EMT CODE

ELECTRICAL MECHANICAL TECHNOLOGIES INC.

CODE OF ETHICS AND BUSINESS CONDUCT 

Message from Eddie Stiles

Our commitment to ethical behaviour and the solid ethical foundations are one of the most essential components of EMT’s operation. We are committed to doing business the right way, based on a culture of ethics and compliance. 

In the long term, we can successfully face the challenges of competitive market environment by accepting the imperatives of moral responsibility, both as individuals and as a company. In performing the job duties, the employees should always act lawfully, ethically and in the best interests of the EMT. 

Thank you for upholding our values and helping us doing things right. It does not only mean that we provide well made, fairly priced and of exceptional quality products and services, but it also means that ethics and integrity is always born in mind. We source material only from suppliers who have impeccable human rights and compliance records, and we ensure that our supply chain is of high integrity and we monitor our entire operation for compliance with our Code.

1. Introduction

 This CODE OF ETHICS AND BUSINESS CONDUCT of EMT serves as our ethical commitment and as a guide to proper business conduct for all of our stakeholders. We, at EMT are committed to doing business legally, ethically and in a transparent manner.

This document applies to all staff who work for the EMT (including officers, directors, managers, team leaders, employees, temporary, agency, interim, sub-contractor or consultant staff), and include other organisations who do business with us.

EMT expects its staff to be impartial and honest in all affairs relating to their job. All staff bear a responsibility in general, to be of good faith and do nothing to destroy the trust necessary for employment.

The success of our business is based on the trust we earn from our employees, customers and shareholders. We gain credibility by adhering to our commitment to fairness and reaching our goals solely through ethical conduct. All staff are expected to adhere to this Code in their professional, as well as personal conduct, treat everyone with respect, honesty and fairness.

EMT is open to any questions at any time and will not allow punishment or retaliation against anyone for reporting a misconduct in good faith.

Managers and leaders have higher responsibility for demonstrating, also through their actions, the importance of this Code. Managers and leaders are responsible for promptly addressing every raised ethical question or concern. Employees must cooperate in investigations of potential or alleged misconduct. 

Non-compliance to this Code considered as a misconduct that could warrant disciplinary action, including termination of employment or other contract in deserving cases.

We are committed to making efforts to apply our values and norms also throughout the entire value chain of our own suppliers, sub-contractors, service providers and business partners.

2. Ethical Values

Our core values are:

• Honesty

• Integrity

• Trustworthiness

• Respect for Others

• Responsibility for our actions

• Accountability

• Reliability

• Obedience of the Law

3. Ethical Decision-making

Ethical conduct is a value-driven decision-making. Several key questions can help to identify situations that may be unethical, inappropriate or illegal. Ask yourself: 

Is what I am doing legal? ● Does it reflect our company values and ethics? ● Does it comply with the Code and company rules/policies? ● Does it respect the rights of others? ● How would it look if it made the news headlines? ● Am I being loyal to my family, my company and myself? ● Is this the right thing to do? ● What would I tell my child to do? ● Have I been asked to misrepresent information or deviate from normal procedure?

4.  Compliance with laws and regulations

Our commitment to integrity begins with complying with laws, rules and regulations. We understand and comply with the legal requirements and commercial practices of lawful business.

We are committed to adhere to every valid and binding contractual agreement that we conclude, and we do not abuse our rights.

Our staff must follow applicable laws and regulations, always including the Code and must ensure compliant operation.

5. Sustainability: People + Profit + Planet

We are committed to meet current requirements without compromising the needs of future generations. To this, we combine economic, environmental and social factors in our operation and our business decisions. 

6. Human rights

We are committed to respect human dignity and rights of each individual and community whom we interact with during work. We shall not, in any way, cause or contribute to the violation of human rights. Our staff shall treat everybody with dignity, respect and care and uphold human rights.

7. Fair labour practices and working conditions

We are committed to promote equality in our employment practices and to fair employment and remuneration policy in compliance with applicable laws. We are firmly opposed to employ or contract child or slave labour or any form of forced or compulsory or bonded labour. We condemn all forms of illegal, unfair, unethical labour practice that exploits workforce, destroys social security or serves as tax evasion, including but not limited to undeclared and “grey” work or holding back wages.

Our staff shall act with integrity and treat their colleagues and others through the work with full respect.

8. Discrimination and harassment

We provide equal opportunity in employment, and we do not tolerate any discrimination or harassment or any type from abuse. No direct or indirect discrimination shall take place based on any professionally non-relevant trait or circumstance, like gender, marital status, age, national or social or ethnic origin, colour, religion and political opinion, disability, sexual orientation, employee representation, property, birth or other status. Any kind of discriminatory behaviour, harassment, bullying or victimization is prohibited. 

