NVG employees worldwide are expected and directed to comply with all laws and all NVG business conduct policies relating to their NVG business activities. It is also each employee’s responsibility to know and understand legal and policy requirements as they apply to their job, and to notify management when they believe a violation of law or NVG policies/ standards has occurred.
Books & Records The Company’s business records are depended upon to produce reliable and accurate reports to management, shareholders, creditors, governmental entities and others. Thus, all official records of the conduct of the Company’s business must be accurate, honest and complete, without any restriction or qualification of any kind. This means the accuracy of any records involves both factual documentation and ethical evaluation/appraisal. The Company does not condone concealing any payment by means of passing it through the books or accounts of third parties, such as agents or consultants. All NVG operations worldwide must comply with all local and national laws relating to the accurate and complete maintenance of Company financial books and records. As in their other responsibilities, employees are expected to be honest, objective and loyal in the performance of recordkeeping responsibilities. However, because loyalty includes never knowingly being a part of any illegal or unethical activity, there is no excuse for a deliberately false or misleading Company record.
Disclosure Controls Disclosure controls are systems and processes that help ensure that important information is made available to the right people at the right time. The Company requires every area of the business to maintain disclosure controls to provide adequate assurance that significant information is reported to the appropriate levels of the Company – so that the appropriate business steps can be taken to address any issues, and so that the Company can consider whether the information should be disclosed externally.
Internal Controls Internal Controls are systems and processes that combine policies, authorizations and procedures with proper accounting and management tracking. This reporting is designed to ensure that business operations are properly managed. The Company will have in place a set of internal controls that provides reasonable assurance that:
- Transactions are properly authorized and accurately recorded based on Company policies and procedures;
- Company assets are adequately safeguarded;
- Financial and management reporting is reliable and accurate, and reflects actual business activity;
Activities comply with applicable legal requirements; and business operations are effective and efficient. Creating and complying with strong and effective internal control systems is, ultimately, the responsibility of each employee with respect to his/ her areas of operation.
To ensure fairness and integrity in financial markets, we do not trade in NVG securities or those of any other company based on material, non-public information acquired through our employment. Material information is any information that an investor would reasonably consider important in making investment decisions. Examples include knowledge of acquisitions or divestitures, new product launches or financial information. Nonpublic inside information about NVG must not be communicated without a legitimate business reason and proper leadership authorization.
NVG policy is to comply with all applicable laws, rules and regulations relating to lobbying or attempting to influence government officials. Such information provided to governments must be accurate and interactions with government officers must be honest and ethical. All activities that might constitute lobbying or attempts to influence government officials are first reviewed with subsidiary management and/or legal counsel.
Managers and employees of NVG affiliates doing business around the world abide by special laws and regulations which apply to the import and export of products and technical data, as well as the conduct of business with non-U.S. entities. We also comply with anti-boycott and international embargo regulations in all locations where we do business.
The Health, Safety and Environmental (HS&E) policies are derived from principles, values, legal requirements and regulatory requirements. Compliance with the law is a NVG Core Value and it is the single highest priority for the Company’s HS&E programs. The policy is translated into action by standards of performance (Mandatory What’s), standard operating procedures (Mandatory How To’s), and current best approaches (Voluntary System Guidance), and reinforced by mandatory annual internal audits. A regular reassessment of the standards structure promotes continuous evaluation of the system to improve performance. NVG applies a single performance standard to each of its worldwide manufacturing facilities. This is reinforced by training and mandatory annual internal audits. Facilities have flexibility in how they achieve the standard, so that local circumstances can be considered and costs can be controlled. The Company uses internal audit scores and performance against a set of critical measures to assess how effectively sites are implementing the global standard. These measurements are endorsed by Company management and are conducted semi-annually. Overall results are reported to senior management and to the Public Policy Committee of the Board of Directors.
Safety & Health Policy Nass Valley Gateway is committed to having safe and healthy operations around the world to protect the life and health of its employees and the community surrounding its operations, to protect its assets, to ensure business continuity and to engender public trust. It is the responsibility of every employee to understand and be responsible for incorporating safe behavior in daily business activities. Environmental Quality Policy NVG has historically sought, and continues to seek, to achieve clean, safe, incident-free operation at all our worldwide sites. This policy is assured by internally imposed standards of operation applied worldwide, which frequently go beyond the letter and the spirit of those laws and regulations that apply locally. This commitment to responsible operation is implemented by the sites following formal environmental programs supported by professional staff organizations in Legal, Engineering, Human Resources and Product Supply. NVG’s Environmental Quality Policy, which is applicable to all the Company’s worldwide businesses, states that we will continually strive to improve the environmental quality of our products, packaging and operations around the world. To carry out this commitment at our sites and in all our operations, it is NVG’s policy to:
- Ensure our products, packaging and operations are safe for our employees, consumers and the environment.
- Reduce or prevent the environmental impact of our products and packaging in their design, manufacture, distribution, use and disposal whenever possible. We take a leading role in developing innovative, practical solutions to environmental issues related to our products, packaging and processes. We support the sustainable use of resources and actively encourage reuse, recycling and composting. We share experiences and expertise and aid others who may contribute to progress in achieving environmental goals.
