Table of Contents
NOTE FROM THE C. E. O
WORK WITH AND FOR EACH OTHER
Personal Dignity and Respect
Conflict of interest
Cybersecurity
DO THE RIGHT THING
Honest, ethical conduct and fair dealing
Anti-corruption and Anti-bribery
Gifts and entertainment
Political contributions
Charitable contributions
Social responsibility and sustainability
INNOVATE, COMMUNICATE, WIN AND GROW
Records and money
Public disclosure
Safeguard good name and reputation
Confidential information
CREATE AND GROW SUSTAINED BUSINESS VALUE
Following the letter and spirit of the law
Human Rights
Anti-money laundering
Anti-Trust and Competition laws
BE A COMPANY ALL OF WHICH CAN BE PROUD
Use of intellectual property and proprietary information
Protection of corporate assets
Social media and other online activities
Assistance with audits
SPEAK UP: ASK FOR GUIDANCE AND VOICE CONCERNS
Participating in an investigation
Non-retaliation policy
Ask questions
Personal integrity, practiced on a daily basis, is the foundation of corporate integrity. We are all expected to act with honesty and integrity at all times. We should operate with the highest standards of individual and corporate integrity. To that end, each of us is personally responsible for supporting TERIMO ESTABLISHMENTS CO. LIMITED ‘core values.
We are committed to providing a work environment free of discrimination and harassment on the basis of race, color, national origin, sex, gender, gender identity or expression, sexual orientation, marital status, registered domestic partner status, citizenship status, religion, age, physical or mental disability, medical condition, genetic characteristics and information, ancestry, military and veteran status or any other category. We give equal employment opportunity to all individuals in compliance with legal requirements because it’s the right thing to do.
We are committed to fostering an inclusive workplace where talented people work, thrive, contribute to TERIMO ESTABLISHMENTS CO. LIMITED’ success and develop their careers and the careers of our colleagues. Supporting a diverse, engaged workforce allows us to be successful in building trust, empowering teams, and delighting our customers.
A conflict of interest occurs when one’s personal interests influence or could appear to influence one’s ability to act in the best interest of TERIMO ESTABLISHMENTS CO. LIMITED’. We address conflicts of interest in an ethical manner to ensure the decisions we make involving TERIMO ESTABLISHMENTS CO. LIMITED or its business are in the best interest of our Company. Our personal interests can affect our decisions even when we think they will not, and even the appearance of conflicts of interest can have a negative impact on the Company. You should disclose potential conflicts of interest promptly and accurately, and to abide by any measures put in place by TERIMO ESTABLISHMENTS CO. LIMITED to protect its interests.
You have a conflict of interest if:
• Your actions or interests could prevent you from performing your duties in an honest, objective and effective manner
• You have an incentive to benefit yourself, your friends or family at TERIMO ESTABLISHMENTS CO. LIMITED cost
• You, your friends or family receive improper benefits as a result of your position at TERIMO ESTABLISHMENTS CO. LIMITED.
Whether a conflict of interest exists is not always clear. When in doubt, please discuss the particular situation with your manager, a member of the People Success Team or navigate to the section “Ask Questions” on page 16 of this code for additional ways to ask questions and obtain guidance.
Each team member should be alert for potential attacks on TERIMO ESTABLISHMENTS CO. LIMITED’ systems and customer-facing platforms. Please report anything that seems suspicious or concerning, even if you are unsure. If you observe or become aware of anything concerning or suspicious, please report details promptly to TERIMO ESTABLISHMENTS CO. LIMITED’ Chief Information Security Officer or Administrator.
We deal honestly, ethically and fairly with our customers, competitors, suppliers and each other. We have an absolute commitment to treat others with dignity, respect and equal opportunity. We conduct our business with honesty and integrity, and we expect our business partners’ values and business practices to mirror ours regarding compliance with the law, product quality, safety, human rights, treatment of employees and environmental compliance.
We are and want to always be a company that is known for Doing the Right Thing.
We are committed to acting professionally, fairly and with integrity at all times, and to never engage in bribery, kickbacks or corruption.
