OF THE WATERGROUP INC. / WATERGROUP CANADA INC.CODE
OF BUSINESS CONDUCT
Inc./WaterGroup Canada Inc. Code of Business Conduct ("Code")
sets forth in detail our firm commitment to professional and
ethical business conduct. The Code describes the behavior that
WaterGroup Inc./WaterGroup Canada Inc. and its subsidiaries
in the United States and Canada expect from our employees and
third parties (such as consultants and vendors) who represent
Code includes discussions of the following expectations with
respect to business conduct:
commitment to integrity and high ethical standards must never
be compromised in order to obtain a short-term advantage.
are expected to report improper behavior they observe in the
workplace to designated Company officials and to participate
in internal investigations of misconduct. (See further discussion
at the end of this document.) To the extent possible, confidentiality
will be maintained.
are not to retaliate against anyone who in good faith reports
workplace misconduct or participates in an internal investigation.
Employees engaging in improper workplace conduct (including
retaliation) will be subject to discipline, up to and including
immediate termination of employment.
The workplace must be free of all forms of illegal discrimination
and harassment and accepting of a diverse workforce. Immediately
report improper harassment or discrimination in accordance with
the Companys established procedures. We comply with the
laws governing child labor and the right of employees to unionize.
Health and Safety
Each employee has active responsibility for maintaining
a safe and healthy workplace for all employees. Violence and
the use of illegal drugs in the workplace will not be tolerated.
Employees must be vigilant in ensuring our compliance with
the environmental laws applicable to our companies.
Commitments to Customers
We will provide products and services that meet the needs
of our customers and comply with applicable laws, such as those
pertaining to consumer protection, safety standards, and food
and drug manufacturing.
Use of Property
The property of WaterGroup Inc./WaterGroup Canada Inc. and
our clients and vendors must not be misused or used for the
personal benefit of an employee. For example, it is improper
to make or install unlicensed copies of computer software.
Employees must be careful not to engage in unfair competitive
practices, such as price fixing with competitors, improper disparagement
of competitors, and industrial espionage.
Proprietary, confidential, and classified information of
WaterGroup Inc./WaterGroup Canada Inc. and our clients and vendors
must be safeguarded in order to protect its value. Such information
must not be disclosed by an employee after leaving employment
with the Company.
An employee's use of material, non-public ("inside")
information about WaterGroup Inc./WaterGroup Canada Inc., or
any of their affiliates for the financial benefit of employee
or any other person is illegal. It is equally unlawful for an
employee to use for personal benefit any inside information
about unrelated companies obtained in the course of employment.
Similarly, an employee may not provide such information to outside
persons who do not have a legitimate need to know the information
of Consultants, Vendors, Government Employees, and Lawyers
The Company will employ only reputable, qualified individuals
or firms as agents, representatives, consultants, and vendors.
We will not use such individuals or firms to engage in business
activities that violate our standards of business conduct or
applicable laws and regulations. All vendor and consulting arrangements
involving contingent or success fees, lobbying, or business
development, and all agreements involving the retention or employment
of a person who also is or will be an employee or official of
any government or agency thereof, are subject to special approval
requirements. No lawyers may be employed or retained by the
Company without the prior approval of the WaterGroup Inc./WaterGroup
Canada Inc. Legal Department.
Employees must select subcontractors and suppliers on the
basis of objective criteria, such as quality, technical excellence,
cost, and service, and not on the basis of improper factors,
such as kickbacks or inappropriate gifts. Treat vendors with
respect and fairness.
When dealing with government representatives and agencies,
employees must be truthful and accurate in all statements they
make. Except as provided in the Code, requests for information
from the government about our Company must be referred to the
WaterGroup Inc./WaterGroup Canada Inc. Legal Department for
Inquiries from the media, such as newspaper reporters, should
be responded to only by the Companys professionals designated
to handle such matters.
Contributions and Political Activities
Political contributions may be made by the Company only
to the extent permitted by law and only in accordance with the
policies and procedures of WaterGroup Inc./WaterGroup Canada
Inc. Employees will not be reimbursed for any political contributions
they made. Employees engaged in political action or community
service must exercise caution to do so on their own behalf and
on their own time, and not on behalf of the Company.
Lobbying activities on behalf of WaterGroup Inc./WaterGroup
Canada Inc. may be engaged in only to the extent permitted by
law and only in accordance with the policies and procedures
of WaterGroup Inc./WaterGroup Canada Inc..
summary, we expect all employees and third parties to conduct
their business dealings in accordance with the letter and spirit
of all laws and to refrain from any form of illegal or unethical
employees are encouraged to discuss workplace problems or suspected
misconduct with their supervisors. If an employee feels uncomfortable
discussing a matter with his or her supervisor, the employee
should discuss the matter with the next level of management.
an employee is reluctant to speak with any of the above persons,
believes his or her concerns are not being adequately addressed,
or is not sure whom to call about a particular issue, the employee
should feel free to contact his or her business centers
Human Resources or Legal Department.
August 1, 2004
© 2004 WaterGroup Inc./WaterGroup Canada Inc.
All rights reserved