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Introduction
United Industrial Corporation (and its direct and indirect subsidiaries) (collectively, the “Company”) is committed to conduct its business in accordance with all applicable laws, rules and regulations and the highest ethical standards. All officers, full and part-time employees (including those on assignment to affiliates) and members of our Board of Directors are expected to be compliant with all laws and regulations, and to conduct business with integrity in relationships with all – customers, suppliers, industry and employee individuals and groups. The obligation of accomplishing the Company’s business in an ethical and proper manner extends to the Company’s agents, representatives, independent contractors, staffing agencies and consultants working on our behalf, and, as appropriate, suppliers and subcontractors. By following the Code of Business Conduct and Ethics, we can ensure that we bring the same high level of excellence to the way we do business that we incorporate into the products and services we provide.
Promote, Prevent, and Protect
AAI’s Code of Business Conduct and Ethics is based on a three-pronged approach: Promote, Prevent and Protect.
Promote: Employees are expected to actively promote a culture of compliance and of the highest ethical standards. Doing the right thing, focusing on the company’s best interests, and encouraging others to do the same are important to achieving our goals.
Prevent: Employees are expected to prevent breaches of applicable laws, rules and regulation, or company policies. Prevention is critical and requires that you understand which actions violate the Code and that you seek guidance in advance any time you are unsure.
Protect: Finally, the company is committed to protect those employees who raise concerns in good faith or report existing or potential violations. AAI’s Code expressly prohibits retribution against any such employee.
Who is responsible to follow the Code?
The Code applies to anyone who works for or acts on behalf of the Company and its subsidiaries. Each person acting on behalf of the Company must make a personal commitment to uphold the standards set forth in the Code. Ethical conduct is now evaluated specifically each year during the job performance review cycle. All employees are required to read the Code and to certify their obligation to comply with its requirements.
Ethical conduct requires:
– asking questions
– seeking guidance
– reporting suspected violations
– expressing concerns regarding compliance and
– completion of required training.
The obligation under the Code to report any known or suspected violations is key because timely reporting can prevent small concerns from escalating into major liabilities for the Company and the people involved.
Who is Responsible to Monitor Compliance with the Code?
The Company has a communication plan to ensure that employees are aware of their individual obligations to further the Company’s commitment to integrate integrity. The communication program will inform employees of company policies and procedures regarding ethical business conduct and assist them in resolving questions and in reporting suspected violations.
The Business Conduct and Ethics Advisory Committee, appointed by the Ethics Officer and approved by the Company’s Audit Committee, is responsible to issue policy guidance and procedures, comprising the standards of conduct required of all Company employees. Managers have the additional responsibility for supporting their implementation and monitoring compliance. The Ethics Officer is responsible for all investigations and to ensure that no retribution is taken against any individual who makes a good-faith report of a violation of the Code.
