AGG-ADM-100-OP-010 Code of Conduct and Ethics
AGG-ADM-100-OP-010 Code of Conduct and Ethics
AGG-ADM-100-OP-010 Code of Conduct and Ethics
AUTOKINITON is committed to acting ethically and with integrity in our relationships with each
other and with our customers, suppliers, and others. The Code was adopted to help us
understand our duty and obligation to conduct business in a way that is both ethical and
consistent with all applicable laws and our corporate policies.
The Code is a resource that provides guidance and practical information on a number of topics
to assist us in making ethical decisions in our daily work lives. In addition to this Code, the
Company also maintains more detailed and targeted policies and procedures that govern the
conduct of all associates. Each associate is responsible for acting in accordance with this Code;
we also expect our suppliers, consultants, independent contractors, agents and other
representatives to meet these same standards.
Our conduct, at all times, should reflect the Company’s Mission and Values and demonstrate ethical
leadership, and promote a work environment that upholds the Company’s reputation for integrity,
ethical conduct, and trust.
This Code is intended to guide us in making the best choices in the workplace. AUTOKINITON
expects all associates read, understand, and adhere to this Code as we carry out our
responsibilities. Making the right choices and adhering to all Company policies, this Code, and
the laws and regulations that govern our business are critically important to our success, now
and in the future.
Each of us is responsible for knowing the policies and guidelines contained in the following pages.
We are expected to: 1) become familiar with, and conduct AUTOKINITON business in
compliance with applicable laws, regulations, this Code and Company policies and procedures;
and 2) treat all AUTOKINITON associates, customers and business partners in an ethical, honest,
respectful and fair manner.
Violations of this Code will lead to disciplinary action for associates, up to and including
termination of employment.
If you have questions, ask them; if you have ethical concerns, raise them. The Compliance
Committee, responsible for overseeing and monitoring compliance with this Code, is available to
answer your questions, provide guidance, and is a means for you to report suspected misconduct.
One of the primary goals of the antitrust laws is to promote and preserve each competitor’s
independence when making decisions on price, output, and other competitively sensitive factors.
You must not agree, verbally or otherwise, with any competitor on matters that limit independent
judgment and restrain trade such as agreements to fix prices, provide discounts, coordinate
bidding activities, limit production, control the quantity of products, divide the market for
customers, territories, products or purchases, or boycott customers or suppliers. Associates need
to avoid any situations and activities from which an unlawful agreement could be inferred.
Relationships with customers and suppliers can also be subject to several antitrust prohibitions if
these relationships harm competition. For example, it can be illegal for a company to affect
competition by agreeing with a supplier to limit that supplier’s sales to any of the company’s
competitors. Collective refusals to deal with a competitor, supplier or customer may be unlawful as
well. While a company generally is allowed to decide independently that it does not wish to buy
from or sell to a particular person, when such a decision is reached jointly with others, it may be
unlawful regardless of whether it seems commercially reasonable.
Information gathered about our competitors must only be from legitimate sources such as
published articles, advertisements, brochures or other publicly available sources. We must never
attempt to acquire a competitor’s trade secrets or other proprietary information through unlawful
means such as theft, spying, bribery or breach of a competitor’s non-disclosure agreement.
Trade Controls
The U.S. and other governments, in countries in which AUTOKINITON operates, often establish
controls on the products we export. These controls can establish limits, restrictions and other
prohibitions when conducting transactions with selected countries, governments, and parties.
The Company is committed to complying with all U.S. export, economic sanction and anti-
boycott laws and regulations, as well as similar laws and regulations in other countries in which
we operate. The Company also is committed to complying with the import and other Customs
laws applicable to our business. It is therefore essential that we conduct appropriate due
diligence before engaging in any transaction, particularly when the transaction involves a non-
U.S. party or a shipment is being made internationally.
Conflicts of Interest
We should not allow our personal interests and relationships to interfere with our responsibilities
at work. A conflict of interest exists when an associate’s private interests or activities interfere, or
appear to interfere, with the interests of the Company. Associates are expected to avoid activities,
financial interests, and relationships that may present possible conflicts or the appearance of a
conflict.
Conflicts of interest may occur when an associate, or an immediate family member (i.e., spouse,
children, and parents of the associate), receives personal gain or benefits because of the associate’s
position with the Company. For instance, a conflict of interest exists when an associate is in a
position to influence a business decision that could result in a personal financial gain for the
associate or a member of his/her family. It is almost always a conflict of interest for an associate
(and in some cases their relatives) to own an interest in a company that competes with
AUTOKINITON or to work simultaneously for a competitor, customer, or supplier. The best policy is
to avoid any direct or indirect business connection with AUTOKINITON’s customers, suppliers, or
competitors, except on AUTOKINITON’s behalf.
Should conflicts or activities that create the appearance of a conflict occur, you must fully disclose
them to your supervisor or to Human Resources. As conflicts of interest may not always be clear-
cut, you should consult with management or Human Resources if you have any questions or
doubts. Any associate who becomes aware of a conflict or potential conflict must promptly bring it
to the attention of his or her supervisor, Human Resources, the Compliance Committee or
throughthe anonymous Ethics Alert Integrity hotline.
