OUR OBLIGATIONS
SUPPLIER CONDUCT POLICY
This Supplier Conduct Policy establishes the minimum standards to which suppliers shall adhere, unless where otherwise specifically stated as a recommended practice. Suppliers shall conform to any applicable legal requirements that are greater than the standards set forth herein this Supplier Conduct Policy, and should strive to develop practices for their employees that will increase their protection in the facility and overall work environment.
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Policy
THADDEA's structural foundation is based on integrity, dependability and the message of inspiration through Enhanced Tech Apparel and Products (ETAP). When dealing with suppliers, we expect at a minimum the implementation of these practices in the work place and compliance with the ethical standards we set.
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Accountability of Facility Operations
Manager of Facility: shall construct the programs, implement the policies and procedures of the facility as outlined herein the Supplier Conduct Policy.
Administrators & Supervisors of Facility: shall train the employees to be knowledgeable and to abide by the requirements of the programs, policies and procedures outlined herein the Supplier Conduct Policy.
Employees of Facility: shall abide by the requirements of the programs, policies and procedures outlined herein the Supplier Conduct Policy.
Facility Control Representative: shall institute, maintain and govern the programs, policies and procedures outlined herein the Supplier Conduct Policy.
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Obligations of Facility
Review of Risks
The supplier's facility shall have a documented review of risk conducted that includes; evaluation of potential facility, hazards, safety or environment risks and identifying methods that can help to decrease these risks.
Employee Training
Employees shall be trained when first starting their specific occupation of work, on initial and new assignments, when procedures change and on an annual basis.
Recorded Documents
The supplier's facility shall maintain training and incident records for at least 2 years and maintain a current review of risk.
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Ethical and Legal Business Practices
The supplier is required to be ethical with their business practices and fully conform with all applicable local, state, federal, national and international laws and rules including, but not limited to, those relating to child labor, wages, work hours, labor, health, safety and environment and immigration. Any supplier that adopts the Supplier Conduct Policy must comply with all pertinent manufacturing laws, local and government business laws within that country and support the Supplier Conduct Policy in accordance with the Ethical and Legal Business Practices and must apply the higher standard in cases of difference of conflicts.
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Mandatory Labor
The supplier shall not use any form of forced labor (indentured labor, prison labor or bonded labor) as a business practice.
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Child Labor
Any employee hired by the supplier must be at least 16 years of age or over the age for completion of the mandatory education; whichever age is higher will serve as the authorized working age. If an employee is under the age of 18 then they cannot be employed to work in hazardous conditions, which is the responsibility of the supplier to recognize such conditions.
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Minimum Age Standards
THADDEA and/or its associates may establish a higher minimum age requirement with certain industries or countries, and if established then communicated to the suppliers that it will effect
Those suppliers will be required to receive a proof of age before hiring the individual. The supplier must verify the individuals age by receiving from the individual an identification card (ID), birth certificate, voting identification card, driver's license or some other form of ID. Copies of these documents are to be stored in a physical file folder or on a computer for the entire period of the individual's employment.
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Mistreatment of Employees
The supplier is required to conduct themselves respectively and with dignity toward their employees. The supplier shall not tolerate any form of physical, verbal or psychological harassment or abuse toward an employee. The supplier must have some form of a written harassment and abuse policy and be able to provide upon request to THADDEA or authorized inspectors all documentation pertaining to any allegation of harassment or abuse.
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Prison Labor is Prohibited
The supplier is prohibited from using prison labor or providing subcontract work to prisons. This includes attaining any goods, services or materials that may be used to manufacture THADDEA apparel and/or products.
Discrimination
The supplier shall not engage in employment discrimination, including hiring, benefits, advancement, pay, discipline, termination or retirement, on the basis of sex, race, religious faith, age, disability, sexual orientation, ethnicity, marital status, political opinion, or social origin. It is the responsibility of the supplier to train its staff to recognize these types of discrimination and to make sure they are implementing and enforcing the nondiscrimination law of the country. The supplier must have some form of a written nondiscrimination policy.
Employees Freedom in Workplace
The supplier must provide employees the right to move freely throughout their assigned work areas during their hours of work, and allow them to have access to drinking water and the use of toilet facilities. The supplier must also allow employees the right to leave the workplace during meal breaks or after the work day hours have ended.
Dormitory for Employees
Suppliers that provide dormitory living for employees must provide environmentally livable, healthy, clean and safe living quarters and explain security practices and curfew policies to those employees in which they apply. The guidelines for where curfews exist must be sensible and structured so both national employees and foreign working employees are provided adequate time to rest and the opportunity to partake in activities during hours that are deemed non-working.
Treatment of Women
The supplier must comply with any country law that relates to pregnancy, childbirth, nursing, and including but not limited to the protection of pregnant women from hazardous work and the working hours of a pregnant women, which may be proposed by a licensed physician of the country.
