The Company’s Books & Records 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 the Company’s financial books and records. As in their other responsibilities, employees are expected to be honest, objective and loyal in the performance of record keeping responsibilities.
NVG policy is to comply with all applicable laws, rules, and regulations relating to lobbying. Such information provided to governments must be accurate, and interactions with government officers must be honest and ethical. All activities that might constitute lobbying are first reviewed with subsidiary management and/or legal counsel.
Nass Valley Gateway ensures the safety of our products, packages, and operations for our employees, consumers and the environment. We consider this 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:
Confidentiality The Company requires employees to keep the Company’s confidential information confidential. Confidential information means:
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 achieving 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 the Public Policy Committee of the Board of Directors. Nass Valley Gateway’s Safety & Health Policy is committed to having safe and healthy operations worldwide to protect the life and health of its employees, the community surrounding its operations, and its assets while also ensuring business continuity and public trust. It is the responsibility of every employee to understand and be responsible for incorporating safe behavior in daily business activities. NVG’s Environmental Quality Policy has historically sought and continues to seek a 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:
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,
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.
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: