CODE OF BUSINESS CONDUCT AND ETHICS
Bulwark Coffee Company is committed to the highest standards of business conduct and ethics. This Code of Business Conduct and Ethics (“Code”) reflects the business practices and principles in support of this commitment. All employees are expected to read and understand the Code and its application to their work.
Officers, managers, and other supervisors are expected to promote a sense of commitment to the spirit and letter of the Code and all employees are expected to implement and uphold Bulwark Coffee Company’s legal and ethical standards in the performance of their duties. Managers are also expected to ensure that all vendors conform to standards when working for or on behalf of Bulwark Coffee Company.
The Code addresses conduct that is particularly important to proper dealings with the people and entities with whom we, as Bulwark Coffee Company employees, interact, including our co-workers, customers and third parties such as contractors, vendors, partners, suppliers, and members of our community.
As an employee, conduct by members of your immediate family, significant others or other persons who live in your household may potentially result in ethical issues for you as a Bulwark Coffee Company employee. For example, acceptance of inappropriate gifts by a family member, significant other, or other persons who live in your household from one of our suppliers could create a conflict of interest and result in a Code violation attributable to you. Consequently, in complying with the Code, you need to consider not only your own conduct, but also that of your immediate family members, significant others, and other persons who live in your household.
Bulwark Coffee Company will conduct its business honestly and ethically wherever we operate. All employees should act with integrity and honesty in all matters and follow all applicable laws. Any employee who becomes aware of any departure from the standards in this Code has a responsibility to report his or her knowledge promptly to a manager, Human Resources, or the Legal Department. If you have any questions about your own conduct that may potentially conflict with this Code, you are encouraged to discuss the matter with your manager or Bulwark Coffee Company’s Human Resources or Legal departments.
This Code is not a contract of employment and does not alter your “at-will” employment relationship with Bulwark Coffee Company. Nothing in the Code is intended to, and should not be construed to, inhibit, or restrict any rights protected by Section 7 of the National Labor Relations Act. Bulwark Coffee Company reserves the right to change, modify or amend the Code from time to time.
Whoever walks in integrity walks securely, but whoever takes crooked paths will be found out. -Proverbs 10:9
Our organization’s character is merely a reflection of our individual character within the organization. By acting with integrity and respect, we reflect positively on our values and reputation. Acting with integrity includes, but is not limited to, how we deal with each other, our competitors and our company records, assets, and information.
As a Bulwark Coffee Company employee, you are critical to our success, and we will treat you with integrity and respect. Bulwark Coffee Company is an equal opportunity employer and does not tolerate discrimination against applicants or employees based on race, color, creed, religion, gender, age, marital status, national origin, sexual orientation, citizenship status, disability, genetic information, uniform service, veteran status, or any other category protected under federal, state, or local laws. We prohibit discrimination in decisions concerning recruitment, hiring, compensation, benefits, training, termination, promotions, or any other condition of employment or career development. Simply put, we prioritize equality over equity. Not just because that is the law, but because that is congruent with the character and integrity of our organization and its employees. We are committed to providing a work environment free from discrimination or harassment and will not tolerate discriminatory slurs, unwelcome, unsolicited sexual advances or harassment, or any other remarks, jokes or conduct that creates or fosters an offensive or hostile work environment. Employees at all levels of the organization must act with respect and civility towards co-workers, customers and third parties. We expect our employees to abide by and comply with all Bulwark Coffee Company policies and with all federal, state, and local laws.
We expect our suppliers and customers to treat our employees with respect and will not tolerate discrimination or harassment, discriminatory slurs, unwelcomed, unsolicited sexual advances or harassment, or any other remarks, jokes or conduct which promote a hostile work environment for our employees. Employees should report any improper conduct by suppliers or customers to their manager immediately.
We strive to outperform our competition fairly and honestly. Advantages over our competitors need to be obtained through superior performance of our products and services, not through unethical or illegal business practices. Acquiring proprietary information from others through improper means, possessing trade secret information that was improperly obtained, or inducing improper disclosure of confidential information from past or present employees of other companies is prohibited, even if motivated by an intention to advance our interests. If information is obtained by mistake that may constitute a trade secret or other confidential information of another business, or if you have any questions about the legality of proposed information gathering, please talk with your manager or member of the Legal Department.