The supplier shall not require women employees to perform a pregnancy test as a condition of hire or during their employment period. However, the supplier can provide a pregnancy test but only at the employees request, which then must be documented by the supplier and thereafter for any additional requests. In addition, no employee will be pressured or forced by the supplier to use contraception.
Women employees shall be permitted to maternity leave by the supplier, which guidelines pertaining to maternity leave are in compliance with the country law.
Freedom of Association and Collective Bargain
The supplier must act in accordance with the laws of the manufacturing country, and acknowledge the right of employees to engage in freedom of association and collective bargaining and to do such without obstruction, retribution, harassment or blacklisting.
Wages
The supplier must pay each employee at least the minimum wage required by law or the prevailing industry wage, whichever is higher, provide each employee a clear written report for each pay period, provide legally mandated benefits, which include holidays and leaves, and legal compensation to the employee when their employment period ends. The supplier must have a written leave policy implemented that provides the leave for legally required holidays, annual leave, sick leave, maternity leave, emergency leave for family and any other leaves that are permitted by country law. This leave policy must be able to be effectively articulated to the employees by the supplier.
Benefits
The supplier must provide their employees with all legally mandated benefits of the country.
Work Hours/Overtime
The supplier shall not require or compel their employees to work more than a total of 60 hours a week or less if laws of the manufacturing country permit and shall comply at all times with the legally mandated work hours, breaks, days of rest and use overtime only when each employee is fully compensated according with the country law. In addition, the supplier must inform each employee at the time of their hiring if mandatory overtime is a condition of their employment. In countries where the laws do not limit the work hours, employees are only required to work a regular workweek plus 12 hours of overtime and be given at least 24 consecutive hours off in every seven day period. Overtime hours must be compensated at the legal rate required country law. Countries that do not compensate for overtime must provide at least the employees regular hourly pay. The productions of THADDEA apparel and/or products are to be manufactured within the supplier's facility(s) or the regular work place and not within the home or living quarters of an employee.
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Employee Hiring Organizations
The supplier must use organizations that are legal, in good standing and where applicable registered in accordance with the laws of the country.
The supplier is to employee only legal workers of the receiving country and may not hire Illegal foreign workers.
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Workplace Facility
The supplier's facility must meet local code standard requirements and provide safe working conditions that include, safe exit routes from fires and emergencies, adequate lighting, safe passage when using stairs, protective guards and barriers to shield from bodily harm, industry certified safety equipment for face, eyes, head and extremities, protective clothing and equipment required to operate machinery, properly working and protective machinery guards, safe loading and unloading doc areas and protective procedures in place to decrease or eliminate the risk of a fall or from being hit by falling objects.
Facilities Caring for Children
The supplier must provide an environment that is healthy, clean and safe for children when working with or caring for them within or outside the working facility. The facility must have child care procedures in place that provide contact information for the parent/guardian of the child, release authorization by the parent/guardian, health records of the child, a safe building that meets local code standard requirements, clean drinking water, clean toilet facilities, clean sleeping areas with proper sleep mattresses and protection from areas that contain medicines, chemicals, hot surfaces, electric outlets or other potential dangers.
Health, Safety and Environment
The supplier must provide a work environment that is healthy, clean and safe for their employees and in accordance with country law. Suppliers must conform to all pertinent workplace safety regulations, environmental laws, take the appropriate measures to help prevent accidents and injuries within the facilities, and implement procedures that help to minimize the risk of sanitation and decrease or eliminate mental and physical health risks. In addition, the supplier must provide clean drinking water, provide an adequate number of clean separate toilets for each gender and clean washbasins with hand soap in all areas where work is performed.
If the supplier is providing residential living accommodations to employees then the accommodations must be environmentally livable, healthy and safe.
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Hazardous Conditions
The supplier must implement policies and procedures that help to decrease or eliminate the risk of employees' exposure to any ionizing and non-ionizing radiation sources (such as Ionizing Radiation, Radio Frequency (RF) Radiation and Electric and Magnetic Field (EMF) Radiation), to asbestos containing material (ACM), to ergonomic hazards and to chemical and biological materials or liquids. Further, the supplier must implement policies and procedures to help decrease or eliminate the risk of employees' respiratory system from over-exposures of chemicals and maintain the decreased levels of exposure for the employees' health. The minimum, the supplier must decrease exposures that would be in accordance with established local and international regulations. The supplier must comply with the requirements as set forth in this section or with the local laws and regulations governing the prevention of hazardous conditions, which either one is more strict.
Suppliers must comply with whichever regulation or standard is more restrictive, either their nation's law or health requirements, the Threshold Limit Values (TLV's), American Conference of Governmental Industrial Hygienists (ACGIH) or US Occupational Safety and Health Administration (OSHA). The supplier must select the standards for the employees in the work environment that will protect them to the highest level and that will especially protect them from the exposure to blood borne pathogens.
