Ethics Policy

OUR CREED
We believe in the free enterprise system. We shall consistently treat our customers, employees, shareholders, suppliers and the community with honesty, dignity, fairness and respect. We will conduct our business with the highest ethical standards.

Reporting of Risks
TC GROUP (herein and after, TC GROUP refers to TC Group and all companies whose ultimate parent company is TC Group) is committed to providing quality products and services that meet or exceed the expectations of our customers. Deficiencies that put the financial security of our company at risk or, more importantly, threaten the physical well-being of any person, should be reported immediately to management. Deficiencies may involve product quality, safety, design, installation or maintenance.

Promoting Health and Safety
The health and safety of TC GROUP’ employees throughout the world is of utmost importance. Our work processes and policies are designed to minimize risk. We all must routinely review and improve workplace conditions to ensure a safe and healthful workplace and report unsafe working conditions to supervisors and management anywhere in the world.

Equal Opportunity and Diversity
We value and respect the diversity of our employees, suppliers, customers and communities. Our company is committed to providing equal opportunity in all of our employment and purchasing practices. Only in valuing diversity and committing to equal opportunity practices will we be able to fully utilize the human and business resources available to us in our pursuit of customer satisfaction. At the same time, we believe that by valuing diversity we enable all to fully realize their potential.
We are committed to providing a workplace that is free of harassment or any other behavior that diminishes a person’s integrity and self esteem. Harassment, in any form or degree, will not be tolerated.
The use of child labor or forced labor is strictly prohibited.

Protecting the Environment
We respect the needs and concerns of the communities in which we live and work. This is exemplified in the company’s long tradition of caring about the quality of the environment. Our products, services and manufacturing methods reflect this concern and our belief that what is good for the environment is good for TC GROUP. Sound waste management and source reduction practices, recycling and energy conservation are legal, ethical, and business requirements.

Protecting the Company’s Information
Protecting information about TC GROUP’ products, activities, performance or plans is critical to our company’s competitive position and reputation. Good judgment is needed to determine what information can or cannot be disclosed to others. Should there be any question as to whether certain information is confidential, employees should consult their supervisor. To limit the potential for important information being used improperly, employees should use “need to know” guidelines even with other TC GROUP employees.
The use of confidential company information for the personal gain of an employee or anyone else is contrary to TC GROUP policies and, in many cases unlawful. Buying or selling TC GROUP stock on the basis of material nonpublic information is prohibited. It is also unlawful to communicate this information to other persons who may trade in our stock. Material information is defined as anything a prudent investor should know before investing in a company. This type of information includes, but is not limited to, financial results, new products and acquisition plans that have not already been disclosed to the public.

Avoiding Conflicts of Interest
The best interests of TC GROUP are expected to be foremost in the minds of our employees as they perform their duties. When we become employees of the company, and receive pay and benefits, we make this commitment.
It is wrong to seek any other economic gain by virtue of being a TC GROUP employee. Giving or receiving anything of enough value to influence sound business judgment is prohibited. This also applies to family, friends and business associates. In addition, discussions of future employment with government officials with whom TC GROUP seeks to do business must be approved in advance.
TC GROUP trusts its employees with information about company activities and with company funds and property. Use of any of these in a way that conflicts with company interests is strictly prohibited. Situations or arrangements which may conflict with company interests must be approved in advance by the employee’s respective business group General Manager.
We must also take care that our actions cannot be perceived as serving other interests. While mutually beneficial relationships with customers and suppliers are encouraged, we should avoid situations that offer the potential for problems. Examples include having a significant stake in, or serving as a director of, a firm that sells to or purchases from TC GROUP. Employees should also not work for a customer or a supplier. All these examples apply to involvement with our competitors as well.

Proper Use of Company Funds
Employees are personally accountable for any form of company funds such as credit cards, tickets, cash and checks. Those who authorize the use of funds must ensure that the company has received proper value in return. TC GROUP may be obligated to notify appropriate civil authorities should funds be used for any improper or illegal purpose and will take appropriate disciplinary action in any event.
Proper Use of Company Information and Company Property
TC GROUP trusts its employees with information about company activities and with company property. Use of these in a way that conflicts with company interests, or in any manner that may reasonably be considered offensive or disruptive to another employee, is strictly prohibited.

