Page 15 - 2019 - erbe employee handbook.draft national

outside inquiries regarding the company to the persons in the company authorized to respond to the particular inquiry.
As a condition of employment, all Erbe employees are required to sign a confidentiality/non- disclosure agreement. Please also refer to the separate policies regarding trade secrets, confidentiality and protection of proprietary information.
2-7. Diverting
Diverting is a process in which a product is sold by a company to a specific customer, who subsequently transfers product ownership, distribution and control to a different customer.
Employees shall not knowingly assist or otherwise be involved with the diverting of any products to a customer or entity not otherwise legally permitted to purchase our products.
2-8. Political and Charitable Contributions
Although employees are encouraged to be socially responsible and politically active, employees may not commit the company’s funds or assets to any political candidate, party, charity or similar organizations, unless such contribution is expressly permitted by law and has been preapproved by an authorized company representative.
2-9. Administration of Code
All employees who suspect violations of the letter or spirit of this code have an obligation to report their concerns to Human Resources or other manager. Allegations of improper or illegal behavior will be investigated promptly and thoroughly. The investigation shall remain as confidential as practicable and those conducting the investigation shall respect the privacy of all persons involved.
No adverse action shall be taken or permitted against anyone for communicating legitimate concerns to appropriate company personnel. While an investigation will be facilitated if the employee identifies himself or herself, the company will accept and investigate matters submitted anonymously.
The Code of Conduct is subject to amendment and may be reviewed and updated periodically. All employees must certify annually their intent to comply with the guidelines herein.
2-10. Erbe Group Anti-Corruption Guidelines
Erbe is committed to ethical and legal compliance with all applicable laws and regulations in its business dealings. The company has published additional guidelines related to its anti-corruption efforts. These guidelines are published in their entirety on the Erbe Human Resources Portal.
Questions regarding the Code of Conduct or Anti-Corruption Guidelines should report them to Erbe’s Director of Human Resources, who serves as the company’s Compliance Officer.
15 | Code of Conduct Confidential/Internal Use Only