- Meet or exceed the requirements of all environmental laws and regulations. We use environmentally sound practices, even in the absence of governmental standards. We cooperate with governments in analyzing environmental issues and developing cost-effective, scientifically based solutions and standards.
- Continually assess our environmental technology and programs and monitor progress toward environmental goals. We develop and use state-of-the-art science and product life cycle assessment, from raw materials through disposal, to assess environmental quality.
- Provide our consumers, customers, employees, communities, public interest groups and others with relevant and appropriate factual information about the environmental quality of NVG products, packaging and operations. We seek to establish and nurture open, honest and timely communications and strive to be responsive to concerns.
- Ensure every employee understands and is responsible and accountable for incorporating environmental quality considerations in daily business activities. We encourage, recognize and reward individual and team leadership efforts to improve environmental quality. We also encourage employees to reflect their commitment to environmental quality outside of work.
- Have operating policies, programs and resources in place to implement our environmental quality policy.
Nass Valley Gateway ensures the safety of our products, packages and operations for our employees, consumers and the environment. We consider this to be a requirement for conducting responsible business, and an essential element of building and maintaining public trust in our products. We carefully evaluate the safety of all products and ingredients before they go to market, using well-established risk assessment methods to understand both hazards and potential exposures. These evaluations are a mandatory part of the company’s product development process, and begin during the early stages of a product’s design. The same safety standards are used everywhere we sell or make products. As a guide, we administer our product safety programs by following these policies and principles:
- The Company’s products and packages will be safe for consumers and the environment when used as intended.
- The Company will seek to ensure that our operations are safe for our employees, neighbors and the environment.
- The Company will meet or exceed all applicable legislative and regulatory requirements with respect to product safety and labeling.
- The Company will provide interested parties with relevant and appropriate factual information about the safety of our products and packaging.
Fair Dealing with Suppliers and Customers
NVG’s success depends on building productive relationships with our suppliers and customers based on integrity, ethical behavior and mutual trust.
Treating Suppliers Appropriately
Our suppliers are valued partners in the success of our business. Our relationships with them must be characterized by honesty and fairness. Suppliers are selected on a competitive basis based on total value, which includes quality, service, technology and price. Terms and conditions defining our relationship with suppliers are communicated early in the supplier selection process and agreements to such terms and conditions, or any acceptable modifications, are reached before work begins. Included in these standard terms and conditions are NVG’s policies regarding payment terms, confidentiality, the use of intellectual property, worker health, safety and labor practices, and environmental requirements.
Supplier Diversity is a fundamental business strategy for NVG. Our consumers, customers and suppliers become more and more diverse every day, so our success depends on our ability to understand diverse consumers’ needs and to work effectively with customers and suppliers around the world. Diversity is the uniqueness that everyone – from suppliers to employees to corporate officers – brings to fulfill NVG’s Purpose, Values and Principles. We will continue to expand and build our Supplier Diversity results.
Treating Customers Appropriately
NVG recognizes that our customers have individual needs and expectations representing unique opportunities for mutual success. The Company treats all customers equitably and does not give any customer an unfair advantage over another competing customer. The Company does not discriminate by customer size, type, channel, or business strategy.
We believe in competing fairly because we all benefit from fair, free and open markets. We compete strictly on the merits of our products and services and make no attempts to restrain or limit trade. Specifically,
- We never discuss such matters as prices, pricing strategies, product or marketing plans, or terms of sale with competitors. Should a prohibited subject come up during a trade association or other meeting, we must leave the meeting and inform our leadership or legal counsel.
- We do not enter agreements with our competitors concerning prices, production volumes, customers or sales territories.
- We do not link purchase of one product to another or compel suppliers to buy from us to retain their NVG business.
- We do not disparage the products or services of a competitor.
- We collect competitive information through proper public or other lawful channels but do not use information that was obtained illegally or improperly by others, including through misrepresentation, invasion of property or privacy, or coercion.
Policies A basic operating principle of the Company is honesty. Neither deceptive advertising nor questionable promotional activity can ever be justified. These are vital tenets of our dedication to consumers and essential to gaining and keeping their continuing loyalty to our brands. NVG observes standards of commercial fairness in devising, using and selecting advertising and promotions, so our products succeed based on their own quality and performance and our reputation as a company, rather than by false or deceptive statements or comparisons.
Confidentiality The Company requires employees to keep the Company’s confidential information confidential. Confidential information means:
- Non-public information known to employees as a result of their position with the Company that might be of use to competitors or harmful to the Company if disclosed; and
NVG is committed to universal human rights, particularly those of employees, communities in which we operate, and parties with whom we do business. To that end, NVG practices and seeks to work with business partners who promote the following standards:
- Equal opportunity for employees at all levels and no discrimination or harassment based on any personal characteristics unrelated to job performance;
- A safe and healthy workplace protecting human health and the environment;
- Working with governments and communities to improve the educational, cultural, economic and social well-being of those communities.