Overview
The AHI Carrier FZC Code of Ethics applies to AHI Carrier FZC and its subsidiaries around the world. The Code sets out the rules that govern our activities and expresses our fundamental principles, defining the framework for our decision-making.
The ethical conduct of AHI Carrier FZC’s business practices is based on the following principles:
- We must comply with the law.
- We must act in good faith.
- We must consider the impact of our decisions on all stakeholders and seek fair solutions.
- We must communicate honestly and directly with all stakeholders.
- We must always strive to build relationships of trust, treat others with respect, and conduct our activities with integrity.
The integrity, reputation and profitable progress of AHI Carrier FZC ultimately depend on the individual actions of our board members, officers, employees and representatives around the world. Each of us is personally responsible and accountable for complying with the Code.
Our Principles — How We Make Decisions
Maintaining the highest standards of ethical and professional conduct is a continuing commitment of AHI Carrier FZC. This includes the relationships we maintain with our customers, suppliers, competitors, the local communities in which we operate, and our employees.
Our Customers
We will provide high quality and value, competitive prices and honest dealings to those who use our products and services. We will deal with our customers in a lawful and ethical manner.
Our Employees
We will treat our employees fairly and use employment practices based on the principle of equal opportunity for all employees. We will respect our employees’ right to privacy and treat them with dignity and respect. We are committed to providing safe and healthy working conditions and a climate of honest communication for all our employees.
Our Suppliers and Partners
We will deal with our suppliers and business partners fairly and impartially. We seek to establish long-term business relationships, avoiding any form of discrimination or deception.
Our Shareholders
We will make every effort to deliver high value to our shareholders. We will safeguard the value of their investment through the prudent use and protection of corporate resources and by maintaining the highest standards of legal and ethical conduct in all our business transactions.
Our Competitors
We will engage in open, independent and fair competition, basing our efforts on the merits of our competitive products and services.
Our Local Communities
We will act as a responsible “corporate citizen” in all local communities in which we operate around the world. We will comply with all national and local laws and will make every possible effort to improve the standard of living of our local communities.
Our Standards of Conduct — How We Conduct Our Activities
The following standards of conduct define our minimum requirements for maintaining ethical behavior. Because these standards cannot cover every specific circumstance, they must be interpreted and applied within the framework of the laws, morals and customs of the countries in which we operate, as well as in light of the relevant policies of AHI Carrier FZC and common sense.
Reasons such as “everyone does it” or “it is not illegal” are not considered sufficient justification for violating these Standards. We must remain alert at all times in order to avoid, both inside and outside work, situations and actions that create even the slightest impression of illegal or unethical behavior that could discredit AHI Carrier FZC.
Quality & Safety
The products and services of AHI Carrier FZC must be provided with the safety and health of our customers, users and employees, as well as any other person, as a primary concern.
Marketing & Sales
AHI Carrier FZC will compete in the global market based on the merits of its products and services. We will sell our products and services honestly and will not pursue any sale whose completion requires us to violate the law or these standards.
When making comparisons with competitors, we must take care not to disparage them by relying on inaccurate information.
All persons acting on behalf of AHI Carrier FZC must comply with the laws on improper payments.
Business gifts that are customary and reasonable in frequency and value are generally permitted. Gifts intended as an exchange for favorable treatment, or gifts prohibited by the relevant policies of the recipient or the recipient’s employer, are not permitted under any circumstances.
AHI Carrier FZC does not offer or accept bribes.
The subject of business gifts is covered by the policy entitled “Giving and Receiving of Business Gifts.”
Protection of Information Belonging to Others
AHI Carrier FZC respects the legal property rights and trade secrets of our customers and suppliers, as well as those of any third party. AHI Carrier FZC will request, accept, use and disclose proprietary information owned by others only in compliance with applicable law and the requirements of this Code.
In the highly competitive environment of today’s global markets, gathering information about our competitors and competitive products and services is a necessary and normal business process. When gathering competitive information, AHI Carrier FZC will not use improper means, such as theft or deception.
