Code of Business Conduct

Veriflux conducts its business fairly, impartially, in an ethical and proper manner, and in compliance with all laws and regulations including adherence to the U.S. Anti-Corruption Act and in compliance with all applicable U.S. government sanctions.  We are committed to conducting business with integrity underlying all relationships, including those with customers, suppliers, and among employees.  The highest standards of ethical business conduct are required of our employees in the performance of their responsibilities.  Employees will not engage in conduct or activity that may raise questions as to the company’s honesty, integrity, impartiality or reputation or otherwise cause embarrassment to the company. 

The Veriflux Code of Business Conduct applies to all directors, officers, and employees of Veriflux. 

Compliance with Laws, Rules and Regulations

All employees are required to comply with all laws, rules and regulations that apply to us wherever we do business.   We are committed to lawful conduct, guided by the U.S. Anti-Corruption Act and other relevant legislation.  Our operations and practices are designed to comply with these laws, ensuring we operate with integrity and in full respect of the legal standards set forth by U.S. and international regulations. Employees are expected to use good judgment and common sense in seeking to comply with these laws and to ask for advice when they are uncertain. 

Community and Environmental Responsibility

Our social and environmental responsibilities are taken seriously.  We strive to be a responsible corporate citizen in all aspects of our operations.

Human Rights

Our commitment to human rights is unwavering, recognizing the importance of conducting business in a manner that respects human dignity and rights, as outlined in U.S. law and international human rights standards.

Conflicts of Interest

Each of us has a responsibility to Veriflux, its customers and each other.  In our business dealings we must strive to avoid even the appearance of impropriety. Each of us must avoid any personal or business influences or relationships that affect adversely, or appear to affect adversely, the best interests of Veriflux.

A conflict of interest can generally be described as a situation in which your loyalty is, or may appear to be, divided between self-interest or the interests of a third-party and the interests of Veriflux.  Employees are advised to identify potential conflicts when they arise and notify their manager or Human Resources if they are unsure whether a relationship or transaction poses a conflict. 

Confidential Information

Veriflux employees are required to protect the confidentiality of company related information (i.e. trade secrets, financial or sales records/reports, marketing or business strategies/plans, product development, customer lists, patents, trademarks, or other information not readily available to the public) and any confidential information entrusted to us by actual or prospective suppliers and customers, except when disclosure is approved by an authorized Veriflux manager. Access to this information should be limited to a "need to know" basis and should not be used for personal benefit, disclosed, or released without prior authorization from a supervisor. You must not use Veriflux’s information and communications systems whether alone or in conjunction with any other device to make any unauthorized disclosure or copy of any confidential information belonging to Veriflux. Any employee who has information that leads them to suspect that an employee or competitor is obtaining such information is required to inform their supervisor or Human Resources.

Violations of this policy may result in disciplinary action up to and including termination of employment.

This obligation to safeguard Veriflux’s confidential and nonpublic information applies even after you leave Veriflux as long as the information remains confidential and is not generally available to the public. If you have any questions about whether information is confidential or proprietary, please talk to your manager.

Competition

We are dedicated to ethical, fair and vigorous competition.  Our success depends in part on our ability to offer competitively priced quality products and services.  We comply with applicable antitrust and competition laws and regulations where we do business.  We will make independent pricing and marketing decisions and will not improperly cooperate or coordinate our activities with our competitors to limit or restrict competition.  We will not unfairly disparage or criticize competitors’ products or services.  We will only make honest and factual claims about our products and services.  We recognize the need to understand our competitors.  However, you should not obtain information about our competitors through unlawful or unethical practices.   We will neither offer nor solicit improper payments or gratuities in connection with the purchase of products or services for Veriflux or the sales of our products or services. 

Anti-Corruption and Bribery

We win business and purchase supplies based on the merits and value of products and services and in strict conformance with the laws and regulations of where we do business.  In alignment with the U.S. Anti-Corruption Act, we strictly prohibit any actions that could be construed as corrupt or as bribery.  No employee or business partner may engage in corruption, including offering or accepting bribes, in any form.

Employee Conduct

Veriflux is committed to providing a positive environment for its employees.  Veriflux expects employees to conduct themselves in a professional manner, reflecting positively with staff and customers.  Veriflux expects that employees will maintain the highest degree of integrity and honesty as well as commitment to teamwork and mutual respect. Certain standards are necessary for the efficient operation of the company and for the benefit and protection of the rights and safety of everyone.

Public Disclosure and Communications; Recordkeeping

We will make certain that disclosures made in financial reports and public documents are fair, accurate, timely and understandable.  This obligation applies to all employees.  All corporate records must be true, accurate and complete.  Company records must be promptly and accurately entered in our books in accordance with Veriflux’s and other applicable accounting principles so we may manage our business properly and report our financial results accurately.  None of us may use, authorize or condone the use of “off-the-books” bookkeeping, secret accounts, unrecorded bank accounts, “slush” funds, falsified books, undisclosed side letters or agreements with customers, suppliers, or any other device or procedure that could be used to distort our records, reports or obligations and commitments.

We will retain our records in accordance with law, including the U.S. Anti-Corruption Act.  In addition, we must retain all records, including email and other electronic data that have any bearing on threatened or pending litigation, investigations or administrative proceedings.

Accounting, Auditing or Disclosure Concerns and Fraud Reporting

We have a responsibility to report in good faith matters regarding questionable accounting, auditing or disclosure concerns.  You should promptly report any issues so they may be addressed appropriately.  An employee should raise his or her concern with his/her direct manager, Human Resources, the CFO or the President.

Workplace Policies

EEO and Discrimination. We offer equal opportunity to our employees and applicants without regard to race, color, religion, national or ethnic origin, sex, age, disability, veteran status, marital status, sexual orientation or any other legally protected category.  You may not discriminate or make any employment-related decision based on any of these factors.

Harassment. We do not tolerate sexual harassment of any of our employees.  We also do not tolerate harassment of any employee because of his or her race, color, religion, national or ethnic origin, sex, age, disability, veteran status, citizenship status, marital status, sexual orientation or any other legally protected category.

Protecting Company Assets.  Each employee is responsible for protecting our property, which means you should use our property for legal and ethical activities and in compliance with our policies.  You should protect our property from loss, theft and damage.  We reserve the right to monitor, in accordance with applicable laws, all of our assets, including email, voicemail and contents of other provided media and to review the information on them and to conduct searches or inspections of employees’ personal belongings on our property.

Respectful Workplace. We all deserve to work in an environment where we are treated with dignity and respect. We are committed to creating such an environment because it brings out the full potential in each of us, which, in turn, contributes directly to our business success. 

Disciplinary Action

Violations of this Code of Business Conduct may lead to disciplinary action up to and including suspension either with or without pay, and termination of employment.  Violations may require restitution and/or may lead to civil or criminal action.

Reporting Concerns

This Code of Business Conduct is intended to serve as a guide for your own actions and decisions and those of your co-workers.  If you believe there has been a violation of the policies stated in this Code of Business Conduct, you have an obligation to report your concerns in a timely manner.  There are several reporting options.  You may report via email, in person or phone to your manager.  If you are uncomfortable raising your concern with your manager or your manager is not available, you may contact Human Resources, the CFO or the President.

Any question, report or complaint will be taken seriously.  We will investigate all reported instances, and, where improper behavior is found to have occurred, Veriflux will take appropriate action.

We will not tolerate retaliation against an employee who raises genuine ethics concerns in good faith or assists in an investigation regarding conduct, and Veriflux will take appropriate disciplinary action against anyone who does retaliate or encourages others to do so.  We want you to communicate your concerns and report misconduct without fear of retribution.