Introduction
Tracking Innovations is committed to the pursuit of
excellence and to our shared values—the principles on which our Company was
founded. Our Code is designed to guide each of us as we strive to do business in
accordance with these values and the law. Our Code is structured around our
commitments to our Company; our customers and business partners; our
communities and each other. Upholding these commitments should be at the heart
of every business action we take.
Our Code applies to all Company associates, officers and
directors. To ensure ethical and legal practices throughout our Company’s
operations, we seek out vendors and other business partners who share our
values and uphold our Code in the work they do on our Company’s behalf.
It is vital that we know and comply with the various laws
and regulations that apply to our work. We should also keep in mind that,
depending on our job function and the locations where we are doing business,
local practices may differ from our Code, Company policy or U.S. law. If this
is the case, seek guidance from our Chief Information Officer (“CIO”) before
acting.
Additional Expectations for Managers
Managers must make a special commitment to uphold our Code.
If you are a manager, you are expected to model integrity and our values for
the associates who report to you at all times. Ensure that your conduct
complies with applicable laws and regulations, as well.
Managers have additional obligations that go beyond
upholding our Code, our values and the law. If you are a manager, you are also
expected to communicate frequently with associates about ethics and compliance.
Engaging in such dialogue creates a positive work environment in which asking
questions and reporting concerns is accepted and encouraged. Always take
reports or questions regarding ethical or legal misconduct seriously and ensure
that associates’ concerns are properly resolved. If you become aware of a legal
or ethical issue in the workplace, whether through a rumor, personal
observation or a report, you need to take appropriate steps promptly. If you
are unsure how respond, contact our CIO for guidance as soon as possible.
Seeking Guidance and Reporting Concerns
In the course of doing business for our Company, you may
face a dilemma or suspect legal or ethical misconduct. In these situations, you
have a duty to your fellow associates and our Company to seek guidance or make
a report. Consider discussing the situation first with your manager or
department head. These people know you, are familiar with the work you do and
are likely best equipped to resolve the situation you face.
However, if you feel uncomfortable discussing the issue with
your manager or department head, or if doing so is impracticable or does not
lead to an adequate resolution, please contact any of the following resources:
• Another manager
• Our CIO Randy Kraft in person, or via email at
rkraft@trackinginnovations.com
• Our Chief Executive Officer (“CEO”) Lori Alf in person, or
via email at lalf@trackinginnovations.com
• The EthicsPoint hotline by telephone at (877) 254-1702 or
online at www.ethicspoint.com The EthicsPoint hotline is
operated by an independent company and is available 24 hours a day, 7 days a
week for you to seek guidance or make a report. You may make an anonymous
report where local law allows. However, please remember that maintaining your
anonymity may limit our Company’s ability to undertake a full investigation of
your report.
Non-Retaliation Policy
Anyone who reports actual or suspected misconduct provides
our Company an opportunity to respond to the issue before it becomes a larger
problem. Our Company values and respects associates who report misconduct in
good faith and has made a commitment to protect them from any acts of
retaliation. You make a report in “good faith” when you provide all the
information you have and believe your report to be true. Our Company will also
protect from retaliation anyone who in good faith participates in an
investigation of a report.
Investigating Reports and Handling Violations
Tracking Innovations takes all reports of illegal or
unethical behavior very seriously, responding to all reports quickly and conducting
thorough investigations when necessary. We must participate in the
investigation of reports, as requested. All reports will remain confidential,
consistent with local law and proper resolution of the issue.
Disciplinary Action
If conduct is determined to be in violation of our Code,
Company policy or the law, the individuals involved will be subject to
disciplinary action, up to and including termination. Keep in mind that, if the
conduct violates applicable laws or regulations, those involved may also be
subject to civil and/or criminal liability.