Code of Ethics
Commitment to Ethical Behavior
Our continuous pledge to maintain exceptional corporate performance starts with our vow to always operate in an ethical manner. In addition to elevating our own standard of ethical conduct within our group, we are also devoted to exhibiting peak levels of transparency and accountability while operating within the international business arena.
Wherever we are around the globe, we always strive to be fully compliant with all codes, regulations, and laws that dictate ethical standards of corporate behavior.
Code of Corporate Conduct
Inappropriate conduct, real or perceived, can place both organizational and client goals at risk. Therefore, EHD Group, and any partner, subsidiary, agent or affiliate thereof, will always operate in a manner demonstrating honesty and integrity. We take a proactive approach regarding the establishment and oversight of a strong ethical framework within which we operate by conducting periodic reviews of our internal ethics and anti-corruption programs. With such a regard for ethical corporate conduct, we continuously commit the resources necessary to face any and all ethical dilemmas. No matter what the cost, we will always comply with all applicable laws that are now standard in global business ethics, including, but not limited to, the United States Foreign Corrupt Practices Act (FCPA), as amended.
Ethics Education & Training
EHD Group strives to maintain a formal corporate ethics education and training program designed to fully integrate a strong sense of corporate responsibility into our day-to-day business operations. In all the worldwide markets in which we operate, we provide thorough and comprehensive ethics education and training to all our subsidiaries, partners, employees, agents and/or affiliates at a minimum annual basis. Anti-corruption topics addressed with our education and training programs include, but are not limited to, bribery, lobbying restrictions, conflicts of interest, economic espionage, corporate security, money laundering and the implications of national security on business activities.
Environmental Protection
EHD Group recognizes a shared responsibility to protect our planet. We realize our facilities and operations can have a large ecological footprint. Therefore, we are committed to reducing the environmental impact of our business through preservation, conservation, and waste reduction practices.
Conflict Gemstones & Minerals Policy Statement
EHD Group (EHD) and its subsidiaries, joint ventures, partners and affiliate companies (collectively, “we”, “us” or “our”) are committed to complying with the Conflict Minerals Rule (“the Rule”) issued by the U.S. Securities and Exchange Commission (“SEC”) under Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act . We acknowledge, and share the concern that conflict minerals originating in the Democratic Republic of the Congo and its adjoining countries (collectively, the “Covered Countries”) may be helping finance armed conflict in these regions. In accordance with the Rule, we are working with our direct suppliers to ensure the responsible sourcing of “conflict minerals” – the ores of tin, tantalum, tungsten and gold – through our global supply chains. EHD is a holding company owning or doing business with subsidiaries, joint ventures, and/or affiliate companies that engage in a number of diverse business activities with varying levels of complexity in their supply chains. Subsidiaries are managed on a decentralized basis. Therefore, EHD provides guidance to subsidiaries, joint ventures and/or affiliate companies on their conflict minerals compliance programs and subsidiaries, joint ventures, and/or affiliate companies implement their programs independently, in a manner that is best suited to their specific industry and circumstances, but within guidelines provided by EHD. EHD’s subsidiaries, joint ventures and/or affiliate companies may operate directly with ore extraction and smelting activities. The global supply chain for conflict minerals is complex and includes multiple tiers of activity from mines, smelters and refiners. Therefore, we are relying on information provided by our subsidiaries, joint ventures, and/or affiliate companies to support our responsible sourcing efforts, and for compliance with the Rule. We expect our subsidiaries, joint ventures, affiliate companies, and/or suppliers to respond to our conflict minerals inquiries in a timely manner and provide us with required information on the source and use of conflict minerals in the products supplied to us. As part of our conflict minerals efforts, we engage relevant suppliers in our global supply chain, conduct due diligence activities by leveraging the Organization of Economic Co-operation and Development Due Diligence Framework, and file a conflict minerals disclosure annually as required by the SEC. EHD is committed to ongoing improvement of our responsible sourcing efforts and the traceability of our global supply chains. For questions or concerns related to our conflict minerals initiatives, suppliers and other external stakeholders may contact us by email at inquiries@ehdholdings.com.
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