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Social Responsibility and Corporate Ethics Policy

Social Responsibility and Ethics Policy - Lux Watch Winders

Social Responsibility and Corporate Ethics Policy

Table of Contents

Statement of Corporate Ethics

At Lux Watch Winders , we are committed to conducting our business honestly, transparently, and socially responsible. Our goal is to maintain a high standard of integrity in all our business dealings and interactions. To achieve this, we expect all our employees to comply with the following corporate ethics policy:

  1. Compliance with Applicable Laws and Regulations: All employees must adhere to the applicable laws, regulations, and policies governing our business operations. Violation of these laws or policies will not be tolerated.

  2. Avoidance of Conflicts of Interest: Employees shall not engage in any activity that could influence or appear to influence their objective judgment when dealing with others. This includes avoiding conflicts of interest that could compromise the company's or our customers' best interests.

  3. Illegal and Unethical Actions Prohibited: No employee shall engage in any illegal or unethical actions involving any person or organization that conducts or seeks to conduct business with Lux Watch Winders.

  4. Accurate Records and Documentation: Employees shall maintain complete and accurate books, records, and documentation in accordance with the accounting rules and controls established by the company.

  5. Responsibility of Officers and Directors: Officers are responsible for ensuring that this policy is communicated to staff annually. They must clarify and explain the policies as needed, monitor compliance, and promptly report any known or suspected violations to the President or other designated personnel.

  6. Seeking Guidance in Ethical Dilemmas: Whenever an employee is uncertain about the ethical or legal implications of a particular business conduct, they should seek advice from the President.

  7. Consequences of Non-Compliance: Failure to comply with this policy or any implementing policies may lead to disciplinary action, including termination of employment. Violations of the law will be reported to appropriate law enforcement authorities.

Ethical Business Relationships

To maintain our reputation for ethical conduct in our business relationships, all employees must adhere to the following guidelines:

  1. Avoidance of Conflicting Interests: Employees shall not have any financial interest in any supplier of goods or services to the company unless such interest comprises less than five percent (5%) of the assets of a publicly traded corporation.
  2. No Employment with Suppliers: Employees shall not hold any position (officer, employee, or independent contractor) with any supplier of goods or services to Lux Watch Winders.
  3. Limit on Personal Favors and Gifts: Employees may not accept personal favors, gifts, entertainment, or gratuities from any supplier or potential supplier with a retail price or fair market value exceeding $1100, unless approved by the President.
  4. Non-Exploitation of Information: Employees must not use any information acquired during their employment for personal gain.
  5. Reporting Conflict of Interest: Employees involved in a potential conflict of interest situation must report it immediately to the President.

Whistleblower Policy

Lux Watch Winders encourages reporting any concerns related to actual or suspected violations of this Corporate Ethics Policy or any other company policies or controls. Employees may make reports in person, in writing, by telephone, or by email.

Reports may be made anonymously. To report anonymously by letter, employees should address an envelope marked “CONFIDENTIAL” to any of the designated contacts.

No employee who makes a report in good faith shall face intimidation, harassment, retaliation, discrimination, or adverse employment consequences because of the report.

The President, in conjunction with General Counsel, shall be responsible for investigating and resolving all whistleblower reports. The identity of anonymous whistleblowers shall be protected throughout the investigation process.

Use of and Accounting for Association Funds and Assets

The use of company funds or assets for unlawful or improper purposes is strictly prohibited. Employees involved in handling company finances must:

  1. Maintain Accurate Records: Keep detailed and accurate records of all financial transactions and the disposition of funds and assets.

  2. Internal Controls: Devise and maintain a system of internal controls to ensure transactions are executed with proper authorization, recorded accurately, and asset access is controlled.
  3. Compliance Reviews: Undergo periodic compliance reviews conducted by the Treasurer of the Association or designated personnel.

By following this Corporate Ethics Policy, we ensure that Lux Watch Winders remains committed to the highest ethical standards and fulfills its social responsibility in the marketplace.

[Updated August 27, 2023]