Compliance

Compliance

Steder Group Code of Conduct:
Steder Group and its employees must, at all times, comply with all applicable laws and regulations. Steder Group will not condone the activities of employees who achieve results through violation of the law or unethical business dealings. This includes any payments for illegal acts, indirect contributions, rebates, and bribery. Steder Group does not permit any activity that fails to stand the closest possible public scrutiny.

All business conduct should be well above the minimum standards required by law. Accordingly, employees must ensure that their actions cannot be interpreted as being, in any way, in contravention of the laws and regulations governing Steder Group’s operations.

Employees uncertain about the application or interpretation of any legal requirements should refer the matter to their supervisor, who, if necessary, should seek appropriate legal advice.

General Employee Conduct:
Steder Group expects its employees to conduct themselves in a businesslike manner. Drinking, using drugs, gambling, fighting, swearing, and similar unprofessional activities are strictly prohibited while on the job.

Employees must not engage in sexual harassment, or conduct themselves in a way that could be construed as such, for example, by using inappropriate language, keeping or posting inappropriate materials in their work area, or accessing inappropriate materials on their computer.

Conflicts of Interest:
Steder Group expects that employees will perform their duties conscientiously, honestly, and in accordance with the best interests of Steder Group. Employees must not use their positions or the knowledge gained as a result of their positions for private or personal advantage. Regardless of the circumstances, if employees sense that a course of action they have pursued, or are presently pursuing, or are contemplating pursuing may involve them in a conflict of interest with their employer, they should immediately communicate all the facts to their supervisor.

Anti-bribery:
Steder Group employs good business practices and risk management strategies in accordance with the Business Principles for Countering Bribery. These addresses at least the following areas:

Political contributions
Steder Group, its employees or agents do not make direct or indirect contributions to political parties, organizations or individuals engaged in politics, as a way of obtaining advantage in business transactions. Steder Group accounts for all its political contributions in a separate ledger and consolidate all such payments made by any of the operations that form part of its organization.

Charitable contributions and sponsorships
Steder Group ensures that charitable contributions and sponsorships are not being used as a subterfuge for bribery. Steder Group accounts for all its charitable contributions or sponsorships in a separate ledger and consolidate all such payments made by any of the operations that form part of its organization.

Facilitation payments
Facilitation payments are defined as small payments made to secure or expedite the performance of a routine or necessary action to which the payer of the facilitation payment has legal or other entitlement. Recognizing that facilitation payments are a form of bribery, Steder Group works to identify and eliminate them.

Gifts, Entertainment, and Favors:
Employees must not accept or offer entertainment, gifts, or personal favors that could, in any way, influence, or appear to influence, business decisions in favor of any person or Steder Group with whom or with which Steder Group has, or is likely to have, business dealings. Similarly, employees must not accept any other preferential treatment under these circumstances because their positions with Steder Group might be inclined to, or be perceived to, place them under obligation to return the preferential treatment.

Outside Activities, Employment, and Directorships:
All employees share a serious responsibility for Steder Group’s good public relations, especially at the community level. Their readiness to help with religious, charitable, educational, and civic activities brings credit to Steder Group and is encouraged.

Relationships With Clients and Suppliers:
Employees should avoid investing in or acquiring a financial interest for their own accounts in any business Steder Group that has a contractual relationship with Steder Group, or that provides goods or services, or both, to Steder Group if such investment or interest could influence or create the impression of influencing their decisions in the performance of their duties on behalf of Steder Group.

Kickbacks and Secret Commissions:
Regarding Steder Group’s business activities, employees may not receive payment or compensation of any kind, except as authorized under Steder Group’s business and payroll policies. In particular, Steder Group strictly prohibits the acceptance of kickbacks and secret commissions from suppliers or others.

Any breach of this rule will result in immediate termination and prosecution to the fullest extent of the law and local laws relevant to countering bribery and anticorruption in all the jurisdictions in which it operates, including the UK Bribery Act 2010, U.S. Foreign Corrupt Practices Act (FCPA ) and all other applicable anti-bribery laws.