In accordance with this section, the supplier is prohibited from using the finishing technique of Abrasive Blasting on THADDEA, INC. apparel and products, because the technique consists of unsafe substances and potential biological and chemical agents. Also, the supplier must provide working conditions that are electrically safe (no exposed wires, all cable wires in good condition, all electrical outlets installed correctly with Ground Fault Circuit Interruption near wet locations and secure labeled electrical panels and boxes) and that do not cause heat induced illnesses, such as, heat exhaustion, heat cramps or heat stroke. Procedures must be implemented to decrease or eliminate electrical risks, heat stress risks and injuries.
Maintenance and Repair Safety
The supplier must identify any hazards or equipment failure that could be related with maintenance and repair activities. Further, each facility workshop(s) must be clean and in good working condition, equipment and tools must be safe and work properly, protective equipment must be provided and used and access must be provided to equipment manuals.
Noise Exposure
The supplier must decrease high noise levels and protect employees from high noise levels that can cause the loss of hearing. Any facility with noise levels identified to be over 85 dB is deemed a high noise area and therefore the supplier must decrease or eliminate the risk of employees losing their hearing. Any employee affected from high noise levels must be tested by a certified medical professional at no cost to the employee.
Mobile Powered Vehicles and Traffic
The supplier must implement policies and procedures that help to decrease or eliminate the risk of operations involving power motorized vehicles and pedestrians. Each facility must implement vehicle safety requirements, regular maintenance inspections, safety operating guidelines and report on any accidents or issues concerning potential accidents. The supplier must comply with the requirements as set forth in this section or with the local laws and regulations governing the operation or power motorized vehicles within a facility, which either one is more strict. Further, each facility must implement policies that will help power motorized vehicle operators to manage employees safety and pedestrian traffic, which cover the following for power motorized vehicles while on site: speed limits; driving guidelines; protective equipment for operators; vehicle reversing noise indicator; vehicle must function correctly; and all vehicle operators must be certified or licensed before operating any power motorized vehicle.
Laser Protection
The supplier must implement policies and procedures that help to decrease or eliminate the risk of work-related exposure and use of LASER (Light Amplification by Stimulated Emission of Radiation) devices. Each facility must have emergency procedures in place and procedures that: restrict unauthorized personnel from areas containing LASER's; post signage in LASER areas; provide proper protective equipment; use only LASER devices that consist of guarding and interlocks to protect from the exposure of the beam; and LASER devices must be configured and tested to the manufactures recommendations. Further, any LASER device found with defects must be fixed prior to operating.
Facility Materials, Emissions and Environment Hazards
The supplier must implement policies and procedures that restrict the use of nano-materials, decrease or eliminate the risk of air emissions, hazardous materials (transportation and use), hazardous waste, solid wastes and wastewater. Further, the supplier must implement programs that: protect the potential exposure and health of employees and suppliers; minimize the risk to the environment; and store all hazardous elements in suitable containers. The supplier must have in place procedures to effectively clean the incident relating to the action or use of materials or conditions in this section. Any incident involving these materials or conditions must be documented. The supplier must comply with the requirements as set forth in this section or with the local laws and regulations governing the action or use of these materials or conditions within a facility, which either one is more strict.
Emergency Plan
Each supplier must have within the facility an implemented written emergency plan that provides the names of contacts involved with handling an emergency, plans for evacuation, resources and people designated to help assist handicapped individuals, help with medical and rescue duties and an alarm or warning system that can distinctively notify employees of emergencies.
Fire Hazards
Each supplier must have within the facility an implemented plan to decrease or eliminate the risk of hazards that could cause a fire within or outside the facility, procedures for individual and facility fire safety.
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Injuries or Illnesses in the Facility
In the occurrence of an injury or illness the incident must be reported to the facilities management the day the incident transpired and documented in the records of the facility. Further, each facility must be able to provide first aid treatment to an injured or sick individual whether or not professional care is required and have a first kit, disposable gloves, burn treatment materials, sterile adhesive bandages, eyewash and body flush equipment in case of a chemical exposure to the eyes face or body.
Structure of Building
The supplier must implement policies and procedures that decrease or eliminate safety risks related with the design of the building, structure, usage and maintenance of the building. Any identified or potential hazards related with the design of the building, structure or other causes that could deteriorate the structural foundation of the building must be reported. Each facility must implement policies for building structure safety, which for new building construction includes approval by the local building authority or certified professional building designer or architect when constructing the building and constructing mezzanine structures to support all loads and stationary loads so the weight of the loads do not exceed the allowable stress or stated strength of the materials being used for construction.