Personal information collected from customers, suppliers and other visitors to AHI Carrier FZC websites and facilities will be appropriately protected.
Protection of Corporate Property
The assets of AHI Carrier FZC, including tangible assets such as facilities, cash, equipment and information systems, and intangible assets such as intellectual property, trade secrets, invention disclosures, sensitive commercial and technical information, computer programs and business know-how, will be used properly and as intended by management.
AHI Carrier FZC assets will not be used for personal gain. All business transactions must have management approval and must comply with the policies that define signature authority and internal control and approval procedures.
Accuracy of Records
All assets and liabilities, revenues, expenses and business transactions must be recorded fully and accurately in the books and records of AHI Carrier FZC, in accordance with applicable law, accepted accounting principles and the established financial policies and procedures of AHI Carrier FZC.
Budget proposals and financial evaluations should fairly and accurately reflect all information relevant to the decision being requested or proposed. No secret funds containing cash or other assets will be created or maintained for any reason.
AHI Carrier FZC will inform customers and suppliers of errors it discovers and will correct them promptly through credit notes, refunds or other mutually accepted means.
Government Contracts
AHI Carrier FZC will comply with the laws on government contracts that govern AHI Carrier FZC’s business relationships with governments around the world.
AHI Carrier FZC takes particular care to comply with the unique and specific rules governing contracts with the U.S. government. AHI Carrier FZC will always follow government rules on fair competition, respect restrictions that apply to public officials, such as gifts and employment, deliver products and services that meet specifications, comply with government requirements for accounting and billing, request reimbursement only for allowable costs, and ensure the accuracy of submitted information.
Equal Employment Opportunities
AHI Carrier FZC will treat employees and applicants for employment impartially, based solely on factors related to the legitimate business interests of AHI Carrier FZC.
AHI Carrier FZC makes every possible effort to ensure a continuing competitive advantage in the quality and talent of its workforce, and AHI Carrier FZC supports initiatives that promote workforce diversity, as described in the policy entitled “Managing Workforce Diversity.”
Work Environment
AHI Carrier FZC is committed to providing its employees with a work environment that protects against every known source of risk to safety and health, and at the same time does not allow discrimination, harassment or personal conduct that does not contribute to a productive working climate.
All local AHI Carrier FZC companies worldwide comply with the laws and regulations governing the possession or use of alcohol, drugs and other controlled substances.
Subject to applicable local law and with the approval of the Chief Executive Officer or his/her designee, local management has the right to make decisions regarding the availability of alcoholic beverages on AHI Carrier FZC premises. AHI Carrier FZC prohibits its employees and any other person from being under the influence of substances while on company premises.
AHI Carrier FZC prohibits everyone from using, selling, purchasing, distributing, possessing or having controlled substances in their system while on company premises. Naturally, this prohibition does not apply to lawfully prescribed medicines that are used legally.
Protection of Employee Privacy
AHI Carrier FZC respects its employees’ right to privacy. AHI Carrier FZC will comply with applicable law in all jurisdictions where AHI Carrier FZC collects, uses or discloses employees’ personal information.
Personal conduct unrelated to AHI Carrier FZC is not the company’s concern, unless such conduct adversely affects the employee’s work performance or harms the reputation or other legitimate business interests of AHI Carrier FZC.
Employee Communication
AHI Carrier FZC will provide employees with timely information about business results, product performance, customer relations and customer achievements, at the discretion of the Chief Executive Officer or his/her designee. Appropriate communication channels will be provided to encourage individual expression and open dialogue regarding employees’ views, conduct and concerns.
Employee Personal Development
AHI Carrier FZC is committed to promoting the personal development of employees by helping them improve and expand their work skills and lifelong learning.
Compensation & Benefits
AHI Carrier FZC will seek, motivate and retain people who demonstrate enthusiasm and dedication by providing compensation and benefit programs that are competitive in the global markets in which we operate.
Conflicts of Interest
Board members, officers, employees and representatives of AHI Carrier FZC must be loyal to AHI Carrier FZC and must deal with suppliers, customers and every other person in a manner that does not create even the slightest impression of a conflict between their personal interests and the interests of AHI Carrier FZC.
