Standards of Business Conduct
As responsible business leaders, it is not enough to intend to do things right, we must also do them in the right way. That means making business decisions and taking appropriate actions that are ethical and in full compliance with legal requirements. Our standards of business conduct are an extension of the company’s values and reflect our continued commitment to ethical business practice.
By following the guidance provided in this document, we acknowledge our individual and collective responsibilities to manage our business activities with integrity as we enable financial industry participants to communicate more effectively.
- We operate with integrity and honesty.
- We have passion for employees, customers, partners and our technology.
- We are open and respectful with others and dedicated to making difficult situations better.
- We are willing to take on big challenges and see them through.
- We are committed to personal excellence and self-improvement.
- We are accountable for commitments, results, and quality to employees, customers and partners.
Our Commitment: Integrity in All Our Interactions
Each day we interact with a variety of individuals and groups in a respectful, ethical manner.
We manage our business in compliance with all applicable laws and regulations.
Regulatory Compliance: We are in compliance with laws and regulations that apply to our business. We are responsible for understanding these laws and regulations as they apply to our jobs and for preventing, detecting, and reporting known instances of non-compliance. There are no circumstances that would allow us to disregard any law or regulatory requirement in the conduct of our business, nor will any be tolerated.
Lobbying: We recognize our responsibility to lobby regarding issues that may affect our business operations, customers and partners. We conduct our lobbying activities in full compliance with the laws and regulations governing these activities.
Political Activities and Contributions: Our employees are encouraged to exercise their right to participate in political activities. Any decision to become involved is entirely personal and voluntary. Employees' political activities are done on their own time and with their own resources.
International Business Activities: While we acknowledge and respect the diverse cultures, customs, and business practices of the international financial marketplace, we comply with the anti-corruption laws of the countries in which the company does business, including the United States Foreign Corrupt Practices Act ("FCPA"). In full compliance with the FCPA, Pattison Sand Company and its agents, partners, and representatives will not make any direct or indirect payments or promises of payment to foreign government officials for the purpose of inducing the individual to misuse his/her position to obtain or retain Pattison Sand Company business.
Anti-Boycott Requirements: We comply with U.S. law that prohibits participation in international boycotts that are not sanctioned by the U.S. government. We build and maintain the trust and respect of our customers, consumers, partners, and shareholders.
Responsible Leadership: We manage our business responsibly in order to maintain the confidence, respect, and trust of our employees, customers and partners. We are committed to acting with integrity, investing in new product development, being responsive and accountable to our customers and partners, and to becoming a leader in the financial industry. We understand the responsibility of becoming a worldwide financial network and accept our unique responsibility to the global investment community.
We build and maintain the trust and respect of our customers, consumers, partners, and shareholders.
Product and Service Quality: Our services are developed and managed to meet the expectations of our customers and partners for high quality and exceptional service. We continually seek new ways to improve our service and responsiveness.
Fair Information Practices: Our business is supported by technologies that manage business and personal information and we treat that information with confidentiality and integrity. We are committed to creating a trustworthy environment and online privacy is at the core of this commitment.
Vendors & Partners: Our vendors and partners will adhere to the highest standards of ethical behavior and legal compliance. Vendors are expected to provide high-quality services while maintaining flexibility and cost-effectiveness. Vendors will, when appropriate, train their employees and representatives to ensure that they are aware of our expectations.
We are responsible stewards in the use, protection, and management of our information and assets.
Financial Integrity: We honestly and accurately record and report business information. We require that financial transactions are executed in accordance with management's authorization and are recorded in a proper manner in order to maintain accountability for the company's assets.
Use and Protection of Assets: We wisely use and protect the assets of the company, and we use these assets exclusively for our business purposes.
Fiscal Responsibility: Our employees exercise good stewardship over company funds.
Use of Information Technology: At all times we will use good judgment and common sense; conduct ourselves ethically, lawfully, and professionally; and strictly follow all authorization protocols while accessing and using company-provided information technology and its contents. In using these company assets and systems, we do not create, access, store, print, solicit, or send any material that is intimidating, harassing, threatening, abusive, sexually explicit, or otherwise offensive or inappropriate, nor do we send any false, derogatory, or malicious communications.
Intellectual Property: We comply with the laws and regulations that govern the rights to and protection of our own and others' copyrights, trademarks, patents, trade secrets, and other forms of intellectual property.
Creation, Retention, and Disposal of Records and Information Assets: We create, retain and dispose of our business records and information assets, both written and electronic, as part of our normal course of business in full compliance with Pattison Sand Company Network policies and guidelines.
Confidential and Proprietary Information: We respect our ethical and legal responsibility to protect confidential and proprietary non-public information and communicate it only as necessary to conduct our business. We will not use this information for our personal advantage and will maintain this confidentiality even after we are no longer employed by the company.
Conflicts of Interest: We are expected to act at all times in the company's best interests and to exercise sound judgment unclouded by personal interests or divided loyalties.
Gifts and Entertainment: Our policies and practices encourage the use of good judgment, discretion and moderation when giving or accepting gifts or entertainment in business settings. Gift giving and entertainment practices may vary in different cultures; however, any gifts and entertainment given or received must be in compliance with law, must not violate the giver's and/or receiver's policies on the matter and be consistent with local custom and practice. We do not solicit gifts, entertainment or favors of any value from persons or firms with which we actually or potentially do business. Nor do we act in a manner that would place any vendor or customer in a position where he/she may feel obligated to make a gift, provide entertainment or provide personal favors in order to do business or continue to do business with us.
Purchasing Decisions and Practices: In our purchasing decisions, negotiations, contract development and contract administration we comply with the applicable laws and regulations that govern those relationships.
We promote a diverse, cooperative, and productive work environment.
Openness, Honesty and Respect: In our relationships with each other, we strive to be open, honest and respectful in sharing our ideas and thoughts, and in receiving input.
Diversity: We promote and support a diverse work force at all levels of the company. It is our belief that creating a work environment that enables us to attract, retain and fully engage diverse talents leads to enhanced innovation and creativity in providing our services.
Equal Employment Opportunity: We promote a cooperative and productive work environment by supporting the cultural and ethnic diversity of its work force. We are committed to providing equal employment opportunity to all qualified employees and applicants. We do not unlawfully discriminate on the basis of race, color, sex, sexual orientation, religion, national origin, marital status, age, disability or veteran status in any personnel practice, including recruitment, hiring, training, promotion and discipline. We take allegations of harassment and unlawful discrimination seriously and address all such concerns that are raised regarding this policy.
Safety and Health: A safe and clean work environment is important to the well-being of our employees. We comply with applicable safety and health regulations and appropriate practices.
We are responsible, caring members of the global community.
Respect for the Environment: We respect the environment and comply with environmental laws and regulations.
Our Responsibilities: We are all accountable and responsible for fully understanding and complying with the company's standards of business conduct, applicable laws, regulations, and all company policies and guidelines that are related to our work. In fulfilling these responsibilities, we all will:
- Read, understand, and comply with the company's standards of business conduct, all applicable laws, regulations, company policies and guidelines that are related to our work.
- Participate in company training and educational programs/events related to our work.
- Obtain guidance from company management in resolving a questionable business practice or compliance issue if uncertain about how to proceed.
- Recognize and report to company management all potential violations of the company's standards of business conduct, policies, guidelines, applicable laws, and regulatory requirements.
- Cooperate fully in any investigation involving company business.
- Make a commitment to conduct the company's business with integrity and in full compliance with all applicable laws and regulatory requirements.
These standards are maintained at all times, and serve as our guideline for all corporate activity.