Storing System Tanks
The supplier must implement policies and procedures for the facility that decrease or eliminate the risks of health, safety and environmental impacts related with storing tank systems located above and below ground, which contain petroleum or hazardous materials. Above ground storing system tanks are considered immobile containers located completely above ground level, and must: be labeled with the contents and potential hazards; contain protective barriers in case of accident; be checked frequently to make sure the tank works properly and has no damage or malfunctions; and is designed to contain the material(s) being stored. Storing tank systems that are defined as underground have a portion of the structure (not including piping beneath ground level) located below ground level, and must: contain a leak detection system; be designed to contain the material(s) being stored; have protection from subsurface corrosion; and contain an overfill protection system.
Polychlorinated Biphenyls (PCB)
The supplier must implement policies and procedures to decrease the risk to employees and the environment when the facility has materials and equipment containing polychlorinated biphenyls (PCBs). Any materials or equipment containing 50 ppm of polychlorinated biphenyls (PCB's) and those containing unknown amounts of polychlorinated biphenyls (PCBs), which should be assumed as containing more than 50 ppm, must implement procedures that: display a Warning/Danger label stating which materials or equipment contain polychlorinated biphenyls (PCB')s; give access only to authorized personnel in areas containing polychlorinated biphenyls (PCB); provide annual inspections for those materials and equipment containing polychlorinated biphenyls (PCB); have in place containment procedures in case of a spill; a sanitization process for all polychlorinated biphenyls (PCB) materials that have not been disposed of or intended for reuse; and any materials or equipment containing polychlorinated biphenyls (PCB) that are planned to be sent for disposal must be sent to an authorized disposal facility that accepts polychlorinated biphenyls (PCB) waste.
Facility Control System
The supplier must implement a Facility Control System (FCS) for health, safety and environment management to decrease or eliminate risks related to operations within the facility. Each facility shall: develop a written FCS policy which must be signed by the facilities senior location manager or general manager; develop a written FCS plan which incorporates health, safety and environment objectives that are developed based upon taking into account risks considered to be high, lawful, functional, hi-tech options, company obligations, financial, shareholders views and other obligations; implement procedures to manage all documents associated with FCS; implement an inspection procedure that allows for a full evaluation of the FCS during a period reliant on the overall risk of the facility; implement procedures that can determine and resolve noncompliance issues associated with the FCS; implement procedures that must be performed for the annual FCS management review; and communicate with their employees verbally, via email or through websites about FCS.
Factory Observation
The inspection of supplier facilities are conducted by third-party monitoring companies, THADDEA and/or THADDEA affiliates. These inspections evaluate the supplier's compliance with THADDEA's Supplier Conduct Policy and the contractual obligations stated by country law.
Stipulations of Commitment
Factories must meet their obligations as employers to their employees. In addition, all third parties must agree to conform with laws applicable to the products they make and agree to respect THADDEA's Supplier Conduct Policy.
Implementation
With the supplier agreeing to the terms stated herein the Supplier Conduct Policy, it is the responsibility of the supplier to execute and incorporate this policy and applicable laws into the practices of its business, and to ensure any sub-contractor manufacturing of THADDEA apparel and/or products is in compliance with this policy.
To validate compliance with the Supplier Conduct Policy and country law, the supplier shall provide requested information and cooperate with inspections conducted by THADDEA or third-party auditors affiliated with or independent of THADDEA, with or without prior notice. Any non-compliance issues identified from an inspection shall be addressed and rectified by the supplier in a timely period. Failure to address and rectify the issues may result in a decrease of placed orders or termination of the business arrangement.
THADDEA holds the right to take proper action against the supplier for failing to meet the country law requirements or contractual responsibilities or to take sufficient action to deal with reported matters.
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GLOBAL WORKFORCE STANDARDS
The global manufacturing industry of apparel is very competitive and demanding but a supplier’s first obligation should be to treat their employees with respect and provide a suitable working environment for their employees. THADDEA strives to work with suppliers that meet these criteria’s and adhere to the THADDEA principles stated in the Suppliers Conduct section. THADDEA suppliers and subcontract suppliers of THADDEA are expected to meet their legal responsibilities to their employees and are evaluated to determine whether they adhere to THADDEA's Suppliers Conduct policy.
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MANUFACTURERS OF THADDEA
Suppliers, who have been approved by THADDEA, manufacture the enhanced tech textile fabrics used in our products.
THADDEA products are manufactured with factories that have no direct association with us. We have products manufactured in the USA and other countries. The factories we work with are selected by us based on their social conformity, factory conditions and company financial stability. At times, we deal with multiple factories so a project can be completed. However, we actively seek factories that can produce the highest quality of products, manufacture the fabric and the final products so costs are extremely competitive or better than other brands. We do not enter into long-term agreements with factories, which restrict both parties from any long-term obligation. Any factory manufacturing our products enters into a non-disclosure and confidentiality agreement and must comply with all of our suppliers conduct regulations.
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POLICY OF CONDUCT & PRINCIPLES
The purpose of this policy is to set forth the guidelines, which establish the Policy of Conduct and Principles for the company THADDEA, INC.
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Ethics
The success of THADDEA is based on its principles, which are vital to institute and maintain for the continuing growth of the company. The actions of all our employees represent the image of THADDEA and therefore we are all required to uphold the highest of ethical and professional values. Integrity is the essential element to ethical conduct. For us, having a solid relationship with our suppliers, vendors and customers begins with honesty. Our Policy of Conduct and Principles is structured to assist the employees of THADDEA on understanding what the company requires of them when faced with a possible conflict situation during working hours.
In this Policy of Conduct and Principles, there is a comprehensive outline on conduct and principles though not all issues are discussed. Situations that might result in improper actions, illegal activities, and unethical practices or even appear improper are handled with caution and proper action. The company takes a violation of THADDEA's Policy of Conduct and Principles very seriously and those who violate any part of the policy are disciplined and subject to immediate termination.
It is the responsibility of Upper Level Management and especially those in Officer Positions to lead in accordance with the guidelines set forth within this Policy of Conduct and Principles and to demonstrate them through both actions and words. The Upper Level Management and Officers are also expected to conform to and encourage our?free discussion?policy. These levels of employees are available to anyone with behavioral concerns, questions or other issues. All information discussed involving the outlined circumstances will remain confidential. Employees are encouraged to report their complaint or concern to one of the aforementioned employees and can also contact a member of management in their department. Any discussion involving the circumstances mentioned herein are taken seriously and handled in an expedited manner. These matters are handled professionally and with confidentiality. Furthermore, no employee will have retribution against them for reporting a behavioral concern, question or issue.
The general oversight and interpretation for this Policy of Conduct and Principles is the responsibility of the Officer or member of Upper Level Management.
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Law and Policy
Our Company's foundation is based on the ethical standards we practice. These standards derive from obeying the law. Obeying the law helps us govern our ethical standards and assists in how our duties are performed. Our obligation is to provide a work atmosphere that maintains truthfulness, self-respect, honor, respect, conviction and accountability from every employee so our high work environment standards are attained. For our Company to maintain this type of work environment everyone must contribute to the practices we adhere and Management, Officers and Directors must take on the particular role of lead by example?so all of us can aspire to be and do our best.
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Industry Ethics
The sports apparel industry is a very competitive industry that continues to grow. While the industry continues to grow so does our Company. Though at the same time we are conforming with antitrust and competition laws that govern the countries in which we do business. Any engagement of illegal anti-competitive behavior is unaccepted. All customers need to be treated equally and fairly. This helps to avoid illegally advising to customers what prices to charge for products, and discourages from one customer receiving an advantage over the other.
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Compliance
Every country THADDEA does business with has regulations and customs laws and we must conform to them. It is our responsibility to maintain an honest and precise relationship with these countries. To help achieve our endeavor, we will not make any intentional product misrepresentation entries for lower customs?values or misleading terms.
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Political Participation
If an employee is participating in a government political practice or campaign then he or she must participate as a private citizen. An individual's political involvement needs to be separate from THADDEA's political involvement in order to comply with the rules and regulations that govern lobbying activities. Any attempt to influence a government official is prohibited. THADDEA will not reimburse employees for political campaigns where their personal time or money was contributed. Furthermore, THADDEA will not permit any employee to work on a campaign during working hours nor use any resources or facilities where THADDEA conducts business.
U.S. Government laws prohibit THADDEA from contributing to any campaigning individual, political party or individual holding a political position at the U.S. federal level. Contributions made to state and local campaigning individuals are governed by laws that vary in each individual state and country. These law regulations are similar for political figures located outside the United States. All employees must observe these regulations.
If there are questions regarding the conduct of political activities then the employee needs to consult with an Officer or a member of Upper Level Management.
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Government Agents
In the business environment practices such as transportation, entertainment, providing food or other things of value, are regarded as acceptable. However, when dealing with government agents, these practices could violate local, state, federal or foreign laws. Any item of value should not be provided to a government agent by or through an employee of THADDEA. This action could deem as an attempt of bribery with a government agent. If any employee is uncertain about accepted interactions with government agents then he or she must consult with an Officer or a member of Upper Level Management.
One act that prohibits making payments to sales representatives or consultants through intermediaries, giving money or anything with value to foreign political parties, foreign candidates or foreign government officials is the U.S. Foreign Corrupt Practices Act. The purpose of the act is to protect against influencing a foreign government.
Consult with an Officer or a member of Upper Level Management before providing any form of disbursement or giving anything with value. A result of violating the Foreign Corrupt Practices Act could include civil and criminal punishment for the Company and all other involved parties.
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Inquires by Government
THADDEA will comply with any government inquiries. In the event any employee who logically considers any of THADDEA's operations or practices to be detrimental to a government inquiry needs to inform an Officer or a member of Upper Level Management and present the basis for such belief.
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Integrity and Trust
Honesty and fairness are standards we must apply. Our customer relationships and good business practices are built on integrity and trust. With a competitive industry, we look for the advantage through hard work, relationships, excellent marketing and customer service. To gain business we will not use unethical or questionable business practices. The business we obtain is because of our Enhanced Tech Apparel and Products (ETAP), the inspirational meaning of the THADDEA name and our ability to service customers. All employees must strive to work respectfully with vendors, customers, other employees and competitors. Taking unjust advantage of any individual by means of exploitation, concealment, mistreatment, falsification or privilege information is prohibited.
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Business Advancement
When an employee has the opportunity to advance his or her own legitimate interest then he or she should pursue the opportunity. However, the employee must not benefit personally from opportunities discovered through the use of Company property or information or their position with the Company, or compete with the Company in connection with such opportunities. The employee must not use Company property, information or his or her position with the Company for improper personal gain.
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Employees Conflict
THADDEA does not wish to impede or regulate employees?personal conduct or endeavors outside of working hours. Though at all times, employees of THADDEA do have an obligation to be trustworthiness and behave in a manner that best represents the Company. Employees should avoid outside interests, which may possibly conflict with an employees trustworthiness or cause judgment in their decisions toward THADDEA. When an employees personal interests are conflicting with the preeminent interests of THADDEA then a conflict of interest exists. Conduct by an employee, which might impede or damage THADDEA's business or relationships with individuals or customers must be avoided or the result of the employees actions is subject to his or her termination.
THADDEA employees are expected to dedicate themselves fully toward their occupation with the Company. They need to avoid any other external employment or business interests that might hinder the ability or performance of their work responsibilities. This constitutes the action of an employee working for a competitor, supplier, vendor or any other company that is considering or is currently engaged in a business relationship with THADDEA. Conflicts of interest may also exist if an employee's outside employment interferes with the employee's job performance at the Company. All other outside employment or business entities in which an employee is in involved must be divulged to THADDEA. This helps us to assess any potential impact these circumstances may have on THADDEA. Furthermore, if any employee or member of the employees immediate family?has any financial interests in another company that competes or is in engaged in business activities with THADDEA then the employee must divulge this information. In most cases, THADDEA will decline to participate in any business relationship with an individual that has financial interest and/or including employment, unless the nature of the association is divulged prior and the transaction is considered non-conflicting with THADDEA's business activities. THADDEA may consider taking appropriate actions if it is determined there is a potential conflict of interest. These actions could consist of a reassignment, transfer, change of job obligations or termination.
With regard to the above stated policy, if any employee has any knowledge or actual reason to believe there is the possibility a conflict of interest may exist regarding personal interests and the interests of THADDEA then he or she is required to divulge the possible conflict via email or in writing to an Officer or a member of Upper Level Management. If it is determined there is a violation of this policy then disciplinary action may incur with the possibility of termination. However, this policy does not prohibit an employee from engaging in behavior protected by law or laws and regulations pertaining to employee prejudice, occupational safety and health and labor relations.
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Office Fraternizing
To avoid any type of complaints of preferential treatment, misunderstandings, potential claims of sexual harassment, unfavorable effect on employee morale or disturbance in the workplace, THADDEA discourages all employees from becoming romantically or sexually involved with another employee. Any employee who is an Officer, Director or holds an Upper Level Management position with THADDEA is strongly advised against engaging into a romantic or sexual relationship with any employee. THADDEA's purpose is not to oversee employee's personal interactions. However, the company reserves the right to take appropriate corrective actions if the company comes to the conclusion a personal relationship is causing any form of disturbance in the workplace, is creating conflict regarding supervision or presenting safety, security or morale concerns. In addition, employees need to know and understand that THADDEA upholds a firm policy on any form of unlawful harassment or sexual harassment. Any employee violating the policies mentioned in this section will be subject to termination.
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Reimbursement of Business Expenses
Employees should make sure all business expenses such as business entertainment, travel, lodging, and food expenses are recorded and documented correctly with THADDEA. These expenses must be consistent with the policies and procedures set forth by THADDEA in order to receive reimbursement. Any uncertainty about reimbursement guidelines should be addressed with an Officer or a member of Upper Level Management for verification. Misleading, exaggerated, or falsification of expenses is subject to termination.
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Contributions
Creating goodwill and good business relationships in a commercial environment is a vital part in business, and these endeavors can be made by providing business entertainment and gifts. However, the reason is not to achieve special advantage with clientele or business associates. When an employees actions have unjustifiably influenced an individual, made them feel obligated to reimburse THADDEA or violated their own principles of conduct then a line of unethical behavior has been crossed. It is the responsibility of the employee to behave ethically and use proper judgment when providing any form of entertainment, gifts or gratuities. Depending on the market and country, in most cases it is customary and acceptable to offer business clientele a practical and modest meal and appropriate entertainment. However, it is important to be knowledgeable and recognize a clients or business associates policies regarding receiving a form of gift. If you know an individual is prohibited from receiving a gift then in no way should you offer one. Consult with an Officer or a member of Upper Level Management first if you have any doubt about providing a gift.
THADDEA allows its employees to receive modest forms of entertainment, meals and gratuities that are in connection with business deliberations, as long as such gifts are appropriate and could not be interpreted as an effort to obtain special advantage. However, some THADDEA departments have different restrictive policy guidelines regarding these matters, so employees should consult with a member of Upper Level Management if there are any doubts concerning the policies of a department.
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Guidelines of Entertainment and Gifts
When employees are conducting business on behalf of THADDEA they are to conduct themselves in accordance with the Ethics section set forth herein by THADDEA. Employees should remain respectful and act in a professional manner at all moments. Furthermore, employees are prohibited from providing any expense coverage for alcoholic drinks, legal or illegal drugs, inappropriate adult entertainment or gifts that are not in accordance with THADDEA guidelines. A violation of this policy is cause for termination.
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Inducements
THADDEA does not offer or accept any forms of a gifts, bribes or kickbacks that are of considerable worth. These types of inducements are strictly prohibited and are considered to undermine competition and cause corruption.
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Unethical Conduct
Employees are obligated to report suspected unethical conduct to an Officer. These reports remain confidential and consist of but are not limited to, fraudulent or negligent accounting, fabricated financial reporting, conflicts of interest, violations of confidentiality, breaches of anti-trust laws, violations of environmental policies, inappropriate gifts, inducements, unlawful harassment or discrimination.
If you are uncertain about whether your conduct is ethical or if an unethical violation has occurred, you need to address these concerns with an Officer or a member of Upper Level Management. In accordance with the terms of legal and business requirements, THADDEA will keep the identity of an employee who has submitted a report confidential. No individual will be subject to retaliation or discrimination for reporting an alleged act of misconduct.
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Report Policy
This policy correlates with THADDEA's Policy of Conduct and Principles and along with the Sarbanes-Oxley Act of 2002 in Sections 301 and 806. THADDEA is dedicated to conducting the highest of achievable standards of moral principles and legal business behavior. In conjunction with this pledge and THADDEA's pledge for open communication, this policies purpose is to provide employees with the opportunity to raise concerns and to reinsure them of their protection from retaliation or persecution for reporting (whistleblowing) in good conscience.
The intention of this policy is to cover serious matters that may possibly have a large effect on THADDEA, such as actions that could cause incorrect financial reporting, are illegal, are not in conjunction with THADDEA's company Policy of Conduct and Principles or that otherwise add up to serious inappropriate behavior.
Managing and overseeing matters concerning the Report Policy is the responsibility of THADDEA, INC Officers.
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Protection for Employee Concerns
- THADDEA will not tolerate any form of harassment or discrimination of a complainant.
- A complainant's personal identity is protected to the greatest extent possible.
- Employees are encouraged to identify their identity to an Officer or member of Upper Level Management when providing allegations. This helps if possible follow-up questions are needed. Furthermore, without the complainant's identity it would be difficult to investigate any allegations if required.
- An investigation will occur when anonymous complaints are expressed. These concerns will be addressed based on the extent seriousness of the issue reported, the reliability of the concern and confirming the credibility of the sources.
- Disciplinary action or termination of the accused could occur if the allegations reported by the complainant are found to be true.
- Disciplinary action or termination could occur if the allegations reported by the complainant are found to be of malicious intent.
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Procedure for Addressing a ConcernThe intent of the report policy process is to address serious and sensitive concerns. Implications concerning financial matters, unethical or illegal practices need to be reported to an Officer or a member of Upper Level Management. Any concern relating to an employment issue should be reported to an Officer or a member of Upper Level Management. Addressing concerns early will help to make taking action easier.
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Handling the Complaint
When a concern is reported then appropriate action is taken. The THADDEA personnel responsible for handling a specific concern will report the complaint and then follow-up on the actions taken to resolve the complaint. A thorough investigation will take place if there is a claim of any illegal conduct.
During scheduled board meetings, any matter that has not been presented that concerns; a complaint in accounting, auditing matters or violations of the Company's Policy of Conduct and Principles by an Officer or Director of THADDEA will be addressed at the board meeting. In addition, a comprehensive summary of other complainants and investigations that do not involve accounting, auditing matters or violations of the Company's Policy of Conduct and Principles by an Officer or Director of THADDEA will be addressed at the board meeting.
If the circumstance arises where the identity of a complainant becomes known, an Officer is appointed and required to monitor any disciplinary action against the complainant to decide whether it could lead THADDEA into anti-retaliation liability. THADDEA members of Upper Level Management and employees shall not demote, release, suspend, make threats, harass or in any way discriminate against any employee based on the terms and conditions of their employment. This is based upon the legal actions of an employee whom is reporting a complaint in good faith concerning THADDEA's accounting and auditing issues or as otherwise specified in Section 806 of the Sarbanes-Oxley Act of 2002.