Suppliers and Partners
TC GROUP values its suppliers and partners. Only Suppliers and Partners that live up to Social Responsibilities standards, including not using child of forced labour, promotes equal opportunity, prohibits discrimination and inhumane treatment, refuses to employ or make anyone work against his/her will, pays decent wages, have decent working hours shall be used, and recognize – to the extent legally possible – the right of free association of employees. Further, TC GROUP shall only use Suppliers and Partners who provide a safe and hygienic working environment, follows the environmental law in their respective countries and make an effort to continuously reduce their environmental impact, have plans in place for dealing with occupational injuries and illness, as well as unexpected accidents and disasters. TC GROUP shall only work with Suppliers and Partners who comply with local laws, tolerate no forms of bribery or corruption, and comply with the principles of non-discrimination with regard to supplier selection and treatment.

Appropriate Use of E-Mail, Internet and Other Computing Resources
Electronic commerce, electronic mail, and other Internet-related systems are intended to be used for company business. Additionally, all information on company computer systems, including electronic mail, is the property of TC GROUP. Therefore, to ensure that computing resources are used in accordance with expectations, management may inspect and disclose the contents of electronic messages if such inspection and disclosure is made for legitimate business purposes or as necessary to protect the rights and property of TC GROUP.
The company is careful to ensure that all employees, customers, suppliers, and the public in general, are treated with dignity and respect. Use of computing resources to offend or harass others is prohibited. Employees who use the Internet to access sites that contain offensive materials related to sex, race, or other protected categories, or who otherwise violate these prohibitions, will be subject to discharge.

Integrity of Recordkeeping/Accounting
TC GROUP documents a wide range of its activities. The integrity of these records is relied upon to make important business decisions and take actions. Therefore, it is essential that all records are accurate and complete. This responsibility prohibits false or misleading entries regarding both the amount or purpose of transactions. Some examples include vouchers, bills, financial data, expense reports and performance records.

Political/Governmental and Non-Governmental Contributions
Within the U.S., no contribution of funds or services are to be made to, or on behalf of, any political organization or candidate by TC GROUP or any of our subsidiary companies without advance approval by the Law Department. Within the U.S., offering anything of value, directly or indirectly, to government officials in connection with their government duties is prohibited and includes gifts or other things of value offered to their family members. Throughout the world, direct or indirect contributions to any government officials (including their representatives or family members) that are intended to gain preferential treatment for our company are always prohibited.
TC GROUP recognizes that in some countries outside the U.S. it is legal and customary for companies to make certain contributions to political parties and government officials. Nevertheless, no such contributions or payments can be made by TC GROUP or its subsidiaries, employees or agents with the intent to obtain or retain business. In addition, contributions or payments must be approved by the Law Department and must be completely and accurately documented in our company’s books and records.

Rule of Law
Any employee involved in court or other similar proceedings arising out of his or her employment with TC GROUP shall abide by the rules of that forum, cooperate with the orders of that forum, and not in any way commit perjury or obstruction of justice.

Defense Security
TC GROUP and some of its businesses have Top Secret security clearances. Strict care must be taken to comply with the laws on the protection and disclosure of classified information relating to such businesses. All visits to certain hostile countries, or meetings with their officials anywhere, must be formally reported to the Law Department.

Antitrust
Planning or acting together with any competitor to fix prices or to agree about the nature, extent or means of competition in any market is against company policy and in violation of antitrust laws. Antitrust laws may also in some circumstances prohibit agreements to boycott, to allocate products, territories, or markets, and to limit the production or sale of products. Using illegal or unethical means to obtain competitive information or gain a competitive advantage over a competitor is prohibited.

International Business
There are several laws which restrict where we can do business, what information or products we can supply to certain countries and what information we can provide to a foreign government (e.g., boycott-related requests or U.S. national security concerns). For these reasons, business entry into any new foreign country must be in compliance with these restrictions.

Responsibilities
Each employee of TC GROUP is expected to carry out his or her work in accordance with the business standards of conduct of TC GROUP. Further, all employees are urged to direct any questions or concerns about the company’s activities or these standards to their supervisors or the divisional or corporate human resources departments without delay. Any employee who suspects that a violation of the Ethics Policy has occurred is obligated to report it, and such employees shall be protected from retaliation.
This Ethics Policy supersedes all previous Ethics Policies, Employees should also be aware that these standards are greater than those that may be required by local law. Adherence to these standards is a condition of employment with TC GROUP. Violations are serious matters and will result in disciplinary action. Managers and supervisors are responsible for distributing copies of the Ethics Policy to employees and for making them aware of the importance and specific requirements of the policy.

The Ethics Policy is not all-encompassing, and questions about situations not discussed in the Ethics Policy should be addressed to the CEO of TC Group.