Under applicable anti-bribery and anti-corruption laws, companies can be held responsible for the actions of third parties engaged to act on their behalf, even if the entity is unaware of or does not approve of the third party’s actions. For that reason, please carefully review and attend to third party relationships, such as resellers, advisors, and contractors, and set clear expectations that bribery and corruption are not permissible under any circumstance.
We understand that building relationships with customers, partners and vendors is occasionally accomplished in social settings. Common sense and moderation must prevail in business entertainment engaged in on behalf of TERIMO ESTABLISHMENTS CO. LIMITED’. Team members may accept and provide business entertainment to or from anyone doing business with TERIMO ESTABLISHMENTS CO. LIMITED (e.g., dinners, sporting events, etc.) if the entertainment is modest, and intended to serve legitimate business goals and in compliance with applicable law. Similarly, the exchange of gifts (e.g., holiday cookies, bottle of wine) should be thoughtfully considered. If any team member has a question about entertainment or gifts, please ask your line manager.
We are committed to fostering a “politics-free” environment at the company. TERIMO ESTABLISHMENTS CO. LIMITED funds are not used to support any political party, political committee, or candidate. TERIMO ESTABLISHMENTS CO. LIMITED complies with all laws and regulations governing campaign contributions in any municipalities, constituency or local election, in any country. All team members are free to use their own funds to make individual political contributions in accordance with applicable law. TERIMO ESTABLISHMENTS CO. LIMITED will not provide reimbursement in any form for political contributions.
We recognize our responsibility to the community at large. Being an active participant in our community is a fundamental responsibility. We work hard to ensure that giving back to the communities where our employees work and live, and to making the world a better place,
is a theme that runs throughout our business. This commitment is exemplified by the number of TERIMO ESTABLISHMENTS CO. LIMITED employees involved in charitable organizations around the world as well as the support we provide to these organizations. Our commitment is more than a corporate program, it’s part of the people and the culture at TERIMO ESTABLISHMENTS CO. LIMITED’. To learn more about TERIMO ESTABLISHMENTS CO. LIMITED’ philanthropic programs, please review our Corporate Social Responsibility & Sustainability Report.
TERIMO ESTABLISHMENTS CO. LIMITED is fully aware of the broader impact a company like ours can have on our communities and our planet. The core of TERIMO ESTABLISHMENTS CO. LIMITED’ business is to help youth and women transition from use of plastic packaging to eco-friendly bio-degradable packaging, which in and of itself has a significant environmental impact.
We work to minimize our environmental footprint by recycling materials during construction and renovation of our properties. We use censored lighting, regulated biochemical treatment, energy saving appliances, windows and doors, as well as furnishings and carpet made with recycled materials and on-site water purification systems to reduce the number of plastic bottles used. Sustainability is a way of life at TERIMO ESTABLISHMENTS CO. LIMITED and it is exemplified through our products, customer interactions and employee engagement. For additional information, please review our Corporate Social Responsibility & Sustainability Report.
Please honestly and accurately report all business transactions and remember that you are responsible for the accuracy of your records and reports. Accurate information and reporting are essential to TERIMO ESTABLISHMENTS CO. LIMITED’ ability to meet legal and regulatory obligations. It is company’s policy to provide full, fair, accurate, timely and understandable disclosure in reports and documents filed with, or submitted to, the finance and accounting department and in other public communications. Team members may not enter into side agreements on behalf of the Company, whether written or verbal, which are intended to alter or provide additional terms, conditions or commitments that are not reflected in the actual agreement with a third party.
We are required to accurately account for all TERIMO ESTABLISHMENTS CO. LIMITED money and spend it only on lawful organization-related purposes. If our duties involve verification of expenditures or requests for reimbursement, we are each responsible for verifying that our expenditures legitimately comply with TERIMO ESTABLISHMENTS CO. LIMITED policies and applicable laws, and that the amount of reimbursement received is accurate. We are each responsible for safeguarding TERIMO ESTABLISHMENTS CO. LIMITED assets, and therefore we need to ensure proper accounting of expenses incurred as well as accurate payment of reimbursement requests. All requests for reimbursement should be submitted on a timely basis and be supported by original receipts. In addition, our expenditures must be properly recorded and comply with all applicable TERIMO ESTABLISHMENTS CO. LIMITED policies, including the Travel and Expense Reimbursement Policy.