You are expected to deal fairly with Bulwark customers, suppliers, employees, and anyone else with whom you have contact in the course of performing your job. No employee may take unfair advantage of anyone through misuse of confidential information, misrepresentation of material facts or any other unfair dealing practice.
Employees involved in procurement have a special responsibility to adhere to principles of fair competition in the purchase of products and services by selecting suppliers based exclusively on normal commercial considerations, such as quality, cost, availability, service and reputation, and not on the receipt of special favors.
The integrity of Bulwark Coffee Company records depends on the validity, accuracy and completeness of the information supporting the entries to our books of account. Therefore, corporate and business records should be completed accurately and honestly. The making of false or misleading entries, whether they relate to financial results or test results, is strictly prohibited. Bulwark Coffee Company records serve as a basis for managing our business and are important in meeting our obligations to customers, suppliers, creditors, employees, and others with whom we do business. Our accounting records are also relied upon to produce reports for our management. As a result, it is important that our books, records, and accounts accurately and fairly reflect, in reasonable detail, our assets, liabilities, revenues, costs and expenses, as well as all transactions and changes in assets and liabilities. We require that:
Any employee who becomes aware of any departure from these standards has a responsibility to report his or her knowledge promptly to a manager or the Legal Department.
All employees are expected to protect Bulwark Coffee Company assets and ensure their efficient use. Theft, carelessness, and waste have a direct impact on our profitability. Our property, such as office supplies, computer equipment and software, records, customer information, manpower, Bulwark Coffee Company names and trademarks, physical plants, and products, are expected to be used only for legitimate business purposes. Employees need to be mindful of the fact that we retain the right to access, review, monitor and disclose any information transmitted, received or stored using our electronic equipment, with or without an employee’s or third party’s knowledge, consent or approval. Any misuse or suspected misuse of our assets needs to be immediately reported to your manager or a member of the Finance Department.
Business entertainment and gifts are meant to create goodwill and sound working relationships and not to solicit improper advantage with customers or other officials. Unless permission is received from a manager, entertainment and gifts may not be offered, provided, or accepted by any employee unless consistent with customary business practices. Gifts, meals and entertainment for customers and suppliers must support the legitimate business interests of Bulwark Coffee Company and should be reasonable and appropriate under the circumstances. Always be sensitive to our customers’ and suppliers’ own rules on receiving gifts, meals, and entertainment. These principles apply to our transactions everywhere in the world, even where the practice is widely considered acceptable. Under some statutes, such as the U.S. Foreign Corrupt Practices Act, giving anything of value to a government official to obtain or retain business or favorable treatment is a criminal act.
You may not take personal advantage of opportunities that are presented to you or discovered by you as a result of your position or through your use of corporate property or information, unless authorized by your manager, the General Counsel, or the Audit Committee, as described in “Conflicts of Interest.” Even opportunities that are acquired privately by you may be questionable if they are related to our existing or proposed lines of business. You may not use your position with Bulwark Coffee Company or its corporate property or information for improper personal gain, nor may you compete with us in any way.
A conflict of interest occurs when a person’s personal interest may interfere in any way with the performance of his or her duties or the best interests of Bulwark Coffee Company. A conflicting personal interest could result from an expectation of personal gain now or in the future or from a need to satisfy a prior or concurrent personal obligation. Bulwark Coffee Company expects all employees to be free from influences that conflict with the best interests of the organization. Even the appearance of a conflict of interest where none exists can be damaging and should be avoided. Whether a conflict of interest exists or will exist can be unclear. Conflicts of interest are prohibited unless specifically authorized as described below.
If you have any questions about a potential conflict or if you become aware of an actual or potential conflict, and you are not an officer or director of Bulwark Coffee Company, please discuss the matter with your manager or a member of the Legal Department. Executive Officers and Directors may seek authorization only from the Board of Directors’ Audit Committee.
