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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.

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.

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.

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

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.

Fair Competition

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.  

Advertising/Promotion

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.