Code of Ethics - Sustainability

Ethics

Code of Ethics

Bathco has long been dedicated to abiding by local laws wherever we operate and conducting all business activities with the highest ethical standards. Our main objective is to be a flexible, lean and focused business partner.

We are committed to ecological sustainability, good corporate citizenship and the health and safety of our employees, contractors and customers. At Bathco, we always conduct our business with a highly dedicated and proactive approach. We are aware of and embrace our responsibility towards the environment, the community and each individual’s health. In today’s business environment, we believe upholding this commitment is critical for our continued success as a global leader in our industry.

Our Code of Ethics has been adopted by the Bathco Board of Directors and summarizes the standards that guide our actions. These standards represent the official Bathco company policy and establish conditions for employment. While this Code does not and cannot cover every situation where decisions must be made, it is important that we establish an ethical mindset that guides our actions in the most sustainable way for all stakeholders. Our reputation and integrity depend upon each employee assuming a personal responsibility for their business conduct.

Our Standards
At Bathco, we try to set the highest ethical standards and follow them daily. We believe that sustainability through cooperation results in reliable, fair and trustworthy relationships with all its stakeholders.

Mission, quality, privacy and the environment
At Bathco, we are always aware of our responsibility towards the environment, the community and each individual’s health. Due to the fact that each employee at Bathco is responsible for their own behavior, we expect that while performing job duties, every individual is responsible for ensuring that they conduct themselves in a manner that not only reflects the high standards of the company, but also strengthens them.

Each Bathco employee has a number of personal responsibilities as a condition of their employment with Bathco. These responsibilities include:

  1. Always achieve the greatest possible result under the given conditions
  2. Respect every individual
  3. Respect the environment in the most sustainable way
  4. Comply with all applicable laws and regulations
  5. Comply with all applicable company policies
  6. Maintain the highest ethical behavior
  7. Report any suspected misconduct, illegal activity, fraud, abuse of company assets or other violation of ethical standards

Employees
Bathco believes providing equal opportunities for all in our employment practices. This includes recruiting, compensation, professional development and promotion. Our formal position is to treat all employees and prospective employees with dignity. We believe in respecting human rights, providing safe and healthy working conditions and respecting employees’ rights to bargain collectively. Corporately, we recognize that integrating the unique attributes and talents of our diverse work force contributes to our overall work output, providing better and more creative solutions.

It is our expectation that our employees will speak out if they observe or have knowledge of an ethical lapse. We do not want others to ask our employees to do anything against our policies and standards. Accordingly, we will also never ask anyone else to do anything against our policies and standards. These values extend throughout all divisions of our company.

Customers, Suppliers & Partners
Bathco will always strive to provide high quality products, superior services and innovative solutions. Our employees should always address our partners in a straightforward and honest manner.

Bathco’s obligations are for the long term. These obligations demand that we adhere to the highest professional and personal ethics. We build on our history of integrity so that people will have an abiding trust in our company and our employees. This provides assurances that they can count on us.

Families
Our families should be able to be proud of the work we do. They should be proud that we are employed by a company that is known for its honesty and integrity worldwide. Additionally, we strive for a healthy work- and family-life balance.

Communities
Bathco should be known as a company that communities are able to count on for help in civic, charitable and other community activities. We strive to improve the overall quality of life wherever we operate. We will use resources responsibly and act to preserve the environment.

Promoting a Positive Work Environment & Equal Opportunity
Employees want and deserve a workplace where they feel respected and appreciated. Our policies are designed to ensure that employees are treated fairly and with respect both by the company and by each other. Bathco will hire, evaluate, transfer, compensate and promote employees based on skills and performance alone.

Harassment-Free Workplace
Bathco attempts to create a positive workplace environment and does not tolerate workplace harassment. Harassment may occur when the words, actions or behavior of members of the work group create an intimidating, hostile or offensive work environment. Unwelcome sexual advances or other inappropriate personal conduct are prohibited. Sexual harassment may take many forms, including but not limited to, overt advances to demeaning comments, jokes, language and gestures.

Bathco will not tolerate abusive language, physical violence or the threat of physical violence. Our employees are expected to cooperate fully in the company’s investigation of complaints. Retaliation against anyone who lodges a complaint in good faith will not be tolerated.

Safety and Health
Bathco is committed to providing a safe and healthy work environment. As part of this commitment, Bathco has developed standard for the environment, health and safety. These standards are available for all to review on our website.

There are extensive local and national laws designed to promote a safe workplace and these laws are strictly enforced. Extensive and continuous training and regular safety audits are essential for understanding and complying with safety laws.

Firearms and other weapons are strictly prohibited on company property or on the person of an employee while conducting company business. Company property includes developed and undeveloped company-owned or controlled land, buildings, parking lots, vehicles, areas of embarkment, disembarkment and recreation. Local management, with the concurrence of the management board, is authorized to grant exceptions for special circumstances.

Environment
We are committed to promoting environmental stewardship around the world. As a good corporate citizen, Bathco has a policy dedicated to the environment, health and safety, which is available on our website for anyone to view.

Employees must understand and comply with the environmental laws and regulations that affect our business activities, as well as related company and operating unit policies and procedures. We also insist that contractors, suppliers and others who work with us follow the appropriate laws and regulations.

Substance Abuse
It is the policy of Bathco to maintain a safe, healthful and productive work environment for all employees. To that end, the company will act to eliminate substance abuse as it increases the potential for accidents, absenteeism, substandard performance, poor employee morale or damage to the company’s reputation. As a condition of continued employment with the company, employees must comply with all applicable substance abuse policies, guidelines or procedures.

Building and Maintaining Relationships

Conflicts of Interest
Bathco respects the rights of employees to manage their personal affairs and investments and does not wish to intrude upon their personal lives. At the same time, employees should avoid any situation that may involve a conflict between their personal interests and the interests of the company. As in all other facets of their duties, employees dealings with customers, suppliers, contractors, competitors or any person doing or seeking to do business with the company must be in the best interest of the company to the exclusion of consideration of personal preference or advantage.

A “conflict of interest” occurs when our private interests interfere, in any way, with the interests of the company. A conflict can arise if we take on outside work or make financial investments that make it difficult for us to perform our work at Bathco objectively and effectively. A conflict also can occur if an employee or a member of their family receive personal benefits as a result of the employee’s position in the company. It is equally important to avoid apparent conflicts of interest – where a reasonable observer might assume there is a conflict of interest, and therefore a loss of objectivity in their dealings on behalf of Bathco.

Actions that might involve a conflict of interest, or the appearance of one, should be fully disclosed in writing to the employee’s management for review and approval as soon as the conflict occurs. Employees who knowingly fail to disclose conflicts are subject to discipline, including dismissal.

Soliciting Suppliers, Contractors or Local Merchants
Bathco employees should not request donations from suppliers, contractors or local merchants to help pay for employee social functions or sporting events. The one exception where donations are allowed is for companywide, sanctioned, charitable events. Solicitations of cash, merchandise or services are not allowed because they could be perceived to create obligations in order to keep, increase or obtain Bathco business.

We want our vendors and suppliers to understand that their business relationship with Bathco is based totally on their ability to competitively meet our business needs.

Business Courtesies and Inducements

Gifts, Favors and Entertainment
Business gifts and entertainment are customary courtesies designed to build goodwill among business partners. These courtesies include items of nominal value such as meals and beverages, tickets to sporting or cultural events, and other merchandise or services. In some cultures business gifts play an important role in business relationships. However, a problem may arise when such courtesies compromise – or appear to compromise – our ability to make objective and fair business decisions.

Receiving Gifts, Favors and Entertainment
Bathco employees should neither seek nor accept for themselves or others any gifts, favors or entertainment without a legitimate business purpose, nor seek or accept loans (other than conventional loans at market rates from lending institutions) from any person or business organization that does or seeks to do business with, or is a competitor of, the company. In application of this policy:

  1. Employees may accept for themselves and members of their families common courtesies usually associated with customary business practices.
  2. An especially strict standard is expected with respect to gifts, services, discounts, entertainment or considerations of any kind from suppliers.
  3. It is never permissible to accept a gift in cash or cash equivalents (e.g. stocks or other forms of marketable securities) of any amount.

In certain situations, refusal of gifts with a value substantially in excess of customary business practices can result in awkward business situations. The propriety of employees keeping such valuable gifts for personal use versus turning them over to the company, donating them to a charity or other disposition should be discussed in each case with the employee’s management. Disposition of such a gift should be documented, regardless of whether it is retained, returned or given to charity.