Factors that may be considered in evaluating a potential conflict of interest are, among others:
The following are examples of situations that may, depending on the facts and circumstances, involve conflicts of interests:
Among Bulwark Coffee Company’s most important assets are its trade secrets and other confidential business information. Employees who have received or have access to trade secrets or other private or confidential information belonging to Bulwark Coffee Company or any third party must maintain the confidentiality of that information. Such confidential information may include business, marketing and service plans, financial information, engineering and manufacturing ideas, designs, databases, configuration of our computer systems, customer lists, pricing strategies, marketing materials, personnel data, personally identifiable information pertaining to our employees (e.g., salary, bonus or performance-review data), customers or other individuals (including, for example, names, addresses, telephone numbers and social security numbers), and similar types of information provided to us by our customers, suppliers and partners. This information may be protected by patent, trademark, copyright, and trade secret laws.
Except when disclosure is authorized or legally mandated, you may not share Bulwark Coffee Company’s or Bulwark Coffee Company’s customers’ or suppliers’ confidential information with third parties or others within Bulwark Coffee Company who have no legitimate business purpose for receiving that information. Doing so constitutes a violation of the Proprietary Information and Inventions agreement that you signed upon joining Bulwark Coffee Company. Unauthorized use or distribution of this information could also be illegal and result in civil liability and/or criminal penalties.
You also need to take care to not inadvertently disclose trade secret, private, or other confidential information. Materials that contain confidential information, such as memos, notebooks, computer disks and laptop computers need to be stored securely. Be cautious when discussing sensitive information in public places like elevators, airports, restaurants and “quasi-public” areas within Bulwark Coffee Company, such as break rooms. All Bulwark Coffee Company’s emails, voicemails and other communications are considered confidential and may not be forwarded or otherwise disseminated outside of Bulwark Coffee Company, except where required for legitimate business purposes.
Advantages over our competitors need to be obtained through superior performance of our products and services, not through unethical or illegal business practices. Acquiring proprietary information from others through improper means, possessing trade secret information that was improperly obtained, or inducing improper disclosure of confidential information from past or present employees of other companies is prohibited, even if motivated by an intention to advance our interests. If information is obtained by mistake that may constitute a trade secret or other confidential information of another business, or if you have any questions about the legality of proposed information gathering, please talk with your manager or a member of the Legal Department.
You are expected to deal fairly with Bulwark Coffee Company customers, suppliers, employees, and anyone else with whom you have contact in the course of performing your job. No employee may take unfair advantage of anyone through misuse of confidential information, misrepresentation of material facts or any other unfair dealing practice.
Whoever is kind to the poor lends to the Lord, and he will reward them for what they have done. -Proverbs 19:17
Being a Bulwark begins and ends with service. Your mission is to conduct secret random and planned acts of kindness to help restore people’s faith in God and humanity. Your service will be repaid in multiples, both to yourself and to the company.
Obeying the law, both in letter and in spirit, is the foundation of this Code. Our success depends upon every employee operating within legal guidelines and cooperating with local, national, and international authorities. It is therefore essential that you understand the legal and regulatory requirements applicable to your business unit and area of responsibility. While we do not expect you to memorize every detail of the relevant laws, rules, and regulations associated with your employment, we want you to be able to determine when to seek advice from others. If you have a question in the area of legal compliance, it is important that you talk with your manager or a member of the Legal Department.
Disregard of the law will not be tolerated. Violation of domestic or foreign laws, rules and regulations may subject an individual, as well as Bulwark Coffee Company, to civil and/or criminal penalties. Be aware that conduct and records, including emails, are subject to internal and external audits, and to discovery by third parties in the event of a government investigation or civil litigation. It is in everyone’s best interest to know and comply with our legal and ethical obligations.
You are expected to comply with the applicable laws in all countries to which you travel, in which you operate, and where we otherwise do business, including laws prohibiting bribery, corruption or the conduct of business with specified individuals, companies or countries. The fact that in some countries certain laws are not enforced or that violation of those laws is not subject to public criticism will not be accepted as an excuse for noncompliance. In addition, we expect you to comply with U.S. laws, rules and regulations governing the conduct of business by its citizens and corporations outside the U.S. These U.S. laws, rules, and regulations, which extend to all our activities outside the U.S., include, but are not limited to:
If you have a question as to whether an activity is restricted or prohibited, please seek assistance before taking any action, including giving any verbal assurances.
