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Litens Automotive Group
Code of Conduct and Ethics

 
Statement of Purpose

This Code of Conduct and Ethics sets forth the basic principles we are committed to with respect to our dealings with all our stakeholders and also acts as a guide to assist our employees in meeting the ethical standards reflected in the Code. The Senior Management of Litens Automotive Group (“Litens”) has adopted this Code of Conduct and Ethics to highlight our commitment to a company culture rooted in fairness, integrity, honesty and concern for people.

Scope of Application

This Code applies to all our employees and officers on a global basis and will be promptly and consistently enforced.  Failure to comply will lead to disciplinary action, proportionate to the breach. Our consultants, independent contractors, agents and other representatives will be required to meet the same ethical standards as our employees.  All employees and officers are expected to be familiar with the code and to adhere to those principles and procedures set forth that may apply to them.

Conducting Business within Appropriate Laws with Integrity, Fairness and Respect

We believe in complying with both the letter and spirit of applicable laws, rules and regulations in the jurisdictions in which we conduct business. Our employees will not engage in unfair or illegal trade practices or violate the laws of the jurisdictions in which we conduct business.

We firmly believe in conducting business with integrity, honesty and fairness, in all countries where we compete. Our employees will respect and act in a manner sensitive to the cultures and customs of the countries in which we operate as well as the communities and environment where we conduct business.

Our employees will not, directly or indirectly, offer bribes, kickbacks, or other similar payments, nor promise any other improper benefit for the purpose of influencing any customer, supplier, public official or any other person, nor will they, directly or indirectly, accept bribes, kickbacks or any other improper benefit which could influence or appear to influence them in the performance of their duties, provided that any payments which are permissible under applicable law are not prohibited under this Code. Reasonable business entertainment and gifts or favours of nominal value or those which are appropriate in the circumstances will not be considered a breach of our commitment to fair dealing, as long as such entertainment or gifts are consistent with business practice, not intended as an inducement, not contrary to applicable law and will not embarrass us or our employees if disclosed publicly.

All employees and officers shall conduct their private and personal activities in a manner that does not conflict with the business interests of Litens.

Human Rights and Workplace Practices

We support and respect the protection of international proclaimed human rights within our sphere of influence and will ensure that we are not complicit to human rights abuses.

We foster a work environment that is free from discrimination, harassment, intimidation and hostility of any kind.

We practice the principle of equal employment opportunity without regard to race, religion, age, gender, disability, sexual orientation, nationality or political affiliation.

We encourage all our employees to take responsibility for their work, to be flexible and open minded, to find enjoyment and satisfaction in their work, and to be proud of Litens.

We will not tolerate any form of forced, compulsory or child labor in our sphere of influence.

 Environment, Health and Safety

We are committed to work with our employees and business partners in order to create and maintain a safe and healthy working environment that meets or exceeds industry standards and regulations in all jurisdictions in which we perform business activities.

We will conduct our business in an environmentally responsible manner in accordance with the appropriate legislation and regulations in each of the jurisdictions we operate and strive to meet or surpass the environmental performance requirements of international standards governed by ISO 14001.

We support avoiding materials and methods posing environmental and health risks when alternatives are available and we will work to minimize the impact of our operations on the environments in which we operate.

Financial Reporting

We will maintain financial, accounting and business records that fully and fairly reflect all the transactions and business in which we engage, in accordance with applicable accounting principles, policies and practices.

No employee or anyone acting on the instruction of any employee will take any action to violate our financial reporting policies or to circumvent our system or internal controls. Our employees will carry out transactions in accordance with the direction provided by Litens Financial Management, Accounting Policies and Procedures manual.

Use of Confidential Information

We expect our employees to treat as confidential all trade secrets and proprietary information relating to us and our customers and suppliers. We also expect that our employees prevent misuse or improper disclosure of confidential information relating to other employees.

Corporate Policies

In addition to the corporate policies referred to in this Code, we maintain a variety of policies and procedures governing various matters, and we expect our employees to abide by them.

Responsibility of Managers and Employees

It is the responsibility of Litens Automotive Group Managers / Officers to communicate and demonstrate the content as well as the spirit of this document within their organizations. Reports of violation of this Code may be done anonymously and confidentially to Litens General Counsel for the Partnership for investigation and appropriate action. Reports can be lodged in any of the business languages used at Litens locations across the world. In addition to E-mails and phone messages, prepaid / addressed envelopes available at all Litens locations can be used.

Litens General Counsel for the Partnership, Alex Porat
Phone: 905 850-4851
Email: actionresponseline@litens.com
Address: 730 Rowntree Dairy Road., Woodbridge, ON., CANADA L4L 5T7

Litens General Counsel for the Partnership will not disclose the identity of the person(s) reporting suspected misconduct unless the individual(s) consents to disclose or required by law. The individual(s) will not be discriminated against because of lawful acts in furtherance of this policy.

This Code of Conduct has been approved and adopted by Senior Management and can only be amended or waived by the same. Any amendments or waivers shall be disclosed.

 

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