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CODE OF CONDUCT

 

Bethyl Laboratories, Inc. (Bethyl) maintains a Code of Conduct to guide its employees aligning with our corporate values:

 

Bethyl is committed to preserving the integrity of the Company through our responsibilities to each other, and to our customers, suppliers, and governments.  Bethyl is committed to adhering to laws and regulations with integrity and honesty in all countries where business is conducted.

 

BUSINESS AND FINANCIAL RECORDS

Bethyl ensures the accuracy of the Company’s business and financial records including accounting, quality, production, and personnel.  Employees will have access to various Company resources depending on their role with the organization. The use of these assets for any unlawful or improper purpose is prohibited. Employees should protect assets from misuse, theft and loss.

Payments made on behalf of Bethyl must include adequate supporting documentations and must be approved with the understanding that the proceeds will only be used for the purpose described in the supporting documentation for the payment.

 

PROPRIETARY INFORMATION

Bethyl does not allow the distribution of proprietary information to outside sources, agencies, individuals, etc.  Proprietary information may be viewed only after the outside source has been approved by Executive Management, and a mutual Confidential Information non-disclosure agreement has been fully executed. Proprietary information includes but is not limited to:

 

CONFLICT OF INTEREST

Bethyl prohibits conducting business when a conflict of interest exists. We prohibit all forms of gifts from customers and suppliers where it compromises, or appears to compromise, the Company’s ability to make objective business decisions. 

 

ANTI-BRIBERY

Bethyl strictly prohibits directly or indirectly offering, paying or accepting bribes of any kind, for any purpose. Bribes can be anything of value, including cash, gifts, charitable contributions and entertainment.

 

Prohibition of Improper Payments

Kickbacks or bribes intended to induce or reward favorable buying decisions and governmental actions are unacceptable and prohibited.

No employee of Bethyl or anyone acting on Bethyl’s behalf shall, in violation of any applicable law, offer or make directly or indirectly through any other person or firm any payment of anything of value (in the form of compensation, gift, contribution or otherwise).

 

Political Contributions

Bethyl will not make contributions to any political party or candidate for political office in support of such candidacy except as permitted by law.

This Policy is not intended to prevent the communication of Bethyl’s views to legislators, governmental agencies, or to the general public with respect to existing or proposed legislation or governmental policies or practices affecting business operations.

 

UNITED STATES LABOR LAWS

Equal Employment Opportunity and Anti-Discrimination

Bethyl provides an equal employment opportunity for all applicants and employees. Bethyl does not permit discrimination or retaliation on the basis of age, sex (including pregnancy, childbirth or related medical conditions), color, race, national origin, religion, disability, genetic information, military service or status, citizenship status, filing a charge of discrimination, participating in an investigation or opposing discriminatory practices, or any other category protected by federal, state or local law. Bethyl provides an equal employment opportunity in all aspects of employment, including recruitment, hiring, training and development, promotion, transfer, demotion, termination, reduction in force, compensation, benefits and all other terms, conditions and privileges of employment in accordance with applicable federal, state and local laws. Slavery and human trafficking are not tolerated at Bethyl or knowingly with other businesses associated with Bethyl including suppliers, distributor and collaborators.

 

Child Labor Laws

Bethyl complies with the federal child labor provisions, authorized by the Fair Labor Standards Act (FLSA) of 1938, also known as the child labor laws, enacted to ensure that when young people work, the work is safe and does not jeopardize their health, well-being or educational opportunities.

 

ANTITRUST LAWS

U.S. antitrust laws promote business competition and prevent activities among competitors that could unfairly control a market and harm consumers. The laws achieve this objective by prohibiting unseasonal and unfair restraints of trade in the United States and elsewhere. Bethyl complies with the antitrust laws including the Sherman Act 1890, the Clayton Act 1914 and the Federal Trade Commission Act 1914.  Employees are prohibited from collusion including

 

Reports and Periodic Reviews

  1. Any employee who is requested to engage in any activity which is or may be contrary to this Policy will promptly report such information to the manager whom the individual reports, or to a member of the executive team, if the employee was so directed by the manager, then to assigned Company legal counsel.
  2. Any employee who acquires information that gives the employee reason to believe that any other employee is engaged in conduct forbidden by the Policy will promptly report such information to the manager to whom the employee reports or, if the manager is engaged in such conduct, then to Bethyl’s HR Department or Executive of the company.

 

Reporting Violations

Any employee who is requested to make, authorize, or agree to any offer or payment which is, or may be, contrary to this Policy will promptly report such to a member of the executive team.