AHI Carrier FZC’s policy entitled “Conflicts of Interest” defines conflicts of interest in greater detail, provides guidance on specific issues and presents procedures for resolving potential conflict-of-interest situations. It covers, among other things, the following:
- Direct or indirect financial interest in, or ownership of shares in, suppliers, customers or competitors of AHI Carrier FZC.
- Soliciting or accepting gifts or compensation of any kind from suppliers, customers or other existing or prospective parties doing business with AHI Carrier FZC (see the policy entitled “Business Gifts from Suppliers”).
- Service as a board member, employment or voluntary service in another company or organization.
- Personal use of corporate assets, such as tangible property, proprietary information, non-public information or business opportunities.
Actual or potential conflicts of interest must be disclosed to AHI Carrier FZC for review. In case of doubt, consult management.
Representatives
All representatives, other than board members, officers and employees, of AHI Carrier FZC must act on behalf of AHI Carrier FZC in a manner consistent with the Code.
AHI Carrier FZC will not use representatives to circumvent the standards of conduct described in this Code.
Business Partners & Suppliers
AHI Carrier FZC procures equipment, supplies and services based on merit. AHI Carrier FZC’s business partners, suppliers, dealers and subcontractors will be treated with impartiality and integrity and without discrimination.
Those who deal with suppliers or prospective suppliers are subject to AHI Carrier FZC policies governing conflicts of interest and business gifts from suppliers.
Environmental Protection
AHI Carrier FZC will conduct its worldwide activities in a manner that ensures protection of the natural environment. All required permits will be obtained, the terms of those permits will be followed, and efforts will be made to minimize waste.
Community Activities
AHI Carrier FZC supports community organizations and activities in the countries where it operates. We will support worthwhile civic initiatives and charitable activities, and employees will be encouraged to participate on a personal level.
Political Participation
AHI Carrier FZC will comply with all national, state and local laws that regulate AHI Carrier FZC’s participation in political activity, including restrictions on contributions to political parties, national political committees and individual candidates.
Those who make contacts on behalf of AHI Carrier FZC with political parties, candidates, elected persons or government officials must fully comply with all relevant applicable laws and AHI Carrier FZC policies.
AHI Carrier FZC does not offer or accept bribes.
International Trade
Various governments and multinational organizations control the international movement of certain commodities, manufactured products, technical data and services, and impose full or partial trade embargoes on certain countries, individuals and legal entities. These controls may apply to imports, exports, financial transactions, investments and other forms of business transactions. AHI Carrier FZC will comply fully with the relevant legislation.
We must remember that the export of technical data may occur by electronic, oral or visual means, and that an export may take place even without the transfer of technical data from one country to another. In addition, some countries prohibit or restrict the re-export of goods beyond their original destination.
AHI Carrier FZC’s policy entitled “Export/Import Controls & Economic Sanctions” contains specific guidance, as does the policy entitled “Antiboycott Policy.”
Antitrust Law
AHI Carrier FZC will comply with antitrust law, also known as competition law, in every jurisdiction in which it operates. We will not engage in bid rigging, fix prices, allocate markets or abuse a dominant market position.
AHI Carrier FZC’s policy entitled “Antitrust Compliance” contains specific prohibitions on communications with competitors on matters relating to the marketing and sale of our products and services. For example, we are not permitted to discuss prices, costs, profits or marketing strategies.
Local Laws & Customs
AHI Carrier FZC serves markets in many countries, and its activities are governed by laws and cultural and social standards that often differ significantly from country to country.
AHI Carrier FZC will comply with the national and local law of the countries in which it operates. In the event of a conflict between the applicable laws of two countries, you should contact the office of the Chief Executive Officer.
AHI Carrier FZC will not knowingly facilitate illegal conduct or acts of fraud by third parties, regardless of local customs.
