AKS's SOC is applicable to AKS-VICON JV

STANDARDS OF CONDUCT (SOC)

Each Aks director, officer and employee must:

 

1. Comply with all laws, rules and regulations.

Compliance with the law does not comprise our entire ethical responsibility. Rather, it is a minimum, essential condition for performance of your duties. If you suspect that you, a co-worker or Aks may have done or may be about to do something that violates this Policy, other Aks policies, or any regulation or law, immediately contact your supervisor.They are there to help you interpret the Policy, applicable laws, rules and regulations before you act. If you don't notify one of these people when you know or suspect a violation, you may jeopardize yourself, your employment, and Aks.

 

2. Be honest and true.

You must always give accurate information to Aks's customers and vendors, and to the public. If you are involved in proposals, bid preparations, or contract negotiations, you must be certain that all statements, communications, and representations to prospective customers are accurate and truthful. Do not misrepresent Aks's services when you sell, or Aks's needs when you buy, or any other information in your negotiations, contracts and daily work. Your estimates and projections should be reasonably based on available facts and logical assumptions, and formulated without bias that could skew your results. Generally, avoid giving estimates and projections in public disclosures. If you are issuing information to the public or media, clear it first with Aks's Directors. 

3. Honor individual and corporate obligations.

Make commitments to customers, suppliers, business partners and your co-workers that you and Aks expect to fulfill. Recognize also that Aks makes corporate commitments, and communicate with other departments to make sure your proposed commitments support, and do not conflict with, established ones. Meeting your commitments is an individual accomplishment, while meeting Aks's commitments enhances our corporate integrity.

 

4. Obtain and Use Aks Assets Wisely.

Proper use of Aks property, electronic communications systems, information resources, material facilities and equipment is your responsibility. Use and maintain these assets with the utmost care and respect, guarding against theft, waste and abuse, and never borrow or remove them from Aks property without management's permission. While these assets are intended to be used for Aks business, occasional personal use by employees may be permitted if it does not adversely affect the interests of Aks and permission is given. Personal use of Aks assets must always be in accordance with other Aks policies-consult your supervisor for guidance and permission.

 

5. Negotiate fairly and quickly.

Solicit, buy and sell on the basis of quality, service and price. Refrain from negotiating reciprocal agreements or coercing vendors to deal with Aks. Report to the board that any party negotiating with Aks who infers that a Aks officer, or employee demands a certain deal outcome.

 

6. Compete fairly and do not disrupt free trade or restrict competition.

Antitrust laws prohibit agreements and practices "in restraint of trade" such as price fixing and boycotting suppliers or customers. They also bar pricing intended to run a competitor out of business; disparaging, misrepresenting or harassing a competitor; stealing trade secrets; bribery; and kickbacks. Unless you have a legitimate and legal purpose, do not discuss with, or reveal Aks prices, rate establishing methods, terms, or service schedules to parties outside Aks. Avoid using misrepresentation or innuendo that injures or discredits a legitimate competitor.

To ensure that our customers can purchase goods or services at the same or better price as others in similar conditions, use price variances only if there are differences in the quantity or cost of providing the goods or services, if you are matching a competitor's price in good faith, or if conditions change that effect the marketability of the goods or services.

 

7. Do Not Usurp Business Opportunities.

You are prohibited from (a) taking for yourself personally opportunities or benefits that are discovered through the use of your position or Aks property or information, (b) using your position or Aks property or information for personal gain, and (c) competing with Aks. You owe a duty to Aks to advance its legitimate interests when the opportunity to do so arises.

 

8. Generally avoid gifts.

Aks's business dealings should always be free from even the perception that favorable treatment was sought, received, or given in exchange for gifts or favors. You must neither give nor accept business courtesies that constitute, or could be reasonably perceived as constituting, unfair business inducements or that would violate law, regulation or policies of Aks or a customer, or could cause embarrassment to or reflect negatively on Aks's reputation.

