|
We will pursue our business with honour, fairness and respect for the individual and the public at large, ever mindful that there is no right way to do the wrong thing.
Summary of the Code
- Obey the law.
- Keep faith with our customers, shareholders and employees.
- Never betray Hyco's faith in YOU by acting against the best interests of the Company.
- Communicate honestly.
- Respect rights to privacy.
- Selecting suppliers based on merit—and merit alone.
- Protecting Hyco’s assets.
- Keeping Hyco a safe and healthy place to work.
1. Introduction
This code applies to all employees, officers, and directors ("employees") of Hyco International Inc and its subsidiaries ("Hyco" or the "Company"). As employees of Hyco, we will comply with all laws, regulations, and Company policies that govern our activities around the world. To do any less would compromise our shared values.
We will strive to be involved and responsible citizens in the communities where we live.
At work, we will deal with employees fairly and honestly, and with concern for safety and well being.
Management is responsible for making sure that proper attention is given to, and that controls are in place for promoting compliance with our code of conduct and the specific Company policies addressing each area.
Employees who fail to abide by these Company policies will face corrective action, up to and including termination of employment. As to executive officers, financial officers, and directors, the requirement that you adhere to these policies may only be amended or waived by the board of directors of Hyco, or a committee thereof, and we will disclose to our shareholders within four business days any amendment or waiver of these policies made by the board of directors on behalf of any executive officer, financial officer, or director.
This code briefly summarizes the conduct required by key policies and guidelines in effect in the U.S. and in many other countries and is intended to remind us of the need to act ethically in all we do. Nothing in this code constitutes a contract of employment with any individual.
Hyco’s non-U.S. operations may, in addition, have policies in effect that complement and support Hyco’s ethical approach. Non-U.S. employees are governed by the applicable non-U.S. policies in their operations, as well as the business with integrity principles described in this code.
2. Advertising
All of the Company’s advertising must be truthful, not deceptive, and comply with applicable laws, regulations, and Company advertising policies. Any claims about the performance or qualities of our products in advertising, sales-training material and point-of-purchase displays or literature must be substantiated before being made. We will hold ourselves and our competitors to the same high standard when making comparative claims about competing products.
3. Anti-Trust and Open Competition
Hyco is committed to fair and open competition in markets around the world. All Hyco employees are expected to comply with the antitrust/competition laws of the countries in which we do business. In the U.S. and many other jurisdictions, it is against the law to agree with competitors on prices or supply levels, division of customers or sales territories, or bids. Violations can result in substantial money damages and criminal penalties for both the company and individuals involved.
Employees should exercise due care in any situation where competitors may be present to avoid violating these laws. In particular, Hyco employees should not discuss with competitors current or future prices, bids, margins, costs, discounts, rebates, terms of sales, production capacities, supply levels, inventories, customers, business plans, or distribution strategies for competing products or services.
There are other practices such as refusals to deal, price differences to competing resellers, exclusive dealing, programs that affect the prices charged by our resellers, or tying the sale of one product to the customer’s purchase of a second product that may also violate these laws. You should always consult with the CFO before engaging in discussions with competitors and whenever you have questions about the application of these laws to your business activities.
4. Documents and Records
All Company financial, accounting, research, test, sales, manufacturing, and expense records or reports, timesheets, and other documents must accurately and clearly represent the facts of the underlying matter. Improper or fraudulent documentation or reporting is contrary to Hyco policy and is grounds for immediate termination.
5. Accounting Policies and Procedures
Hyco has established accounting and other control standards and procedures to ensure that all Company assets are protected and properly used, and that financial records are accurate and reliable. In addition, Hyco has in place policies governing the receipt of money and processing of payments to ensure compliance with moneylaundering prevention laws. Employees share the responsibility for maintaining and complying with required internal controls and ensuring that Company assets are not misused.
6. Payment to Government Officials
Employees should not make any payments to any government official, either directly or indirectly, for the purpose of obtaining or retaining business or obtaining favorable regulatory action. Any other payments proposed to be made to government officials should be approved in advance by the CEO, CFO, or COO and recorded in the Company’s financial records.
7. Confidential Information and Electronic Information
Trade secrets and other proprietary information about Hyco, its business activities, and its customers and suppliers, should be treated as confidential. Except to the extent legally required, such information, or confidential employee data, should not be disclosed to people inside or outside the Company who do not have a legitimate workrelated need to know. Any such disclosure must be made in accordance with Company policies and any applicable law, including all privacy laws relating to the protection and disclosure of personal data.
In addition to the proper use of information, it is important for employees to prevent misuse, disclosure, or destruction (other than in accordance with the appropriate record retention policy) of the information for which they are responsible. This information may be in printed form, computer based, or stored on microfilm or some other format. In handling the Company’s information or information owned by a third party and/or licensed by the Company, employees should comply with copyright laws, computer software licensing agreements, and relevant Company policy.
8. Conflicts Of Interest and Corporate Opportunities
Employees are expected to perform their duties in a way that does not conflict with the best interests of Hyco. Employees, and their immediate families, must avoid any action or business relationship that may create a conflict between their own interests and those of Hyco. In other words, employees must not participate in Company decisions by which they may personally benefit.