Non-Disparagement
During the period of employment and for the time following any date of termination of
employment, Associate shall not, directly or indirectly, make or publish, or cause to be made or
published, any statement, observation, image or opinion, or otherwise communicate any
information (whether in written or oral form) that: (a) defames, disparages, or slanders the
Company, its respective Affiliates, or any of their businesses, products, or services; (b) could
harm the reputation of any of the Company or its respective Affiliates; (c) casts the Company or
its respective Affiliates in a negative light; (d) interferes with any of the Company’s or its
respective Affiliates’ respective business relationships; or (e) in any way criticizes the personal
or business reputation, practices, or conduct of the Company or its respective Affiliates.
Associate acknowledges and agrees that the foregoing covenant extends to statements, written
or verbal, electronic or otherwise, made to anyone, including, but not limited to, the news
media, via social media, investors, potential investors, any board of directors or advisory board
of directors, industry analysts, competitors, strategic partners, vendors, employees (past and
present), and clients. Nothing contained in this section shall be interpreted to prevent Associate
from making truthful statements in any legal or other proceeding that would subject Associate
to penalty for perjury, even if such statements are otherwise in conflict with this section.
Harassment
AUTOKINITON strives to create and maintain an inclusive work environment in which people are
treated with dignity, fairness, decency and respect. All associates are responsible for conducting
themselves in a manner such that their actions are not considered harassing, intimidating,
demeaning, or disrespectful. Harassment based upon race, color, religion, age, national origin,
disability status, genetics, protected veteran status, sexual orientation, gender identity or
expression, or any other characteristic protected by federal, state or local laws will not be
tolerated. Company policy strictly prohibits any form of harassment in the workplace whether by
fellow Company associates or other parties with whom an associate is expected to work. The
Company will take prompt and appropriate action to prevent and, where appropriate,
disciplinebehavior that violates this policy.
Harassment includes any physical or verbal conduct that has the purpose or effect of unreasonably
interfering with an associate’s work performance or creating an intimidating, threatening,
offensive or hostile work environment. Harassment can take many forms and includes, but is not
limited to, the following conduct: bullying; taunting; disparaging comments; slurs; epithets;
negative stereotyping; threatening, intimidating or hostile acts; and written or graphic material
that ridicules or shows hostility, hatred towards or aversion to an individual or group and that is
posted on Company premises or circulated in the workplace.
The Company also does not tolerate any form of sexual harassment. Sexual harassment may
consist of unwelcome sexual advances, requests for sexual favors, and other verbal, visual or
physicalconduct of a sexual nature. It can also exist when an associate’s employment is adversely
affected when another associate in a leadership role abuses authority by making promises or
threats in order to obtain sexual favors.
If you believe you have been subjected to harassment of any kind, promptly report the incident to
your supervisor, Human Resources, or to any member of the Compliance Committee. If you are
uncomfortable reporting a suspected violation in person, you are encouraged to contact the
Company’s Ethics Alert Integrity Hotline. No one will be subject to retaliation because of
a good- faith report of suspected misconduct. Complaints of harassment, abuse or
discrimination will be investigated promptly and thoroughly and will be kept confidential to the
extent possible.
An associate who is found to be responsible for harassment, or for retaliating against any
individual for reporting a claim of harassment or cooperating in an investigation, will be subject to
disciplinary action up to and including termination.
The Company is committed to maintaining a drug-free work environment. You may not use,
possess, or be under the influence of alcohol or any controlled substance, including certain
prescription medications, when performing Company business (whether on or off Company
property), operating Company machinery, and/or driving a Company vehicle or any vehicle on
Company business. Associates also cannot sell or purchase, or attempt to sell or purchase, alcohol
or any controlled substance while on premises or performing Company business (whether on or off
Company property).
The Company will not tolerate any level of violence in the workplace or in any work-related
setting, Threats, assault, bullying and any other form of violent or threatening behavior is not
permitted. No associate may bring firearms, explosives, incendiary devices or any other
weapons into the workplace or any work-related setting regardless of whether or not the
associate is licensed tocarry such weapons.
Violations of this policy must be referred to your supervisor and the Human Resources Department
immediately. Threats or assaults that require immediate attention must be reported to Human
Resources or to the police as necessary.
Environmental Matters
Federal and state laws extensively regulate environmental matters and impose serious restrictions
regarding the handling and disposal of toxic, hazardous, and non-hazardous substances and waste.
The Company requires active compliance with all such environmental standards. The Company has
established programs for compliance with environmental regulations that may include notification
to proper authorities upon the occurrence of certain incidents. All associates are expected to be
familiar and comply with the environmental standards and laws applicable to their positions.
The Company protects personal information by: 1) using personal information only for legitimate
business purposes; 2) sharing only the information required for the circumstance; 3) sharing the
information only with those who have a business need-to-know; and 4) securely disposing of it
when no longer needed for the original purpose. Associates are expected to protect the privacy of
co- workers and their personal data should that information become available to them.