All staff is expected to follow the highest standards of conduct in all verbal and written communication based on mutual respect, and must refrain from any form of harassment, slander or any behaviour that could be taken as offensive, intimidating, humiliating, malicious or insulting.

9. Health, Safety and Environment

We provide clean, safe and healthy work conditions and we are dedicated to maintaining a healthy environment. We are committed to minimise the impact on the natural environment of our operations. We make efforts to reduce the use of finite resources, like energy or water, and the harmful emissions, like waste.

All staff must follow and comply with every relevant health, safety and environmental protection laws, regulations and rules all times.

10. Fair competition and business conduct 

Our relationships with business partners are built upon trust and mutual benefits compliant with competition law. We are dedicated to ethical and fair competition, as we sell products and services based on their quality, functionality and competitive pricing. We will make independent pricing and marketing decisions and will not improperly cooperate or coordinate our activities with our competitors. We will not offer or solicit improper payments or gratuities, nor will we engage or assist in unlawful boycotts of customers. We commit to comply with all applicable trade controls, restrictions, sanctions and import-export embargos.

We do not allow any violence of the fairness of any tendering process in any way. We refrain from damaging competition and the reputation of any business partners and any behaviour that harms competitor’s creditability. 

We do not hold back maliciously, unlawfully or unduly payments towards our partners, and we do not allow such practices in our supply chain, we fight the unethical practice of “debt chain”.

Our staff is responsible for ensuring fair business during their job and adhere to every competition, consumer protection and fair marketing rule. Customers and business partners shall be treated fairly and equally, products and services shall be displayed in a manner that is fair and accurate (fair marketing and advertising), and that discloses all relevant information.

11. Anti-corruption 

We firmly condemn and do not tolerate all forms of corruption. It is prohibited directly or indirectly offering, promising, giving, asking, soliciting or accepting any unfair advantage or benefit, in order to obtain, retain or facilitate in any way the business. An unfair advantage or benefit may include cash, any cash equivalent (e.g. voucher), gift, credit, discount, travel, personal advantage, accommodation or services. We do not permit facilitation (or “grease”) payments to government officials or private business in order to secure or speed up routine actions. Corruption also covers the misuse of function or position as well, when someone makes that false appearance that s/he improperly influences a decision maker. 

Corruption for either to obtain or retain business, or to obtain or retain an advantage in the conduct of business is considered gross misconduct. Similarly accepting or allowing another person to accept a bribe is considered gross misconduct. Our staff has to account for all benefits received in the course of doing business and must to not give or receive bribes or otherwise act corruptly.

12. Gifts and Hospitality

We shall avoid any actions that create a perception that favourable treatment was sought, received or given in exchange for personal benefits.

Business courtesies or benefits include gifts, gratuities, meals, refreshments, entertainment or other advantage from persons or companies with whom we do or may do business. We will neither give nor accept such benefits that constitute, or could reasonably be perceived as constituting, unfair business inducements that would violate law, regulation or polices, or would cause embarrassment. Our staff may never use personal funds or resources to do something that cannot be done with our resources.

We may accept and offer occasional gifts and hospitality that are customary and conform to reasonable ethical practices of the market, if they are not inappropriately excessive, not frequent and do not reflect a pattern of frequent acceptance, does not create the appearance of an attempt to influence business decisions. Only trivial gifts with low value can be accepted. All other gifts must be politely refused or, if received through post, returned to the donor. If return is not possible it shall be offered for charity or community purposes. It is the responsibility of the person offering, providing, receiving or accepting the gift to decide whether the gift is appropriate.

13. Security, protection and proper use of company assets

We are responsible for the security, protection and for the economic use of company resources. Our resources, including time, material, equipment and information are provided for legitimate business use only. Occasional personal use is permissible as long as it is lawful, does not affect job performance or disrupts workplace morale.

All staff is obliged to follow appropriate security measures, and they should treat company property, whether material or intangible, with respect and shouldn’t misuse company assets or use it carelessly.

14. Confidentiality, information security, proprietary information and intellectual property

We are committed to business information confidentiality, integrity and accessibility, we implement proper technical security measures this and it is our staff’s obligation to uphold this. Proprietary information includes all non-public information that might be harmful to the company or its customers, business partners if disclosed to unauthorised parties. All staff must handle any such information as secret. It also covers that, no one is entitled to trade with securities while in possession of non-public information or deliver non-public information to others that could have impact on the securities. Every rule ensuring information security must be followed all times. 