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Accounting Records
THADDEA is required to ensure that proper liabilities and transactions are maintained and used properly. These guidelines establish appropriate accounting procedures that accurately reflect the company's books and the records of all corporate assets. THADDEA prohibits any employee from providing false statements, initially omitting or adjusting financial figures or not disclosing documents or communications that are relevant to the company's records. All employees must accurately disclose all of THADDEA's transactions to the company's internal and external auditors, including the company's CPA(s).
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THADDEA's Protection of Company Information
It is significant that THADDEA's interests and company information be kept protected and remain confidential. This confidential information would include, but is not limited to; addresses, credit card information, names, telephone numbers, email accounts or any other information that is personal or financially related to customers, vendors or business partners. In addition, information pertaining to the company's business concepts or ideas, involvement of business transactions, materials, operating methods, business plans, marketing and sales programs, financial projections, cost summaries, pricing formulae and any information encompassed in any research, reports, investigations, drawings, designs, plans, proposals, software or computer-generated files are all considered confidential information of THADDEA. By providing confidential information without permission from THADDEA's Legal Counsel is a violation of the Policy of Conduct and Principles and is subject to an employees termination and/or lawsuit against the individual or company.
Information developed by an employee or a third party working with or on behalf of THADDEA is considered confidential company information and is property of THADDEA. Furthermore, all labor, in any capacity done while working for THADDEA, or on THADDEA property, whether tangible or intangible, will be the exclusive property and ownership of THADDEA. All property of intellectual value, dealing with but not limited to current and potential customers, marketing materials, databases, contact lists, business cards, records, reports and all computer programs are part of THADDEA property. Employees of THADDEA are required to keep all information confidential throughout and following their employment with THADDEA. As one of the conditions of being an employee of THADDEA, the employee must agree not to use, or allow the use of any confidential company information in any manner, which could have a direct or indirect adverse effect upon THADDEA, its business, business associates, customers or vendors. As well, employees may not divulge or permit to be divulged any confidential information of THADDEA or anything relating to the information without written permission from THADDEA's Legal Counsel, except for in the proper and needed operation of the employees duties and then only to authorized personnel. However, if an employee of THADDEA has a justifiable business reason for divulging confidential company information to a supplier, consultant or vendor then he or she must make certain that these or any other third parties have entered into a written agreement of confidentiality with THADDEA in which the third party agrees to keep the information confidential for all purposes. If for any reason there is uncertainty pertaining to the existence of such an agreement with a third party, the employee must contact THADDEA's Legal Counsel for instructions before the release of the confidential information is given.
If an employee is terminated or at THADDEA's request, the employee must promptly return all confidential company information and any other property, which belongs to THADDEA, including copies of any materials. Subject matters that are sensitive, including medical information, salary data and performance assessments, shall be discussed only when information is essential to meeting job duties and then only with individuals who the business is intended for or with authorized personnel or if required by law. In addition, a confidentiality agreement may be required to be signed by an employee if he or she has access to any confidential company information or for the sole purpose of protecting THADDEA's intellectual property. A violation of this policy may result in disciplinary action and could lead to the immediate termination of employment. If there is any question regarding a particular issue or the confidentiality of a matter then the employee needs to confer with an Officer or the Legal Counsel.
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Company Assets
Employees are obligated and held accountable for taking all sensible steps to protect THADDEA's assets from theft, misuse or loss and to make certain of their effective use. Company assets that need to be protected include but are not limited to; all forms of personal property, trademarks, copyrights, patents, manufacturing concepts, marketing strategies, clothing and artwork designs, published and non published company records and any reports. Any use of the THADDEA's assets must be for justifiable business purposes.
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Media Relationship
THADDEA wants to have a good communication relationship with the media. This will help to provide an accurate representation of THADDEA. To achieve this, all employees of THADDEA need to work together. All responses to media inquiries and issues need to be professionally conducted with the same manner and effort that is put into THADDEA's marketing. In the event, a media representative contacts an employee; he or she must immediately put the media representative in contact with a THADDEA Officer. All employees, including members of Upper Level Management, should avoid speaking directly with the media. Employees may not respond to inquiries from investors or analysts unless specifically authorized by an Officer of THADDEA. Communications of any form received from investors or analysts should be submitted to an Officer of THADDEA. These forms of communication would also include placing information on message boards, chat rooms, blogs or any other type of internet communication service. All employees are prohibited from using and/or placing any information on any form of internet communication services.
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Management Responsibilities
THADDEA has assigned the Officers and Board of Directors to govern the Company Policy of Conduct and Principles. These groups shall take rational procedures to observe the Company Policy of Conduct and Principles and to enforce that this code continues to conform to all applicable rules and policies. Any waiver of this code from an Officer or Director is required for approval by the majority of the Board of Directors and must be disclosed as required by law or regulation. A majority of the Board of Directors must approve any other waiver from an employee, representative, consultant or agent.
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