Associates who are found to have submitted or approved any documentation, report or other
information containing knowingly materially inaccurate, materially incomplete or other improper
data or unauthorized signatures are subject to disciplinary measures, up to and including
termination of employment.
Retention of Company Records
In the course of its business, the Company produces and receives a large number of records.
Numerous laws require the retention of certain Company records for various periods of time. To
comply with these laws, records are to be identified, maintained, safeguarded, and destroyed or
retained on a systematic and regular basis according to AUTOKINITON retention policy.
Works of authorship such as books, articles, drawings, computer software and other such materials
may be covered by copyright laws. It is a violation of those laws and Company policy to make
unauthorized copies of or derivative works based upon copyrighted materials.
Company assets, including time, equipment, materials, resources and proprietary information, that
result in work products such as patent applications, internal reports, product designs, and/or
drawings, are the intellectual property of AUTOKINITON. Similarly, it is Company policy not to
infringe upon the intellectual property rights of others. Associates must never use the Intellectual
property of others without express permission of the owner of the intellectual property.
You must take all necessary measures to secure your computer and all passwords. Should your
password or the security of any Company computer be compromised, you must immediately change
your password and report the incident to the Information Technology Department. When
communicating sensitive information or information with data that may raise privacy concerns, the
files should either be password protected, encrypted, or transmitted through approved sites.
You should use social media, such as Twitter, Facebook, Instagram, responsibly and not post any
confidential or other information about the Company, its suppliers or customers. Remember to
always be professional, respectful and refrain from posting comments that could be harmful or
disparaging to our Company, customers, suppliers or coworkers. Associates are not authorized to
comment or post communications on behalf of the Company. Only designated parties are
permitted to post official Company communications.
This Code cannot provide definitive answers to all questions or situations you may encounter.
If you have questions, regarding any of the policies discussed in this Code or if you are in doubt
about the best course of action in a particular situation, you should seek guidance from your
supervisor, Human Resources, the Legal Department or the Compliance Committee.
All reported violations will be promptly investigated and treated confidentially to the extent
reasonably possible. It is imperative that reporting persons not conduct their own preliminary
investigations. Investigations of alleged violations may involve complex legal issues and acting
on your own may compromise the integrity of an investigation and adversely affect both you and
the Company. Every reasonable effort will be made to halt conduct not in compliance with this
Code as soon as reasonably possible after its discovery.
Remember
Ultimate responsibility to ensure that we as a Company comply with the many laws,
regulations and ethical standards affecting our business rests with each of us. You must become
familiar with and conduct yourself strictly in compliance with those laws, regulations and standards
and the Company’s policies and guidelines pertaining to them.
NO RIGHTS CREATED
This Code is a statement of the fundamental principles and key policies and procedures that govern
the conduct of the Company’s business. It is not intended to and does not create any obligations
to or rights in any associate, director, client, supplier, competitor, or any other person or entity.
The Code is also a statement of policies for individual and business conduct and does not, in
any way, constitute an employment contract or an assurance of continued employment.
Associates of the Company are employed at-will except when covered by an express, written
employment agreement. This means that you may choose to resign your employment at any
time, for any reason or for no reason at all. Similarly, the Company may choose to terminate
your employment at any time, for any legal reason or for no reason at all, but not for an
unlawful reason.
Commitment to Sustainability and Social Responsibility
AGG’s commitment to sustainability and the well-being of our associates and communities is second to
none. We make sustainability and corporate citizenship integral parts of our decision-making processes,
from the materials and resources we use to the practices we encourage our associates to follow.
AGG is an equal-opportunity employer that is dedicated to attracting, hiring, and developing a strong,
talented, and diverse workforce. We treat associates fairly and provide a challenging and fun
environment in which to work. Employment decisions are based on individual qualifications without
regard to race, color, religion, national origin, sex, sexual orientation, age, veteran status, disability, or
any other basis protected by federal, state, or local fair employment practice laws.
AGG works to mindfully reduce or eliminate - substances that are hazardous to human health and the
environment. We review all new chemicals to gauge their impact on the health of our associates and our
ecosystem, and we ensure chemical information can easily be accessed by all members of our team.
AGG strives to be a good corporate citizen within the communities we operate. We believe that making
a positive impact in the community is an important part of our overall environmental footprint. We
contribute to communities through volunteer programs, donations, and sponsorships, and we
encourage participation from all our associates in these efforts.
AGG-EHS-247-FM-001-A
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OUR COMMITMENT TO HEALTH AND SAFETY
AGG is devoted to continually improving our performance through effective safety management. We
strive to eliminate all safety risks to our associates. Safety rules are strictly enforced, and managers
provide extensive instruction, training, and supervision to ensure each associate is safe from injury and
health risks.
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POLÍTICA DO USO DA TERRA
Os direitos de propriedade e uso regular da terra devem ser comprováveis por meio de
certidões emitidas pelos órgãos competentes.