All of our public communications, need to be accurate, timely and understandable. If any team member becomes aware of any material information or omission that may make our public disclosure misleading or inaccurate, please bring that information to the attention of the Managing Director.
TERIMO ESTABLISHMENTS CO. LIMITED’ good name is in your hands. We should always conduct ourselves in a manner that is consistent with protecting the Company’s good name and reputation. To that end, please do not make, or cause others to make, any false, disparaging or derogatory statements in public or private to any person, entity, media or social media outlet regarding TERIMO ESTABLISHMENTS CO. LIMITED’ products, business affairs, financial condition, or relationship with any of its customers.
We keep confidential information confidential. To earn and maintain the trust of our customers, we commit to maintain confidentiality and protect not only our own confidential information, but that of third parties that entrust us with their sensitive and confidential information.
Please maintain the security, privacy and integrity of confidential information from TERIMO ESTABLISHMENTS CO. LIMITED or any other entity including customers or other third parties with whom we do business. Confidential information of TERIMO ESTABLISHMENTS CO. LIMITED or any other entity should not to be shared with other team members unless they have a need to know the information to perform their job.
Third parties may ask you for information about TERIMO ESTABLISHMENTS CO. LIMITED’. Please do not discuss internal confidential TERIMO ESTABLISHMENTS CO. LIMITED matters or share internal confidential information with anyone outside of the company, except as required by your job or role and after an appropriate confidentiality agreement is in place. This applies particularly to inquiries concerning TERIMO ESTABLISHMENTS CO. LIMITED from the media, investment professionals (such as institutional investors, investment advisers, brokers and dealers) as well as to any form of social media. If you receive any inquiries of this nature, please decline to comment and refer the inquirer to one of our official spokespersons.
We are all required to comply with laws, rules and regulations applicable to TERIMO ESTABLISHMENTS CO. LIMITED’. We expect each team member to use good judgment and common sense and to seek advice in unfamiliar situations. If you become aware of any violation of law, rule or regulation by the company or by any team member, please report the violation promptly to your manager or our General Counsel. We always strive to address all matters internally where practical, but you should not feel discouraged from reporting any illegal activity to an appropriate government or regulatory authority. Team members may not discharge, demote, suspend, threaten, harass or in any other manner discriminate against another team member because he or she reports any such violation. This Code is not intended to and should not be construed to prevent you from engaging in concerted activity protected by the rules and regulations of the National Labor Relations Board (or government labor agency or board in your jurisdiction) or from testifying, participating or otherwise assisting in any state or municipal administrative, judicial or legislative proceeding or investigation.
TERIMO ESTABLISHMENTS CO. LIMITED is committed to the protection and preservation of human rights around the world. Our commitment to human rights is embedded in the culture and values that define our company and is reflected in our policies and actions toward our employees, partners, suppliers, and the communities and countries where we do business.
We require our business partners to exhibit respect for fundamental human
rights and human dignity and respect for the equal rights of men and women while doing business with us.
We are committed to an inclusive, safe and ethical workplace as demonstrated within our Equal Employment Opportunity Statements and our other People Success policies.
TERIMO ESTABLISHMENTS CO. LIMITED is committed to the fight against money laundering, which continues to be the focus of considerable attention by governments, international organizations and law enforcement agencies around the world. This is an issue that we take extremely seriously.
Money laundering is the process of concealing illicit funds or making them look as though they are legitimate. This includes concealing the criminal origin of money or other property – sometimes called the proceeds of crime – within legitimate business activities. It also covers the use of legitimate funds to support crime or terrorism.
We never condone, facilitate or support money laundering, which means:
We will always comply with anti-money laundering laws and regulations which generally includes identifying clients, monitoring client activity and reporting suspicious or unusual activity consistent with applicable laws.
We will seek to minimize money risks through our anti-money laundering policies and practices. These are designed to avoid receiving, or being involved in an arrangement or transaction that relates to funds that may be the proceeds of crime.
We take reasonable and appropriate actions to identify and assess the integrity of our business partners. We should be vigilant and exercise good judgment when dealing with unusual customer transactions.
We each play a role in actively guarding against the use of our brand, products and services for money laundering.
TERIMO ESTABLISHMENTS CO. LIMITED supports free and fair competition. We do not engage in any conduct that would unfairly and unlawfully diminish competition in the marketplace. To ensure markets operate fairly and efficiently, many nations have implemented laws to prohibit anti-competitive practices. While anti-trust and competition laws are complex, they generally forbid entering into formal or informal agreements regarding activities that may restrict competition.
Examples of conduct that is generally prohibited under the anti-trust and competition laws and this Code include:
Agreements among competitors about price or margin
Agreements among competitors to allocate markets or customers
Coordinating agreements among customers not to deal with competitors
Unlawful restrictions on resale
Sales unlawfully conditioned on agreements to purchase other products
Exchanging commercially sensitive information with competitors, even if there is no agreement of any kind
TERIMO ESTABLISHMENTS CO. LIMITED intellectual property (patents, copyrights, trademarks, trade secrets) and other proprietary information are valuable assets. Protecting these assets, including documenting their creation and maintaining their secrecy, is critical to TERIMO ESTABLISHMENTS CO. LIMITED’ continued success. Patentable inventions include new and useful products, compositions, devices, methods, and techniques. Trademarks include words or symbols used to identify the entity and its products and services. Copyrights protect creative expression, but can include things such as software product labels, manuals and website content. Trade secrets include data or information that is treated as secret, derives value from not being known outside TERIMO ESTABLISHMENTS CO. LIMITED’, and that is unavailable to those outside TERIMO ESTABLISHMENTS CO. LIMITED except under confidentiality agreements. Proprietary information includes data or other information that has been developed or assembled on company’s (or a third party’s) time or at Organization’s (or a third party’s) expense and is non-public or not easily determined or re-created by others.
It is our duty to protect the company’s intellectual property and proprietary information, and not share such information with anyone outside or within TERIMO ESTABLISHMENTS CO. LIMITED who is not authorized to receive and does not have a business need to receive that information.
All material used in the course of our business that is protected by the intellectual property rights of others must be appropriately used with permission from the third party that owns or controls such rights. Questions about whether permission is needed, or whether the material may already have been licensed by TERIMO ESTABLISHMENTS CO. LIMITED’, should be directed to the Legal Team.
All team members play a role in protecting TERIMO ESTABLISHMENTS CO. LIMITED assets and using those assets efficiently and appropriately. Assets provided to team members by the company, including desktops, laptops, mobile devices, and TERIMO ESTABLISHMENTS CO. LIMITED data stored within them, remain the exclusive property of the organization. Theft, carelessness and waste have a direct impact on organization’s financial performance. Please report loss of any TERIMO ESTABLISHMENTS CO. LIMITED device or data to your manager.
Please keep in mind that TERIMO ESTABLISHMENTS CO. LIMITED’ intellectual property includes not only patents and trademarks, but also trade secrets, know-how and other product and technical information that is not publicly known. Protection of this intellectual property is critical to the company’s continued success. Please use care not to purposefully or inadvertently disclose this information to parties outside of TERIMO ESTABLISHMENTS CO. LIMITED’. There may be instances when disclosure of intellectual property to third parties is appropriate, in which case team members should seek guidance from the company’s Legal Team prior to any such disclosure, to ensure that appropriate protections are in place.
Those of us who use online communication tools like blogs, social media sites and other digital platforms — whether on our own personal time or in an official capacity on behalf of TERIMO ESTABLISHMENTS CO. LIMITED’ — assume responsibility for ensuring that our activities comply with TERIMO ESTABLISHMENTS CO. LIMITED policies and laws or regulations.
