Our Code of Ethics and Business Conduct
Little Rapids Corporation appreciates the importance of acting with integrity and honesty at all times. We remain committed to our core values of achievement, teamwork, innovation, and respect as they provide a basis for all aspects of our business relationships. We seek to deal fairly and responsibly in the course of carrying out our business. Acting with integrity and honesty means that we must adhere to and support a sense of ethics and business conduct that places our dealings with one another and with our various stakeholders above and beyond reproach.
Just as our values direct our thinking, our policies drive our actions. We expect every LRC employee to understand and adhere to our code of ethics and business conduct. It is extremely important that each of us—no matter what our job, business unit, or geographic location—understands and adheres to these policies. Our customers, competitors, suppliers, and fellow employees must be able to trust that all of our actions and interactions will be guided by fairness, respect, and integrity.
This Code is intended to demonstrate LRC’s commitment to ethical business conduct, to compliance with all relevant laws and regulations, and to show beyond any doubt that such conduct is a fundamental part of LRC’s values and corporate culture. This Code reflects and anticipates many of the principles detailed in the policies and procedures that are already in place or may in the future be put in place throughout LRC’s operations. This Code does not repeat all of the detail that falls within such policies and procedures. Instead it serves as a baseline and introduction to such detail. This Code cannot be expected to cover every circumstance that could conceivably arise. Instead, it offers LRC employees basic guidance as to how they should deal with a particular situation and most importantly where or to whom they should go in search of more detailed guidance and support.
It is the duty of every one of us to familiarize ourselves with the content of the Code and, where relevant to our role within LRC, the detailed policies and procedures that lie underneath, and to act accordingly. Our fellow employees, shareholders, customers, suppliers and other stakeholders expect no less from us.
Kirk S. Ryan
President & CEO
The LRC Values
All LRC employees are familiar with the core values of Little Rapids Corporation; the principles that guide us, express our beliefs and reflect our hopes for the kind of company we want to be. The core values of achievement, teamwork, innovation, and respect provide the basis for all aspects of our business relationships. This Code is intended to reflect and be consistent with the LRC values. The high ethical standards expected of LRC associates, past and present, have been a major factor in our company’s success. In order to become the leader in products, services, and solutions that enable and transform the way frontline caregivers and professionals improve the lives of their patients and clients, we must continue to follow our Code of Conduct. These standards help make it possible for us to be proud of ourselves and our company.
Health, Safety and the Environment
We are committed to producing and selling products that are safe and that fulfill customer expectations. We are equally committed to safety in the workplace. Safety is fundamental to the success of LRC. Our goal is an accident-free workplace. We all have a duty to take reasonable care for our own health and safety and for the health and safety of other people affected by our actions.
LRC is committed to being a good corporate citizen with a sincere and proper regard for the environment. The company strives to comply fully with governmental requirements. All employees are expected to act as responsible citizens by adhering to workplace rules and regulations concerning the environment.
LRC respects the rights and dignity of all its employees. We welcome and promote diversity in our workforce and will support implementation of the LRC core values to develop our people and provide them with a challenging and rewarding workplace environment. Decisions regarding selection, terms of employment, advancement, retention and termination will be made without regard to race, religion, color, national origin, age, sex, marital status, sexual orientation, disability or veterans status relative to essential job functions. LRC is an equal opportunity and affirmative action employer.
LRC employees are expected to treat each other with respect and dignity. Harassment, victimization or bullying of any employee, for any reason, will not be tolerated.
LRC employees have an obligation to attend their place of work fully alert and able to perform their job. Drug and illegal substance abuse as well as alcohol abuse will be seen as a serious breach of this obligation as any such abuse may put the safety of that employee and other employees at risk as well as compromise their job performance and LRC’s business interests.
Compliance with Laws
We will strive to comply with all applicable governmental laws, rules and regulations. The company also commits to engage in no activity that violates or appears to violate the antitrust laws of countries in which it does business. In contacts with competitors in the United States and many other countries, it is illegal to discuss pricing policies, sales terms, inventory levels, business or marketing plans and/or any other confidential matters. If a competitor raises these issues, no matter how casually, stop the conversation immediately, explain that it is against our policy to discuss such matters and, if necessary, leave the gathering. Any incident of this nature should be reported to a member of our senior leadership team.