Under certain circumstances, it may be appropriate to conduct due diligence on potential business partners in order to ensure an appropriate degree of confidence that their involvement in improper activities in relation to their dealings with AHI Carrier FZC is not considered likely. Such investigations may include, among other things, checking or confirming the following:
- The company is lawfully registered, and valid and consistent company registration and tax registration numbers exist.
- The company actually exists under the terms stated by the persons representing it.
- The address is real and there are no unusual links with offshore companies.
- The beneficial owners are known.
- The subcontractor’s main activities are consistent with what we are able to know.
- Any past criminal or tax offenses, as well as their outcome, are examined.
The Chief Executive Officer establishes procedures that define how and under what circumstances such investigations will be carried out before working with third parties.
Corporate Citizenship
AHI Carrier FZC is firmly committed to being a responsible corporate citizen and believes that cooperation with others improves every individual. For its employees, AHI Carrier FZC guarantees a safe and healthy work environment. AHI Carrier FZC does not use child or forced labor.
In the local communities in which it operates around the world, AHI Carrier FZC works to protect the environment. As stated in other sections of the Code, AHI Carrier FZC complies with the law, does not discriminate in its personnel practices and does not engage in corrupt practices. Beyond its own commitments, AHI Carrier FZC expects its direct suppliers to apply appropriate codes of business conduct.
Summary
We follow the Code and do not treat it merely as a set of rules, but as a “compass” that helps us fulfill our commitments.
We comply with the law, conduct our activities in good faith, communicate honestly and seek fair outcomes for everyone.
We ask questions, raise concerns and point out problems.
Simply put, we build relationships of trust, treat others with respect and conduct our activities with integrity.
Our Code of Ethics — How We Comply
Compliance with the Code of Ethics
Every board member, officer, employee and representative of AHI Carrier FZC around the world must comply with this Code and its implementing provisions and policies.
Managers at all levels of AHI Carrier FZC’s organization are responsible for creating and promoting a culture characterized by ethical business practices, encouraging honest communication and ensuring that employees are familiar with and committed to this Code of Ethics.
Any failure to comply with this Code or its requirements will result in appropriate disciplinary action, up to and including termination of employment. Disciplinary sanctions will be decided by management, which will determine them in accordance with the principles of fairness and equal treatment.
Submitting Questions & Reports
Any question regarding this Code, its application under specific circumstances, as well as any report of an actual or suspected violation, may be submitted at any level of the supervisory chain, to the Compliance Officer, to the Finance Integration Manager, or through the Confidential Communication Channel (www.ccc.ahi-carrier.ethicspoint.com).
The Confidential Communication Channel is confidential, meaning that the identity of the reporting person is protected; neutral, meaning that it does not take the side of either management or employees; and independent, meaning that it is not managed by management. In addition, questions or reports may be submitted anonymously through the Confidential Communication Channel.
The Confidential Communication Channel operates exclusively as a mediation channel. Management is responsible for investigating the concerns raised and for providing answers to questions submitted through the program. The Confidential Communication Channel handles all matters concerning the company, except those prohibited by law. The identity of persons using the Confidential Communication Channel will be protected, unless disclosure is required by court order or there appears to be a risk of serious harm.
The Confidential Communication Channel is an established two-way communication channel and is intended for the resolution of less complex issues. The Confidential Communication Channel is available worldwide through a secure, encrypted, web-based electronic system (https://www.ccc.ahi-carrier.ethicspoint.com). To ensure the maximum degree of confidentiality, corporate computers should not be used for any communication through the Confidential Communication Channel.
Any AHI Carrier FZC employee and any other person who has suspicions of irregularities in the company’s accounting procedures, internal control mechanisms or audit matters may report them to AHI Carrier FZC by contacting management, at any management level. Alternatively, AHI Carrier FZC employees may use the Confidential Communication Channel.
Implementation of the Code of Ethics
This Code of Ethics has been approved by the Board of Directors of AHI Carrier FZC and applies globally. The term “AHI Carrier FZC,” as used in this Code, includes all companies controlled by AHI Carrier FZC. The Code applies to all board members, officers, employees and representatives of the company, including consultants and agents.
The CEO of AHI Carrier FZC is responsible for implementing this Code.