Any time we endorse or promote TERIMO ESTABLISHMENTS CO. LIMITED or any of our products in a forum in which our connection to TERIMO ESTABLISHMENTS CO. LIMITED is not obvious, whether in person or online, we need to disclose our connection to the company. Such disclosure should be clear and conspicuous, readily visible within our communication, and understandable and apparent to the average reader near the beginning of the communication.
If we use social media or other forums to express our personal views regarding TERIMO ESTABLISHMENTS CO. LIMITED’, our products or our competitors, we should indicate that our comments do not represent the positions, strategies or opinions of the company. If we engage or provide something of value to a consultant, agency, celebrity, consumer, blogger or other party to entice or encourage them to review, promote or endorse TERIMO ESTABLISHMENTS CO. LIMITED or our products, we must ensure that those parties also disclose their affiliation with the company.
These requirements apply even to comments we make on our own personal blog or social media pages or on third-party websites, as well as to actions we take on TERIMO ESTABLISHMENTS CO. LIMITED’ -affiliated websites, such as product ratings and reviews and our brands’ social media pages.
Our commitment to accurately and honestly reflect the business transactions of TERIMO ESTABLISHMENTS CO. LIMITED relies on an open and honest relationship with independent auditors. No team member shall, directly or indirectly, make or cause to be made a materially false or misleading statement (or omit to state, or cause another person to omit to state, any material fact necessary in order to make statements made, in light of the circumstances under which such statements were made, not misleading) to an accountant in connection with any audit, review or examination of the company’s financial statements or the preparation or filing of any document or report.
If you have a concern or complaint regarding an accounting or auditing matter or internal accounting controls, you may confidentially and anonymously submit those concerns or complaints in writing at the addresses provided at the end of this Code. Any such concerns or complaints may also be communicated confidentially and, if you desire, anonymously, pursuant to TERIMO ESTABLISHMENTS CO. LIMITED ‘Whistleblower Policy. All complaints will be reported to the Audit Committee.
TERIMO ESTABLISHMENTS CO. LIMITED has a responsibility to monitor compliance with this Code and to act when it becomes aware of violations. When we in good faith seek advice, raise a concern or report actual or suspected misconduct, we are following the spirit of our Code and doing the right thing. We should all feel comfortable reporting actual or suspected misconduct without fear of losing our jobs or other harm.
Each team member can make a tremendous difference to this organization, so it is vital that we all act with integrity, respect and in accordance with applicable laws. TERIMO ESTABLISHMENTS CO. LIMITED will not discipline, discriminate or retaliate against any team member who reports a complaint or concern in good faith.
If you or someone you know is the victim of retaliation, report it immediately to any of the TERIMO ESTABLISHMENTS CO. LIMITED resources available for reporting.
It is a violation of our Code to retaliate against anyone for cooperating with or participating in an investigation involving possible violations of the law, our Code or other TERIMO ESTABLISHMENTS CO. LIMITED policies, even if the investigation finds no evidence of misconduct. Anyone who retaliates against a person for participating in an investigation will be subject to disciplinary action, including termination
We have a responsibility to ourselves, each other and TERIMO ESTABLISHMENTS CO. LIMITED to conduct business legally and ethically. We should be alert to activities going on around us and speak up if we suspect illegal or unethical conduct by any employee, contractor, vendor, supplier, director, customer or other person working for or on behalf of the company.
Sometimes, it might seem easier to “look the other way,” but doing nothing is, in itself, an action that can have serious consequences for us as individuals and for TERIMO ESTABLISHMENTS CO. LIMITED’. Participation and commitment to monitoring the integrity of our business conduct is instrumental in sustaining our ethical culture. If we do not speak up, TERIMO ESTABLISHMENTS CO. LIMITED cannot address the problem.
If we suspect that someone is behaving illegally or unethically, or that an actual or potential violation of the Code or TERIMO ESTABLISHMENTS CO. LIMITED policy has occurred, each of us is responsible for reporting it.
Ways to Raise Questions and Report Concerns:
Speak to your line manager or the Admin
Contact the General Counsel
Send an anonymous message to our Admin
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