In the ordinary course of business, information is acquired about other companies, including customers, suppliers and competitors. Obtaining this type of information is an ordinary part of the competitive system. However, there are legal and ethical limits on acquiring competitive information. We should not acquire information through improper means, such as industrial espionage, nor should we hire an employee of a competitor to gain confidential information or encourage employees of competitors to disclose confidential information about their employer.
Gifts, Entertainment and Sponsorship
LRC employees and their family members may not give or accept any gift, entertainment, transportation, sponsorship, charitable donation or other benefit which might be intended or perceived as an attempt to improperly influence the business relationship between LRC and any current or prospective supplier, customer, or other party doing business with LRC. However, this prohibition is not intended to apply to any customary and reasonable business courtesies, including entertainment, token gifts, meals or transportation given or received in the normal course of business dealings.
Dealing with Customers and Suppliers
LRC is committed to excellence in the development, manufacture and delivery of its products and to meeting and exceeding our customers’ expectations as we comply with our contractual obligations and high quality standards.
We will select and treat our suppliers for products, materials and services impartially and without discrimination. Suppliers, and increasingly our whole supply chain, will be evaluated on the basis of quality, price, reputation, timing, performance, commitment, reliability and corporate responsibility.
Every employee has an obligation to protect customer and supplier relationships by acting ethically and fairly.
No contributions of LRC funds, products, services or other resources is to be made to any political party or candidate unless such contribution is legal under applicable local laws and made with the express prior approval of the LRC Board of Directors.
No illegal or improper payments may be made to employees of our suppliers, customers or competitors or to any government officials or employees. Any payments to government officials or employees that are legal and proper where made must conform to any applicable LRC policies. Payments to consultants, distributors, agents or other intermediaries must be at prevailing customary rates in direct proportion to the services provided and for legitimate services provided.
Conflicts of Interest
In a world of complex relationships, any one of us could be challenged to balance our personal interests with those of the company. Remember, you may use the company’s name, information, goodwill and assets only when it’s good for the company—not to derive personal gain. Similarly, opportunities discovered using company resources belong to the company and may not be pursued personally by employees.
LRC will not permit employees to work for a competitor or supplier or to be a consultant or member of a board of directors of a competitor or supplier if it is reasonable to believe that the interest or relationship will conflict with the company’s business interests.
LRC employees should avoid having any financial interests in an outside concern doing business with LRC or competitive with LRC, where such interests might influence adversely the employee’s responsibilities to LRC.
Financial and Accounting Controls & Records
All information about LRC must be recorded and presented accurately, diligently and fairly, in accordance with good business practices, applicable accounting standards and local laws.
Every LRC employee has the duty to preserve, protect and prevent the dissipation of LRC’s assets, including its property, plant, equipment and monies, and is expected to use those assets appropriately.
Confidential Information and Trade Secrets
In the course of our work, many of us have access to confidential information, including business plans, financial information, patent applications, product development information, and personnel and salary information. Also included in the confidential category are company research and development activities and manufacturing methods.
Disclosure of confidential information outside the company, especially to competitors, could be harmful to the company’s competitive position. Consequently, confidential information should be maintained in secure files or storage areas and properly disposed of in accordance with our records retention policy. Also, care should be exercised when discussing information in public such as in elevators, airplanes and restaurants, when using cellular or otherwise unsecured communications devices.
To the extent that an employee has access to confidential information and trade secrets, the employee must be very careful about its use and vigilantly protect it from inadvertent disclosure. Employees should also ensure they comply with LRC’s obligations to maintain the confidentiality of information from third parties.
As a matter of good practice, LRC is required to retain business records for reasonable periods of time prior to their destruction and in order to comply with specific legal and regulatory requirements in this regard. This relates particularly to contractual documentation, tax, finance, accounting, employee health & safety and the environment. Also, records and documentation pertinent to a particular investigation or legal dispute may not be destroyed once LRC has notice of related pending litigation.
Code of Conduct Violations and Responsibility
Violations of the Code of Conduct are serious offenses that may result in disciplinary action, reprimand, suspension, dismissal or civil action by the company. In addition, violations of the Code of Conduct which are also violations of law may result in fines, penalties, or other legal remedies.
Implementation of this Code is every employee’s responsibility; acting with integrity and using sound business judgment will go a long way toward assuring ethical behavior. This Code and our compliance with it will do much to strengthen our culture and play its part in creating a “great” company which will stand out against its peers.