Giving Gifts, Favors and Entertainment
Gifts, favors and entertainment may be given others at company expense only if they meet all the following criteria:

  1. Consistent with customary business practices.
  2. Not excessive in value and cannot be construed as a bribe or payoff.
  3. Not in violation of applicable law or ethical standards.
  4. Public disclosure of the facts will not embarrass the company nor the employee.

Accounting records and supporting documentation reflecting gifts, favors and entertainment to others must be accurately stated, including appropriate, clear, descriptive text. Departments or organizations are encouraged to establish policies and procedures for approval in advance of gifts, favors or entertainment of unusual monetary value.

In case of doubt as to the legality of any gift, favor or entertainment proposed to be given by or on behalf of the company, Bathco Ethics Management should be consulted in advance of commitment.

Bribes and Kickbacks
It is unacceptable to directly or indirectly offer, pay, solicit or accept bribes or kickbacks in any form.

Commissions, Rebates, Discounts, Credits and Allowances
Sales-related commissions, rebates, discounts, credits and allowances are customary business inducements, but careful attention is needed to avoid illegal or unethical payments and to ensure compliance with various currency exchange controls and tax regulations. Such business-inducement payments must be reasonable in value, competitively justified, properly documented and made to the business entity to whom the original sales agreement or invoice was made or issued. They should not be made to individual officers, employees or agents of that entity or to a related business entity. They should be made only in the country of that entity’s place of business.

Commissions, rebates, credits, discounts or allowances that are paid or granted by the company in conformity with standard trade terms for the industry, catalog prices or other standard procedures are deemed to have been established in writing and need not be documented further.

Fees and Honorariums
With management approval, employees are allowed to serve as a director of another company, give lectures, conduct seminars or publish articles and books. Any fees, honorariums or reimbursements must be transferred to the company unless written management approval is given to retain them. A copy of the management approval will be filed in the employee’s personnel file.

Obeying the Law
Bathco policy is to comply with all applicable laws and regulations. As our employees conduct business, they may encounter a variety of legal issues, particularly in the areas described below. The company holds information and training sessions to promote compliance with laws, rules and regulations. If you have questions on specific laws or regulations, contact Bathco Legal department (legal@bathco.ch).

Competitive Intelligence and Customer/Supplier Information
Competitive information is a valuable tool that allows us to understand and manage our markets, products and services so we can better meet our customers’ needs. However, employees are expected to gather and use that information in an ethical manner and in compliance with the law.

Prohibited, of course, are theft, illegal entry, black market purchases, blackmail, electronic eavesdropping, threats and other improper methods. Employees of competitors or suppliers should not be asked to reveal proprietary information. Our employees should likewise never divulge proprietary information about their former employers, and we will not ask them to do so.

Similarly, the records that we maintain on our customers are confidential and therefore protected accordingly. The information that we have on our customers should only be used for Bathco’s business purposes. This information should not be released without proper authorization and for legitimate business reasons.

Any proprietary or non-public information about our competitors or suppliers should not be used if you suspect it has been obtained improperly or misdirected to you in error (such as misdirected faxes or bid information).

International Business Laws
We expect all employees to comply with the laws of the countries in which we operate.

Responsibility
Each employee has a personal responsibility to abide by this Code. Violations of this Code may result in disciplinary action in accordance with Bathco’s policies. Such disciplinary action may include reprimand, reimbursement of any loss or damage suffered by Bathco, termination of employment/services, referral for civil action or criminal prosecution, or any other disciplinary action deemed appropriate by the company, in each case, in accordance with applicable laws.

Waivers of the Code
Waivers of provisions of the Code with regard to the Bathco Board of Directors may be granted by the Ethics Management. Any waiver, including Bathco’s failure to take action within a reasonable period of time regarding a material departure from a provision of the Code, will be publicly disclosed by the company as required by law. Senior Officers should note that it is not Bathco’s intention to grant or to permit waivers from the requirements of the Code except for good reason.

Questions
We will be glad to answer any questions related to compliance or our Code of Ethics. Please contact us directly using the information provided below.

Reports
Please advise us of any unethical conduct or irregularity regarding our Code of Ethics. Ethics Management will maintain strict confidentiality concerning all reports and related information, and can also ensure anonymity at your request.

Ethics Management

Phone: + 41 44 586 30 51
E-Mail: ethics@bathco.ch

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