 

9. Business Courtesies to Non-Government Persons

Meals, Refreshments and Entertainment

It is an acceptable practice for Aks employees to provide meals, refreshments, entertainment, and other business courtesies of reasonable value to non-government persons in support of business activities, provided:

*The practice does not violate any law or regulation or the standards of conduct of the recipient's organization. It is your responsibility to inquire about prohibitions or limitations of the recipient's organization before offering any business courtesy; and

*The business courtesy must be consistent with marketplace practices, infrequent in nature, and may not be lavish or extravagant. While it is difficult to define "lavish or extravagant" by means of a specific dollar amount, a common sense determination should be made consistent with reasonable marketplace practices.

 

10. Keep outside interests from conflicting with your job.

The Board of Directors must approve any material transactions between Aks and its directors, officers, stockholders, employees, agents or affiliates, and members of their immediate family. This includes any transactions with third parties (e.g., vendors, franchisees) in which such persons have a material interest. If you encounter any such transactions, forward them to the Legal Department.

Conflicts of interest can arise when you or a member of your family receive improper personal benefit because of your position with Aks. Do not take actions, conduct business, or make statements that create real or potential conflicts with Aks's interests, including taking a personal, proprietary or financial interest in an entity with which Aks does business or competes, or which could adversely, or appear to adversely, influence you in your Aks employment.

You may not have an outside job, business, financial interest or activity that, because of its size, significance or nature, adversely affects your job performance or that conflicts or appears to conflict with Aks's interests. Get the approval of the CEO, or, in some cases, the Board of Directors, before you get a job outside Aks that pays you money or other consideration.

 

11. Keep confidential information here.

In your daily work, you will receive information about Aks, other companies, or individuals that the public does not know. That information is confidential, and unless the information is public knowledge or is required to be disclosed by law, you must not share the information outside of Aks.  Never use confidential information that you get at work for your personal gain or to give or get an unfair advantage in a personal or competitive business transaction. You may also receive confidential information and data about Aks's business plans, trademarks, new products, revenues, expenses, profits, methods, systems, franchisee lists, employee rosters and/or vendor lists. If so, you have access to a trade secret that is Aks's valuable asset, and that, if you disclosed it outside the company, may harm Aks. For this reason, you may not disclose trade secrets to the public or use them for purposes other than as required in your work at Aks.

 

12. Respect individual dignity.

Be fair and impartial with co-workers and those outside Aks, offering everyone an equal opportunity to achieve their full business potential. Do not discriminate against or harass any fellow employee, franchisee, or any other outside person. You and Aks must never discriminate on the basis of race, color, creed, religion, sex, sexual preference, national origin, disability or any other status recognized by civil rights law. While everyone who works for Aks must comply with these provisions, our executives and supervisors assume a special responsibility for fostering a work environment that is free from discrimination, harassment and the fear or retribution. Supervisors must be careful in words and conduct to avoid placing, or seeming to place, pressure on subordinates that could cause them to deviate from acceptable ethical behavior.

Report immediately and completely to your supervisor, Human Resources any action, word, or practice you believe is discrimination, harassment or retaliation.

 

13. Maintain clear and accurate records.

Maintain complete, clear and dated financial and other records unless you are specifically instructed otherwise. Aks relies on the trustworthiness and professionalism of your accounting, record keeping, and reporting. Never misstate, exaggerate or fabricate files that pertain to Aks's business.

.

OTHER POLICIES

Aks maintains and publishes other policies that supplement many of the obligations in this Policy

SEEKING GUIDANCE/REPORTING A VIOLATION

You are encouraged to talk to your supervisor, if you have when you have questions about this Policy or are in doubt of the best course of action. Additionally, it is your obligation to report suspected violations of laws or this Policy. You will not be retaliated against for any report made in good faith.

 

SANCTIONS

Recognizing that employee ethics violations can mean extensive court costs, lost business and diminished goodwill, Aks will investigate any reported ethical violation promptly and completely. If Aks determines that you violated the Policy, you will be punished in proportion to the severity of your violation, which may include terminating your employment.


IMPLEMENTATION

Aks believes in and adheres to this Policy and requires you to read, use and adhere to the Policy as well. To ensure that you are always aware of the current Policy.

Comments