Antitrust laws are designed to protect the competitive business process. These laws generally prohibit:
Certain kinds of information, such as pricing, production and inventory, competitors’ bid and proposal information, and “source selection information,” may not be exchanged with competitors, regardless of how innocent or casual the exchange may be and regardless of the setting, whether business or social. We must conduct all interactions with competitors, including social activities, as if they were completely in the public view, because they may later be subject to probing examination and unfavorable interpretation.
Understanding the requirements of antitrust and unfair competition laws of the various jurisdictions where we do business can be difficult, and you are urged to seek assistance from your manager or a member of the Legal Department whenever you have a question.
Whatever you do [whatever your task may be], work from the soul [that is, put in your very best effort], as [something done] for the Lord and not for men. -Colossians 3:23
Even the appearance of impropriety can be damaging. If you encounter a situation and its appropriateness is unclear, please discuss the matter immediately and fully with your manager or a member of the Legal Department.
If you are aware of a suspected or actual violation of this Code by others, you have a responsibility to report it. You are expected to promptly provide a compliance resource with a specific description of the believed violation, including information about the persons involved, the suspected violation, and the time of the violation. Whether you choose to speak with your manager, Human Resources, or the Legal Department, you may do so without fear of any form of retaliation. Bulwark Coffee Company will take prompt disciplinary action against any employee who retaliates against you, up to and including termination of employment.
Managers must promptly report any complaints or observations of Code violations to the Legal Department. All reported Code violations will be investigated promptly and with the highest degree of confidentiality possible. Your cooperation in the investigation will be expected. As needed, the Legal Department will consult with Human Resources and/or the Audit Committee of the Board of Directors.
If the investigation indicates that a violation of the Code has occurred, Bulwark Coffee Company will take action that we believe appropriate. If we determine that an employee is responsible for a Code violation, he or she will be subject to disciplinary action up to, and including termination of employment and, in appropriate cases, civil action or referral for criminal prosecution. Appropriate action may also be taken to deter any future Code violations.
Bulwark Coffee Company will not discharge, demote, suspend, threaten, harass or in any manner discriminate against any employee in the terms and conditions of employment based upon the lawful actions of such employee with respect to good faith reporting of complaints.
Bulwark Coffee Company’s Open Door Policy sets forth resources available to you when asking a question or speaking up about a possible issue. These resources include:
Bulwark Coffee Company will promptly and thoroughly investigate all reports of violations of this Code and will maintain confidentiality to the extent possible without impeding the investigation process, as set forth in the Bulwark Open Door Policy.
Bulwark Coffee Company will not permit retaliation of any kind by or on behalf of the Company against its employees for filing a good faith report or complaint of a violation of this Code.
Whatever is true, whatever is honorable and worthy of respect, whatever is right and confirmed by God’s word, whatever is pure and wholesome, whatever is lovely and brings peace, whatever is admirable and of good repute; if there is any excellence, if there is anything worthy of praise, think continually on these things [center your mind on them, and implant them in your heart]. -Philippians 4:8
The Code of Business Conduct does not address all workplace conduct. Bulwark Coffee Company maintains additional policies and guidelines that may provide further guidance on matters in the Code or address conduct not covered by the Code. It is your responsibility to be aware of the policies that apply to you. Policies are available on the company website or by contacting a member of the Human Resources department.
All new employees must read and comply with the Code of Business Conduct and Ethics and sign an acknowledgement form confirming that they have read the Code, understand it and have had the opportunity to ask questions about it, and agree to abide by its provisions. All employees will be required to make similar acknowledgements on a periodic basis. Failure to read the Code or sign the acknowledgement form does not excuse an employee from compliance with the Code.
Any exceptions to this policy must be approved by the General Counsel. Any exceptions to this policy for executive officers may be authorized only by the Board of Directors or a committee of the Board.
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