal governmental official or employee or any other person, either in the US or in another county, if such payment or benefit is either prohibited by law or was made with the intent to influence or affect official action. (Examples include, but are not limited to, giving or promising to give money or any item, service, entertainment, meal, gift or transportation of value to a governmental official if prohibited by law or if the intent is to influence specific, official acts.)
Improper Supplier or Contractor Activity Supplier or contractor activity in violation of corporate policies and procedures; improper supplier or contractor selection based on personal gain, improper negotiation or diversion of contract awards.
Labor Issues Includes violation of child labor laws, collective bargaining or labor union issues, forced labor, or other matters related to worker's rights.
Misconduct or Inappropriate Behavior Intentional wrongdoing; specifically: deliberate violation of a law or standard.
Perishable Agricultural Commodities Act (“PACA”) Concerns regarding compliance with provisions of the Perishable Agricultural Commodities Act (“PACA”), a United States federal statute that, along with comparable state laws, prohibits unfair, fraudulent or unethical business practices in connection with the importation, purchase or sale of perishable agricultural commodities in interstate and foreign commerce. (Examples: false or misleading statements in connection with any purchase, sale, consignment or other transaction involving perishable agricultural commodities; providing an accounting of sale or any other documents that do not truly and accurately reflect the details of the transaction; altering, forging or counterfeiting any inspection certificate issued under authority of the United States Department of Agriculture.)
Retaliation An act or omission taken in response to the employee’s report of apparent unethical conduct or an ethical concern; or the employee’s participation in an investigation of or proceeding concerning conduct reasonably believed to be unethical or in violation of laws, rules, policies or the company’s Code . Examples include termination, demotion, suspension or threat thereof; harassment, intimidation, coercion or retaliation in any other form that is perceived to result from a good faith complaint or assistance in the investigation of a good faith complaint, whether or not the complaint is ultimately proven to be unfounded.
Theft The act of stealing; specifically: the felonious taking and removing of personal property with intent to deprive the rightful owner of it.
Time Abuse Concerns about an employee or manager who is falsifying his/her work hours.
Unfair Trade Practices, Deception and Fraud Includes practices such as misrepresenting, creating misleading impressions, omitting important facts or making false claims about the Company's or its competitors' product or service offerings, as well as bribery and other similar exploitive or inequitable conduct.
Unsafe Working Conditions Failure of meeting requirements needed to perform all duties in a secure environment. Potential areas of harm. (Examples include: environmental damage, OSHA, EPA, supervisor directive, poor housekeeping)
Violation of Policy Willful or innocent actions that are in direct violation of company policy, procedures, code of conduct, and/or implied contractual responsibilities. (Examples include: non-disclosure agreements, hiring standards, safety, Internet usage, corporate guidelines)
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Other If you feel that the definitions above do not describe the event, action or situation you are looking to report about, please use this header.