Conflicts of interest include interference, including apparent interference, with the best interests of Hyco as a result of private interest. For example, you may be presented with business opportunities from time to time as a result of your employment or other relationship with Hyco. You should not take for yourself personally any opportunity that you have discovered through the use of corporate property, information, or position, nor should you use corporate property, information, or position for your own personal gain. You should also refrain, directly or indirectly, from competing with Hyco. Employees are required to disclose to management (other than directors, who are required to disclose to the board of directors or a committee thereof) any situation that may be, or appears to be, a conflict of interest. When in doubt, it is best to disclose.
9. Diversity and Equal Opportunity
Hyco’s future depends on its ability to attract and retain the best people at all levels of the Company. To do that, we must create a working environment that values diversity and protects the right of each employee to fair and equitable treatment. Our policies and practices assure equal employment and advancement opportunities for all qualified people. We will maintain appropriate standards of conduct in the workplace and always be sensitive to the concerns of our diverse group of employees. Harassment of any employee for any reason is inconsistent with Hyco’s code of ethics and will not be tolerated.
10. Environment
Hyco is dedicated to environmental responsibility and will follow all applicable environmental laws and regulations. Where laws do not exist or are inadequate, we will establish and follow our own standards consistent with this commitment to environmental responsibility. Employees have an obligation to promptly alert management to any work-related actions that threaten the environment.
11. Gifts and Fair Dealing
Employees should deal honestly and fairly with suppliers, customers, competitors, and employees and should award Hyco business based on quality, delivery, service, and competitive pricing. To avoid the appearance of improper influence, no employee, or member of an employee’s immediate family, should accept any gift of more than token value. Neither is it appropriate to accept loans or unusual hospitality (excesses in meals, refreshment, or entertainment) from suppliers or customers. Employees should not take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any other unfair-dealing practice.
12. Political Activities
Generally, neither the Company nor its representatives may make political party or candidate contributions on behalf of the Company except as specifically authorized by the Board of Directors, and as permitted under local law. Any such contributions with Company funds require prior approval from the CEO or CFO. Unless authorized, employees who participate in partisan political activities should not suggest or state that they speak or act for Hyco. Of course, each employee is individually free to pursue political activities he or she deems appropriate.
13. Security Laws and Insider Trading
Under U.S. securities law and the law of several other countries, if an employee knows important, nonpublic information about Hyco or another company, the employee should not buy or sell any securities (including stock) of Hyco or the other company until the information is generally known by the public. In addition, that employee should not disclose the nonpublic information to others inside or outside Hyco who do not have an obligation to maintain confidentiality. Government agencies are able to monitor trading activities, with violations of this law leading to significant civil and criminal penalties against companies and individuals. In addition, employees who are involved in preparing and reviewing reports and other documents filed with or submitted to the U.S. Securities and Exchange Commission, stock exchanges, and other regulators, and press releases and other public communications must strive to provide full, fair, accurate, timely, and understandable disclosure in such materials.
14. Product Safety
Hyco’s objective is to manufacture and market products that are safe for their anticipated use. Employees should immediately report any suspected product safety problem to their supervisor.
15. Proper Use of Hyco Assets
All employees should protect Hyco’s corporate assets and ensure their efficient use. All assets of the Company should be used for legitimate business purposes.
16. Health and Safety
Hyco strives to provide a safe and healthful work setting for all employees. In turn, each employee should encourage and practice safety while on the job and observe appropriate standards of conduct. Employees should immediately notify a supervisor or manager of any work hazards that come to their attention.
17. Support for Hyco Code of Ethics
Hyco is committed to supporting its people in meeting their obligations under this code. In a similar fashion, all Hyco employees must comply with this code in their work conduct.
If you observe or know of violations of this code, or a violation of the law, or have questions about the meaning, intent, and/or application of the underlying policies, it is your responsibility to report such situations or pose any questions promptly. Hyco will not tolerate any reprisal or retaliation against any person who, in good faith, reports a known or suspected violation of this code or the law. Hyco will take disciplinary action, up to and including termination of employment, against any employee involved in any reprisal or retaliation.
18. Reporting Process
Employees can pose questions or make a report by contacting their supervisor, HR Department, or the CFO who has responsibility for all Hyco legal issues. If you wish to register any questions, concerns, or complaints directly to the Audit Committee of the Board of Directors regarding accounting, internal accounting controls, or auditing matters, or if you wish to deliver an anonymous submission of concerns regarding questionable accounting, internal accounting controls, or auditing matters, you may write to the Chairman of the Audit Committee at the following address:
Hyco International Audit Committee Chairman,
c/o Centre Partners Inc
30 Rockefeller Plaza 50th Floor
New York, NY 10020
If an employee reports a concern to their supervisor, HR Department, or the CFO and feels action is not taken after a reasonable period of time, the employee may contact the Chairman of the Audit Committee. Also if an employee feels there is a conflict of interest in reporting to one of the individuals listed above, you may write to the Chairman of the Audit Committee.
Hyco is the world leader in Custom Designed Rod and Telescoping Hydraulic Cylinders
Site Map | 
