FERRARA’S ETHICS AND COMPLIANCE PROGRAM
Leading with integrity at Ferrara requires all of our employees to foster a culture of ethical and compliant behavior. Ferrara has established an Office of Ethics and Compliance within our Legal department that will focus on the development and enhancement of our compliance program. The Office of Ethics and Compliance (OEC) provides dedicated support to Ferrara’s leaders and employees. The OEC will also make regular reports regarding compliance matters to our Board of Directors, Chief Executive Officer and other senior-level leaders.
THE CODE OF CONDUCT AND OTHER ETHICAL STANDARDS
Our Code of Conduct provides core guidelines and requirements for ethical behavior and makes clear that Ferrara cannot tolerate illegal or unethical behavior in any aspect of our business. It emphasizes the importance of ethical and honest conduct, adhering to Ferrara’s policies and procedures, treating confidential information appropriately, avoiding conflicts of interest and maintaining Ferrara’s books and records with accuracy and integrity and promotes other ethical conduct and behavior. Further, it requires our employees to report any concerns regarding compliance matters.
In addition to our Code, we have policies and procedures that guide employees as they conduct their day-to-day business activities, such as our Conflict of Interest and Anti-Bribery Policy. These policies and procedures provide guidance regarding relevant laws and regulations, and take into account industry best practices. We regularly update our policies to incorporate changes to the law and best practices.
EMPOWERING YOUR VOICE
It is everyone’s responsibility to speak up. We have established systems and processes for employees and others to ask questions, raise concerns and report suspected violations of our Code, policies and procedures, or laws and regulations, without fear of retribution or retaliation. We offer a number of resources to employees, such as our Ethics and Compliance Helpline that provides telephone- and web-based hotlines available 24 hours a day, seven days a week. You can also contact our OEC at firstname.lastname@example.org.
All good faith allegations are investigated and, if they are substantiated and do comprise a violation, appropriate corrective action will be taken. The OEC will provide regular reports to senior management the Board about concerns reported, the outcome of investigations and any corrective actions taken.
Our OEC looks forward to providing all Ferrara employees with relevant training, enabling each of us to hold ourselves accountable to upholding our company’s integrity. We will partner with various stakeholders on assessment and remediation.
• Training: We will provide training and education programs for employees and other relevant personnel to increase their awareness of our Code and the legal and ethical implications of their actions and behaviors. The OEC will also work with our commercial teams to help them conduct trainings and hold education programs that help ensure compliance and strengthen our Company’s reputation as a responsible corporate citizen while enhancing relationships with customers and other stakeholders.
• Accountability: We expect all employees to adhere to our Code as a condition of their continued employment. Anyone who violates our Code, or any policy or procedure, is subject to appropriate disciplinary action up to and including termination. Any Ferrara employee who fails to report a violation of Ferrara policy or procedure of which he or she is aware may also be subject to disciplinary action.
• No Retaliation: Ferrara has a strict “No Retaliation” policy and will not tolerate retaliation against anyone who makes a good-faith report regarding a violation or potential violation of our Code, policies or procedures, or laws or regulations.
• Assessment: Our OEC will utilize results from internal investigations, internal audits and internal monitoring programs to assess the effectiveness of, and identify areas for improvement in, the compliance program and relevant business practices. In addition, it will consider the external environment, including government investigations, settlements, industry codes and government guidance to identify new opportunities to enhance the compliance program.
• Remediation: Results of investigations, audits and monitoring are communicated to the appropriate business leaders. When an area for improvement is identified, the OEC and relevant stakeholders will partner to implement corrective actions.