Steder Group Funds and Other Assets:
Employees who have access to Steder Group funds in any form must follow the prescribed procedures for recording, handling, and protecting money as detailed in Steder Group’s policies and procedures or other explanatory materials, or both. Steder Group imposes strict standards to prevent fraud and dishonesty. If employees become aware of any evidence of fraud and dishonesty, they should immediately advise their supervisor or seek appropriate legal guidance so that Steder Group can promptly investigate further.

When an employee’s position requires spending Steder Group funds or incurring any reimbursable personal expenses, that individual must use good judgment on Steder Group’s behalf to ensure that good value is received for every expenditure.

Steder Group funds and all other assets of Steder Group are purposed for Steder Group only and not for personal benefit. This includes the personal use of Steder Groupal assets, such as computers.

Steder Group Records and Communications:
Accurate and reliable records of many kinds are necessary to meet Steder Group’s legal and financial obligations and to manage the affairs of Steder Group. Steder Group’s books and records must reflect in an accurate and timely manner all business transactions. The employees responsible for accounting and recordkeeping must fully disclose and record all assets, liabilities, or both, and must exercise diligence in enforcing these requirements.

Employees must not make or engage in any false record or communication of any kind, whether internal or external, including but not limited to false expense, attendance, production, financial, or similar reports and statements and false advertising, deceptive marketing practices, or other misleading representations

Dealing With Outside People and Steder Group:
Employees must take care to separate their personal roles from their Steder Group positions when communicating on matters not involving Steder Group business. Employees must not use Steder Group identification, stationery, supplies, and equipment for personal or political matters.

When communicating publicly on matters that involve Steder Group business, employees must not presume to speak for Steder Group on any topic, unless they are certain that the views they express are those of Steder Group, and it is Steder Group’s desire that such views be publicly disseminated.

When dealing with anyone outside Steder Group, including public officials, employees must take care not to compromise the integrity or damage the reputation of either Steder Group, or any outside individual, business, or government body.

Prompt Communications:
In all matters relevant to customers, suppliers, government authorities, the public and others in Steder Group, all employees must make every effort to achieve complete, accurate, and timely communications responding promptly and courteously to all proper requests for information and to all complaints.

Discrimination an Harassment
The diversity of Steder Group employees is a tremendous asset. Steder Group is firmly committed to providing equal opportunity in all aspects of employment and will not tolerate any illegal discrimination or harassment based on race, color, sex, religion, national origin or any other protected class.

Health and Safety
Steder Group strives to provide each employee with a safe and healthy work environment. Each employee has the responsibility for maintaining a safe and healthy workplace for all employees by following environmental, safety, and health rules and practices and by reporting accidents, injuries and unsafe equipment, practices or conditions. Violence and threatening behavior are not permitted.

Environmental
Stteder Group expects its employees to follow all applicable environmental laws and regulations. If you are uncertain about your responsibility or obligation, you should check with your supervisor.

Privacy and Confidentiality:
When handling financial and personal information about customers or others with whom Steder Group has dealings, observe the following principles:
1.
Collect, use, and retain only the personal information necessary for Steder Group’s business. Whenever possible, obtain any relevant information directly from the person concerned. Use only reputable and reliable sources to supplement this information.
2.
Retain information only for as long as necessary or as required by law. Protect the physical security of this information.
3.
Limit internal access to personal information to those with a legitimate business reason for seeking that information. Use only personal information for the purposes for which it was originally obtained. Obtain the consent of the person concerned before externally disclosing any personal information, unless legal process or contractual obligation provides otherwise.

Annual Acknowledgement
To help ensure compliance with this Code Conduct, Steder Group requires that all exempt salaried employees review the Code of Conduct and acknowledge their understanding and adherence in writing on an annual basis.