ETHICS AND COMPLIANCE
ETHICS AND COMPLIANCE
Holistic Lock ’s commitment to operational excellence begins with our commitment to ethical excellence. Holistic Lock personnel across the United States, and around the world, are committed to the highest standards of ethics, transparency, and accountability. In addition to being fully compliant with all applicable laws and regulations, we raise the bar in setting our own standard of conduct in relation to our customers, suppliers, competitors, and co-workers.
CODE OF ETHICS AND BUSINESS CONDUCT
Improper activities, or even the appearance of impropriety, can jeopardize the mission. No employee, on behalf of Holistic Lock , shall engage in conduct that violates federal law or is inconsistent with the highest levels of honesty and integrity. For more information regarding Holistic Lock ’s Ethics policies, please refer to the Code of Business Ethics and Conduct Guidebook below: Download Code of Ethics.
RISK MANAGEMENT
Holistic Lock considers risk management to be an integral part of all business operations and functions and is committed to embedding risk management into existing practices and procedures. Risk management is part of Holistic Lock ’s culture, not an independent activity. The company’s Enterprise Risk Management Policy was designed to establish a rigorous reporting process to facilitate better-informed management decision-making, transparency, and resource allocation. Identifying, mitigating, and reviewing risks are the responsibility of every Holistic Lock employee.
ETHICAL FRAMEWORK
Like many core functions at Holistic Lock , the structure of the ethics program is designed to have continuous monitoring as well as periodic reviews involving key stakeholders.
The Board of Managers maintains oversight of the company’s ethics program. The day-to-day management of the program is delegated to Holistic Lock ’s Ethics Officer, Megan Pearson. The Ethics Officer works closely with the Deputy Ethics Officer, the Risk Officer, the Legal Department, and Human Resources as needed. The team takes a proactive approach to make sure that Holistic Lock employees have access to the resources they need when facing an ethical dilemma. Each quarter, the primary stakeholders meet to review the ethics agenda, including:
- Review of allegations of violations of the company’s Code of Ethics and Business Conduct;
- New laws or regulations as they relate to the company’s Ethics Program; and
- Any company policy changes recommended as a result of the Ethics Program review.
The functional areas included in this review are Legal, Compliance, Human Resources, and Operations. The Ethics Officer meets annually with the member of the company’s Board of Managers who has the role of Ethics & Anti-Corruption oversight. Additionally, the Ethics Officer provides Ethics program updates on a quarterly basis to this Board member. The responsibility of the Board member with Ethics and Anti-Corruption oversight entails:
- Reviewing the company’s Ethics program;
- Recommending and/or reviewing proposed changes or enhancements to related company policy; and
- Setting the agenda for the following year.
ETHICS TRAINING
It is the intent of Holistic Lock to ensure ethics awareness is continually addressed and integrated into day-to-day business. Formal ethics training is provided to all employees on an annual basis, at a minimum, to include but not limited to:
- Code of Business Ethics and Conduct Review
- Bribery and Illegal Gratuities
- Collusive Bidding
- Export Controls
- Truth in Negotiations Act
- False Statements and Claims, Lobbying Restrictions
- Foreign Corrupt Practices Act
- Kickbacks
- Harassment
- Procurement Integrity Act
- Conflicts of Interest
- Economic Espionage Act
- Human Trafficking
Holistic Lock regularly provides training to its employees in all regions in which the company operates. Holistic Lock maintains a 100% completion rate for this training.