We respect the property rights of others. We will not acquire or seek to acquire trade secrets or other proprietary or confidential information by improper means. We will not engage in unauthorized use, copying, distribution or alteration of software or other protected intellectual property.

15. Bookkeeping, true reporting and financial integrity

Our books, records, accounts and financial statements must be maintained in appropriate detail, must truly and properly reflect our transactions. We condemn all forms of money laundering, so we are committed to do business with partners involved in legitimate business activities with funds derived from legitimate sources. 

We commit ourselves to fair taxation and to avoid all tax evasion practices, including such as failing to issue receipt or accounting fake expense invoices.

All staff must follow accounting procedures, ensure that business transactions are recorded and documented appropriately and make certain that all disclosures made in financial reports are full, honest, accurate, timely and understandable. All staff must not improperly influence, manipulate or mislead any audit.

16. Anti-Fraud

Fraud – the act or intent to cheat, steal, deceive or lie – is both unethical and, in most cases, criminal. Fraud in every form, (including e.g. submitting false expense reports; forging or altering financial documents or certifications; misappropriating assets or misusing company property; making any untrue financial or non-financial entry on records or statements) is prohibited.

17. Conflict of Interests

Our decisions shall be based on objective and fair assessments avoiding the possibility of any improper influence. A "conflict of interest" exists when an employee's personal interest (that can be linked to e.g. friends, family, or customer, competitor, supplier, contractor entity, as well) interferes or potentially interferes with the best interests of EMT Determining whether a conflict of interest exists is not always easy to do, thus anyone with a conflict-of-interest question should seek advice from management.

Conflicts of interest could arise:

• Being employed (you or a close family member) by or being in economic relation with an actual or potential customer, competitor, supplier or contractor.

• Hiring or supervising family members or closely related persons.

• Serving as a board member for another company or organization.

• Owning or having a substantial interest in a customer, competitor, supplier or contractor.

• Having a personal interest, financial interest or potential personal gain in any company transaction.

If co-workers become involved in personal relations with each other, the onus is on the senior employee concerned to bring this to the attention of his or her manager to confirm that there is no conflict of interest, nor will a conflict of interest arise.

18. Privacy, personal data protection

We respect people’s privacy, and we acknowledge customers, employees and other natural persons’ need to feel confident that their personal data is processed appropriately and for a legitimate business purpose. We are committed to comply with all personal data protection laws. We only acquire and keep personal information that is necessary, and we give proper information on these activities to data owners. We implement proper security measures to assure confidentiality, integrity and availability of personal information.

Our staff must observe the legal requirements, apply compliant practices and follow related procedures to ensure legality of personal data handling and processing activities.

Electrical Mechanical Technologies Emergancy action plan

I.             Policy

It is the policy of this company to take every possible action to comply with all emergency regulations and protect employees in emergency situations.

II.           Emergency Plan Coordinator

Gary Winner is responsible for making sure this emergency action plan is kept up to date, practiced, and reviewed periodically.

The Emergency Plan Coordinator can be reached at Main Office 423/472-8539.

III.         Reporting Procedures

List the types of emergencies that could occur at your workplace and how employees should report them. Options include internal telephone numbers, intercom, public address systems, etc. Employees must also notify external emergency responders if the company uses them for help in emergencies.

  Type of emergency

 How to report

   Fire

 Direct to main office

   Explosion

 Direct to main office

   Weather

 Direct to main office

   Chemical spill/leak

 Work area supervisor then to Main office

   Violence

 Work area supervisor then to Main office

   Medical

 Work area supervisor then to Main office

   Other (list)

Reporting procedures are posted Main office hallway.

IV.        Evacuation Procedures

A. Emergency Escape Procedures and Routes

Emergency escape procedures and route assignments have been posted in each work area, and all employees have been trained by supervision in the correct procedures to follow. New employees are trained when assigned to a work area. A sample escape procedure and escape route sheet of the type posted in work areas is included with this plan.

B. Procedure for Employees Who Remain to Operate Critical Operations Before They Evacuate

During some emergency situations, it will be necessary for some specifically assigned and properly trained employees to remain in work areas that are being evacuated long enough to perform critical operations. These assignments are necessary to ensure proper emergency control.

