1.877.LAVANTE
Ethics Policy and Code of Conduct
Summary
Lavante expects that all of its business will be conducted in compliance with high ethical standards of business practice. We apply these standards to all dealings with employees, customers, suppliers and other stakeholders.
The Ethics Policy, which has been approved by the Board of Lavante Inc., is set out below. Our Ethics Policy and Code of Conduct have been developed to ensure that our business is conducted in adherence with high ethical practices and consistent with legal principles, and sets standards of professionalism and integrity for all employees.
The following is a summary:
- All employees have the right to expect, and the responsibility to ensure, that Lavante’s business is conducted with high ethical standards and consistent with legal principles;
- Our policy is to operate within applicable law;
- Discrimination or harassment of any kind will not be tolerated;
- As a matter of policy, we do not make political donations, nor give or receive bribes or other inducements;
- Conflicts of interest must be avoided, and immediately disclosed if in doubt;
- We aim to be a responsible partner within our local communities and seek to make a positive contribution;
- Employees are encouraged and supported to report, in confidence, any suspected wrong doing.
Our internal control process includes the review of appropriate ethical behavior. Additional information is provided in the Lavante Employee Handbook, which all employees are required to review and acknowledge in writing.
Introduction
This summary is not intended to address every instance in which we are called upon to observe and practice sound business ethics. However, it is meant to remind us that if we each strive to live and abide by basic ethical principles in the day-to-day conduct of our business, we will foster an environment of mutual trust and respect, and continue to build on our reputation for integrity, which is the foundation of the Company.
Lavante believes that trust fosters long-term relationships which are built through honesty, openness, good judgment and fair play. All aspects of our business must be based on the highest ethical standards. Our employees are key to our success and we're all part of the Lavante team, so we all must take responsibility for our own actions and conduct. In addition, since managers are responsible for directing the actions of others and for setting an example for other employees, they should be familiar with this Ethics Policy and how it applies to them and to those under their supervision. It should be remembered that no one has authority to require or influence another employee to violate this Ethics Policy and Code of Conduct, and any attempt to do so may result in immediate disciplinary action, up to and including termination of employment.
Employment, Discrimination and Harassment
Taking into account operational requirements of the business, it is our goal to offer unambiguous and fair terms of employment and to provide employees with appropriate opportunities to develop their skills and progress in their careers. It is our intention to honor all applicable terms and conditions of employment.
The Company recognizes its duty and the benefits of providing working conditions which promote good health, safety and environmental practices. Employees are encouraged to report immediately any health, safety or environmental concerns to their manager in order to protect the welfare of themselves and colleagues. Employees are encouraged to recognize their duty to act in a responsible manner in the workplace, having due regard for the health, safety and general welfare of their colleagues.
We consider that the diverse backgrounds of Lavante’s employees provide strength to the business. All employees regardless of their color, race, religion, marital status, sexual orientation, disability or age should be treated fairly and honestly with both respect and dignity. Harassment (including sexual, physical, mental, use of abusive language or offensive gestures) or bullying, in any shape or form will not be tolerated.
Conduct and Behavior Standards
All employees are expected to contribute to the success of Lavante by performing their jobs as required and conducting themselves in a professional manner consistent with the Company's business philosophy, values and standards of business conduct. Employee honesty and integrity are essential to ethical business practices. Employees are required to prepare all of their work accurately and truthfully.
Unacceptable conduct that is considered detrimental to the Company's best interests may result in immediate disciplinary action, up to and including termination of employment.
Ethics in the Marketplace
- Nothing is to be gained through misrepresentation, exaggerated claims or other forms of false advertising. Our products and services must stand on their own merits and their quality.
- Collaboration with competitors to establish or maintain prices or to unlawfully restrain trade will not be allowed. Customers should be given factual information about prices, schedules, services and other terms of business. Suppliers, subcontractors, advisors or representatives also deserve to be treated fairly, honestly and in accordance with agreed terms.
- It is not Company policy to knowingly infringe on the copyright, trademarks, patents or other properly registered intellectual property of others.
Political Contributions, Other Payments to Influence Business Transactions, Gifts and Entertainment
Lavante’s policy is that it does not use corporate funds, whether in cash, goods, services, equipment, etc., to make contributions to political candidates, political parties or committees. No bribes of any sort may be paid to or accepted from customers, politicians, government representatives, advisors or representatives.
Special care must be taken in accepting or giving gifts and entertainment. These are not permitted if it would create a real or perceived conflict of interest. The exchange of social courtesies is acceptable when there is a clear business purpose and they remain within good taste. Neither the receipt nor the giving of excessive entertainment, substantial gifts or favors is acceptable. The giving of gifts/entertainment must be properly authorized and accounted for.
Whistle Blowing
All employees, clients or other constituents of Lavante have the right and the responsibility to question possible wrongdoings, and are encouraged to remain vigilant against such possible actions. If an employee suspects wrongdoing (whether or not the suspected act has actually occurred), he/she should immediately report the matter to their manager, or if this is not possible /appropriate, to a higher level of management. Management should be able to advise if the action in question is in fact a possible instance of wrongdoing. If the employee feels that he/she cannot report the suspected wrongdoing to Lavante’s management, the employee should report it immediately to the General Counsel, who is authorized directly by the Board of Directors to investigate any such matters. Employees who report the suspected wrongdoing to General Counsel may do so in confidence and may report the suspected wrongdoing anonymously if they do so via a letter. Discrimination of employees who raise genuine concerns will not be tolerated under any circumstances and support will be provided to whistleblowers as appropriate.
General Counsel
Lavante, Inc.
c/o DPA Law Group
46 W. Santa Clara St.
San Jose CA 95113
(Envelopes should be marked “Strictly Private and Confidential”)
Lavante’s Ethics Policy is supported by the whole Board of Lavante, Inc., and shall be reviewed from time to time. The policy applies to every employee of the Company.
