Operating Principles
Responsible behavior is fundamental to TILIAgroup and how we conduct business. We are committed to achieving these high ethical standards, which substantiate our duties to our clientele by: (i) managing our operations responsibly; and (ii) conducting our business through ethical practices. TILIAgroup’s professional relationships and its resources throughout the global marketplace are a critical part of this commitment.
To clarify what we expect from the manufacturers, distributors, suppliers, contractors and end users (each referred to as “party” and collectively “parties”) and each of their supply chains, we have adopted these “Operating Principles” – Guidance for Responsible Business (hereafter referred to as “Principles”). The Principles outline a set of ‘best practice’ expectations. They are not intended to conflict with or modify the terms of any contracts or agreements with TILIAgroup or any of its affiliates. If a contract requirement (and/or an applicable law or regulation) addresses the same areas as covered in these Principles, parties to the contract must comply with the contract (and/or legal) requirement.
Responsible behavior is vitally important to the reputation and success of TILIAgroup. Our advisers, directors, employees, independent contractors, 3rd party service providers, and the contractors, manufactures, distributors, product trade suppliers, and end users (collectively “TILIAagents”) that we engage with, are all instrumental pieces of that effort.
What We Expect From TILIAagents
Code of Conduct and Compliance
TILIAgroup’s Code of Conduct is central to our responsible business environment. We encourage TILIAagents to implement and adhere to their own similar written code of conduct. In addition, commensurate with the size and nature of their responsibilities and/or business, we expect TILIAagents to have management systems in place to support compliance with applicable laws and regulations.
Anti-Corruption
We expect TILIAagents to comply with all relevant laws and regulations regarding anti-corruption including, where applicable, the Foreign Corrupt Practices Act and the UK Bribery Act. TILIAgroup has a zero tolerance for any corrupt activity. In particular TILIAgroup will not tolerate corrupt activity involving government officials, our commercial business partners, or the receipt of bribes or kickbacks by TILIAgroup personnel. We will not offer, give, or receive any payment, benefit or gift that may be construed as a bribe, for any business purpose whether directly or through any third party. TILIAgroup expects its suppliers to be similarly intolerant of corrupt activity and to have appropriate and adequate procedures to prevent such activity from taking place.
TILIAgroup does not pay ‘facilitation’ payments and will not pay for the expediting of routine government activity unless there is a formal lawful fee schedule for expedited service, and we similarly expect that TILIAagents will not make such payments in connection with any TILIAgroup business. We expect TILIAagents to ensure that the offering or receipt of any gift or business courtesy is permitted by law and regulation, does not violate the rules and standards of the recipients organization, and is consistent with all reasonable market terms and conditions.
International Trade Compliance
We expect TILIAagents to conduct business in compliance with all applicable laws and regulations governing:
– export, re-export, import of products, technical data, software and services; and
– economic sanctions and embargoes.
Anti-Trust and Competition
We expect TILIAagents to conduct business in accordance with all applicable competition and anti-trust laws and regulations. We expect that TILIAagents will not enter into formal or informal anti-competitive arrangements that fix prices, rig bids, limit supply, control markets, or otherwise improperly restrict or impact competition.
Conflict Minerals
We expect TILIAagents to conduct appropriate due diligence, where reasonably feasible, to identify, report and take remedial action, if their products contain conflict minerals (tin, tantalum, gold and tungsten, etc.) that are used to finance conflict in the Democratic Republic of Congo, adjoining countries, or other conflict-affected or high-risk areas. Where applicable local laws and regulations exist in the jurisdiction in which the supplier operates, we expect TILIAagents to comply with such laws and regulations.
Counterfeit Components
We expect TILIAagents to develop, implement and maintain methods and processes appropriate to their products to prevent counterfeit parts and materials being delivered. Effective processes should be in place to detect, report and quarantine counterfeit parts and materials and prevent such parts re-entering the supply chain. We expect TILIAagents to only use parts from Original Equipment or Component Manufacturers or their authorized sources, and to comply with applicable laws, regulations, and industry ‘best practice’ protocols when conducting business with TILIAgroup.
Conflicts of Interest
We expect TILIAagents to avoid conflicts of interest or situations giving the appearance of a potential conflict of interest in their dealings with TILIAgroup. We understand that such actual or potential conflicts do arise in the course of business from time to time, in which case we expect TILIAagents to timely disclose them to TILIAgroup and all other affected parties.
Accurate Record Keeping
We expect TILIAagents to accurately and securely capture, store, and retain, as appropriate, business records.
Personal, Confidential and Proprietary Information
We expect TILIAagents to protect all sensitive information, including confidential, proprietary and protected personal information. Information should not be used for any purpose other than the business purpose for which it was provided without prior authorization. Where such information is held or transferred electronically, we expect TILIAagents to implement appropriate IT cyber security and to notify TILIAgroup of any suspected or actual data breaches. We expect TILIAagents to comply with applicable intellectual property rights and data privacy laws.
Workplace/Employees
We expect TILIAagents to foster an inclusive work environment where individuals are treated with dignity and respect. To that end, we expect TILIAagents to comply with applicable non-discrimination laws and regulations. We also expect TILIAagents to ensure that employees may perform work in an environment that is free from harassment or other abusive conduct.
We expect TILIAagents to not engage in the use of forced or bonded labor, slavery or trafficking of persons. Suppliers should allow employees to freely choose to work or to leave employment. We also expect TILIAagents to ensure that child labor is not used in the performance of work. The term ‘child’ refers to any person under the minimum legal age for employment where the work is performed.
We expect TILIAagents to comply with applicable laws and regulations on pay, benefits, working hours, health and safety, and the rights of individuals to join trade unions and participate in collective bargaining.
We expect TILIAagents to provide employees and third parties with access to adequate reporting channels to seek advice or raise legal or ethical concerns without fear of retaliation, including opportunities for anonymous reporting. We expect TILIAagents to take action to prevent, detect and correct retaliatory actions.
Environment
We expect TILIAagents to comply with applicable laws and regulations regarding the environment and to conduct their business in a manner that actively manages environmental risks.
Timely Payment
We expect TILIAagents to pay their suppliers on time in accordance with agreed contractual payment terms.
Ethics Helpline
If a supplier has a concern regarding these Principles, contact our Ethics Helpline at: +1.812.432.2717
Website and Social Media Statement
TILIAgroup is a privately held organization; its public facing content strategy is to focus its available time and resources on serving TILIAagents by assisting them with, and adapting to, their operational and day-to-day requirements. As a policy, we do not advertise TILIAagent’s or their contact information. We do provide references and pertinent credentials upon request and when appropriate.
TILIAgroup maintains a twitter account (“@tiliagroup”) for the sole purpose of monitoring information relating to our various projects and services, however and at this time, we do not: (i) post tweets; (ii) maintain any other social media accounts; (iii) issue press releases; or (iv) seek to build a public audience.
Please contact us with any questions by phone or text at: (812) 432-2717, or by email at: info@tiliagroup.com.