The following lists these employees and their duties:

  Name

 Title

 Work area

 Special assignment

   N. Marr

 Supervisor

 Fab Shop

 Fire control

   A Buhl

 Supervisor

 Machine Shop

 Fire control

   R Boland

 Supervisor

 Lazer Shop

 Fire control

   Ed Stiles

 VP

 Office

 Fire control

The preceding individuals have received special instructions and training by their immediate supervisors to ensure their safety in carrying out the designated assignments. A training record describing the instructions provided and the detailed procedures to be followed is maintained in the Emergency Plan Coordinator's office.

C. Employee Accountability Procedures after Evacuations

Each supervisor is responsible for accounting for all assigned employees, personally or through a designee, by having all such employees report to a predetermined designated rally point and conducting a head count. Each assigned employee must be accounted for by name. All supervisors are required to report their head count (by name) to the Emergency Evacuation Coordinator. A summary of the evacuation rally points, together with the identities of supervisors and assigned employees who must report to each, is included with this plan.

D. Alarm System

Describe the alarm system to be used to notify employees (including disabled employees) to evacuate and/or take other actions. The alarms used for different actions should be distinctive and might include horn blasts, sirens, or even public address systems.

Alarm systems for notifying all employees in case of an emergency are:

  Action to be taken

 Alarm system

   P A System

(OSHA Standard 29 CFR 1910.165, Employee Alarm Systems, provides guidance on emergency alarms.)

E. Sheltering in Place

Certain emergencies require employees not to evacuate, but to move to an interior, windowless room. Describe procedures for sheltering-in-place emergencies at your workplace.

  Proceed to Machine shop

F. Training

The following personnel have been trained to assist in the safe and orderly emergency evacuation of other employees.

  Name

 Title

 Work area

 Special assignment

   N Marr

 Supervisor

 Fab Shop

   A Buhl

 Supervisor

 Machine Shop

   R Boland

 Supervisor

 Lazer Shop

   Ed Stiles

 VP

 Office

Training is provided for employees:

1.   When the plan is initiated

2.   When responsibilities change

3.   When new employees are hired or transferred

4.   At least annually

V.          Fire Extinguishers

  Supervisor trained how and When to use Fire Extinguishers

Periodically inspect the ones in their area.

VI.        Employee Accountability Procedures Following an Emergency Evacuation

Each supervisor is responsible for accounting for each assigned employee following an emergency evacuation. The following apply:

1.   Rally points have been established for all evacuation routes and procedures. These points are designated on each posted work area escape route.

2.   All work area supervisors and employees must report to their designated rally points immediately following an evacuation.

3.   Each employee is responsible for reporting to his or her supervisor so that an accurate head count can be made. Supervisors will check off the names of all those reporting and will report those not checked off as missing to the Emergency Evacuation Coordinator.

4.   The Emergency Evacuation Coordinator will be located at one of the following locations:

a.   

Primary location: Lazer shop exit

b.   

Secondary location: Weld shop exit

5.   The Emergency Evacuation Coordinator will determine the method to locate missing personnel in each situation.

VII.       Rescue and Medical Duties

It may become necessary in an emergency to rescue personnel and perform some specified medical duties, including first-aid treatment. All employees assigned to perform such duties will have been properly trained and equipped to carry out their assigned responsibilities properly and safely.

Most small businesses rely on local resources such as hospitals or fire departments to provide rescue and medical services. Where that is the case, list those resources. If employees have such duties, include a list of these individuals and the training they have received.

  Name

 Location assignment

 Special assignment

 Training provided

   Local EMS

Injury and Accident Response and Reporting

If an employee is injured or witnesses an injury at work, they must report it immediately to the nearest available manager. Employees should render any assistance requested by that manager. When any accident, injury, or illness occurs while an employee is at work, regardless of the nature or severity, the employee must complete an injury reporting form and return it to Human Resources as soon as possible. Reporting should not be allowed to delay necessary medical attention. Once the accident is reported, follow-up will be handled by Human Resources or the designated safety officer, including a determination as to whether the injured employee may return to work.

Questions asked by law enforcement or fire officials making an investigative report should be answered giving only factual information and without speculation. Liability for personal injury or property damage should never be admitted in answering an investigatory question asked by law enforcement or fire officials.

In addition to compliance with safety measures imposed by the federal Occupational Safety and Health Act (OSHA) and state law, the Company has an independent interest in making its facilities a safe and healthy place to work. The Company recognizes that employees may be able to notice dangerous conditions and practices and therefore encourages employees to report such conditions, as well as non-functioning or hazardous equipment, immediately to a manager. Appropriate remedial measures will be taken when possible and appropriate. Employees will not be retaliated or discriminated against for reporting accidents, injuries, or illnesses, filing safety-related complaints, or requesting to see injury and illness logs.