Code of Conduct

Introduction

APC Global CPK Systems (“CPK”) is committed to complying with all applicable laws and to always operating in an ethical and honest way. This Code of Conduct has been prepared to provide guidance for our business and to all those with whom we work. It sets out the framework of how we should deal with each other and our customers, suppliers, stakeholders and the environment in which we operate. Crucially, this Code is built around CPK’ core values of Integrity, Innovation and Excellence (see Our Core Values).

This Code of Conduct applies to all CPK employees. Every employee is responsible for reading and following it. If you have any concerns about your own conduct or that of any other person, we encourage you to speak up and share your concerns. In the first instance, you should raise issues with your direct manager. Alternatively, you may contact a member of Group legal counsel.

Working in line with this Code of Conduct will enable CPK to continue building a business of which we can all be proud, and which reflects our ongoing commitment to our customers and our respect for each other.

About our Code of Conduct Policy

CPK is committed to conducting its activities with the highest standards of integrity and business practice in all dealings with employees, customers, suppliers, public authorities, shareholders and the general public.

This Code of Conduct and its accompanying policies apply to all CPK directors, officers and employees worldwide (collectively “employees”), all CPK companies worldwide, all joint ventures in which CPK is involved, and all third parties working on our behalf. It is a standing guide for conducting our business in an honest and professional manner and should be used in determining key business decisions and actions.

These principles are not intended to be all-inclusive, but they do provide the necessary guidance on our established way of doing business. Local or department guidelines may be issued in various sites to supplement or implement them. Furthermore, whilst many of our key policies are appended to this Code of Conduct, additional policies, may apply. Notwithstanding that they are not contained within this Code of Conduct, compliance with those other policies is compulsory.

CPK and all of our subsidiaries and employees must act in compliance with the laws and regulations of all countries in which they operate. National laws may sometimes require us to modify the practices that we have outlined here. Any waiver of these practices requires the prior approval of Group legal counsel.

Please keep in mind that failure to conduct business in compliance with this Code of Conduct may result in disciplinary action, up to and including termination of employment, and reporting to the relevant authorities.

CPK has designed this Code of Conduct to clearly set out and promote:

• our Employment Practices, which are built on our core values and provide equitable employment opportunities for all employees and applicants; and
• our Personal Ethics, including honest and ethical business conduct, the handling of conflicts of interest and dealing with material non-public information;
• our Corporate Social Responsibility;
• our Commercial Integrity, including compliance with applicable rules and regulations such as, inter alia, competition and anti-bribery laws;
• the proper use of our Corporate Assets and Information.

This Code of Conduct should be the basis of your daily working practice. If you need further guidance in applying it to your specific situation, your direct manager should be able to help you. You may also contact Human Resources or Group legal counsel for more specific guidance or advice.

When in doubt, ask! 

Employment Practices Policy

Principles, rights and general conditions

Fundamental employment principles

Our employment environment is constantly changing. What will not change is our commitment to our core values which form the foundation of our Employment Policy. They are building blocks that demonstrate our commitment to our business and our respect for each other.

Fundamental rights at work

CPK respects the International Labour Organization (“ILO”) Declaration on Fundamental Principles and Rights at Work. Within these principles, CPK supports, among others, the freedom of association and effective recognition of the right to collective bargaining, the elimination of all forms of forced or compulsory labour, the effective abolition of child labour, and the elimination of discrimination regarding employment and occupation.

We do not allow child and forced labour and we therefore put the following measures in place:

• We verify age of job applicants and employees at recruitment and run regular reports to verify compliance on the minimum age requirements
• We verify legal working status of all employees at recruitment (as further explained in our internal Recruitment & Selection Policy)
• No presence of employees below the legal minimum working age as defined by local law
• Employees below the age of 18 are only employed in non-risk areas as defined by law, and
• We require any third-party, temporary or contract employees working for CPK or in CPK facilities to strictly follow all local laws related to child and forced labour

General conditions of work and social protection

The conditions of work, wages and other forms of remuneration will comply with national laws and regulations and will be consistent with applicable international labour standards. Where applicable, remuneration systems will be transparent, including the process and criteria being used, and communicated to all impacted employees. CPK is committed to providing decent conditions of work with regards to wages, hours of work, weekly rest, holidays, health and safety, maternity protection and ability to combine work with family responsibilities. CPK will provide social protection for employees as required in the country of operation and compensate employees for overtime in accordance with laws, regulations or collective agreements. CPK promotes health and well-being, such as care programmes and career mobility.

Social dialogue

CPK recognises that employers and employees have both competing and mutual interests. We recognise therefore the importance of social dialogue and its institutions, including at international level, as well as applicable collective bargaining structures.

In this respect, it is CPK’s policy to:

• Respect and not obstruct the right of employees to form or join their own organisations to advance their interests or to bargain collectively
• Provide reasonable notice to the appropriate government authorities and employee representatives bodies in order to mitigate any adverse impact to the greatest extent possible, where changes in operations would have major employment impacts
• Provide duly designated employee representatives with access to information that will allow them to have a true and fair picture of our finances and activities;
• Not to encourage governments to restrict the exercise of the internationally recognised rights for freedom of association and collective bargaining, and
• Offer interactive communication sessions with employees regarding working conditions in a structure approach

Union representation

CPK supports the presence of Unions or other types of collaboration and engagement with work force representatives across the globe.

Human development in the workplace

It is CPK’s aim to:

• Provide all employees with appropriate access to skills development, training and opportunities for career advancement, on an equal and non-discriminatory basis
• Facilitate, for employees being made redundant, when necessary and appropriate, any access to assistance for new employment, training or counselling, and
• Promote health and well-being, such as care programmes and career mobility

Employees and the workplace environment

Safety

CPK constantly strives to prevent accidents, occupational injuries and workplace illnesses by:

• Providing the appropriate physical conditions and protections
• Implementing robust procedures
• Fostering the right people behaviour, and
• Promoting work and life balance

Physical security

CPK aims at providing a secure business environment for the reasonable protection of our employees, products, materials, equipment and proprietary systems and information. Materials, equipment and systems incorporated into the design of our facilities will ensure adequate security. Physical security is the responsibility of all employees. You should report any breach of security to your direct manager.

Non-discrimination and diversity

We respect, value and welcome diversity in our workforce, as well as at our customers and at our suppliers. Our policy is to comply with all applicable laws and to provide equal employment opportunity for all applicants and employees without regard to non-job-related factors such as ethnicity, colour, religion, gender, national origin, ancestry, age, disability, veteran status, marital status or sexual orientation. This Policy applies to all areas of employment, including recruitment, hiring, training, promotion, compensation, benefits, transfer and social and recreational programs.

Workplace violence

CPK has a zero-tolerance policy for violence. Violence includes physically harming another, shoving, pushing, harassing, intimidating, coercing, brandishing weapons, and threatening or talking of engaging in those activities.

It is CPK’s aim to ensure that everyone associated with our business, including employees and customers, never feels threatened by any employee’s actions or conduct. It is everyone’s responsibility to prevent violence in the workplace. Employees can help by reporting any workplace incident that could indicate a co-worker is in trouble. Employees are encouraged to report any incident that may involve a violation of this Policy.

Harassment-free workplace

CPK is committed to providing a workplace free of all types of harassment. CPK strongly disapproves of, and will not tolerate, harassment or bullying of employees by managers or colleagues. CPK will also provide a work environment to protect employees from harassment by non-employees in the workplace.

Harassment or bullying includes verbal, physical and visual conduct that creates an intimidating, offensive or hostile working environment or that interferes with work performance, and which goes beyond regular business conduct. Some examples include racial slurs, ethnic or sexual jokes, offensive statements and intimidation tactics, regardless of their way of communication and including via electronic mail, and the use of pornographic screens or software. Sexual harassment includes behaviours such as solicitation of sexual favours, unwelcome sexual advances or other verbal, visual or physical conduct of a sexual nature.

Sexual harassment can also occur through electronic means (such as emails or text messages or by viewing pornographic websites) and through social media, regardless of whether the post was made during work hours or not. Where there is a link to employment, employees are subject to the same rules about sexual harassment in the virtual world as they are in the real world.

As such, employees are required to use technology and social media responsibly in the workplace and in relation to anything or anyone associated with the workplace. This extends to the use of technology and social media outside the workplace where there is a strong connection to the employment relationship (for example, between colleagues where the foundation of the relationship is a common workplace).

Work hours and vacation

At CPK, being at work on time and being available during normal business hours are part of our company’s commitment to our customers and employees. Start times are generally consistent with local business start times.

CPK supports flexible work hours / schedules when business requirements are met or exceeded as a result of this change. Rest periods and vacations meet at least the legal requirements in the concerned country.

Employee reviews

CPK is committed to developing a sustainable workforce by providing development and advancement opportunities to all employees to ensure that they have the opportunity to continually improve themselves to reach their full potential. It is understood that this is a two-way process which requires the employee to take responsibility for their own development. These reviews will be conducted annually.

It is important for all employees to know how they are performing with regards to the company’s expectations. To support employee reviews, CPK uses various personal review systems and communications. The personal development review is designed to encourage a two-way dialogue which culminates in the employee and manager agreeing to smart objectives as well as clear development needs and opportunities for career enhancement. The smart objectives are driven by the company objectives and flow down from the Leadership Team. Due consideration is given to how much an individual can support the achievement of our targets. The outcome of all personal reviews is used to drive the training and development programs.

To accomplish this, CPK will undergo negotiations with unions and other employee representatives where applicable and use neutral market data. The total compensation program is managed to achieve a commercially sustainable package in full accordance with the local rules and legislation regarding social security contributions and tax withholding in the applicable countries and is ratified, for example, in individual contracts or collective labour agreements for our employees. CPK funds management-approved reasonable business travel, education, relocation, in/expatriate expenses, business entertainment and other expenses necessary to conduct our business in line with our internal Travel Expense Policy. Individual employees are responsible for the accuracy, completeness and timely filing of the required forms, including appropriate backup documentation for reimbursements, advances of funds or credit card purchases.

Employee communication

Open communication

CPK promotes performance, teamwork and results through open communications. We encourage communications meetings at all sites, where employees have the opportunity to share any concerns with senior management. CPK also supports an “open door” management policy. Employees are encouraged to raise work-related concerns with their direct manager. If this is not the most appropriate person, they are encouraged to bring their concerns to the attention of the functional manager, Human Resources or any senior manager, up to and including the Chief Executive Officer.

Employee posting on the Internet

CPK employees may choose, or be required by their jobs, to participate in social networks, public forums on the network, Internet mailing lists and so on. Employees may not represent CPK’s corporate opinion in these forums unless they have been specifically asked to do so. To avoid confusion, employees should indicate in their postings that the views they express are their own and not those of CPK.

Employees should remember that, even with this disclaimer, they will be identified with CPK and that their network behaviour reflects on the company in a broader way. In addition, employees should never comment on confidential or internal company matters, and should never comment on pending legal actions involving CPK, our customers or our partners.

All comments should be well informed and within the employee’s sphere of expertise. Further, if the posting affects others at CPK those affected should be advised of it in advance.

Complaints

In case of any misconduct, you should first contact your Manager, Human Resources, or Group legal counsel.