Ethics Policy

1. Objectives:

Bergstrom (together with its domestic and international subsidiaries and affiliates, the “Company”) is committed to maintaining the highest standards of ethical conduct and integrity and complying with applicable laws in all aspects of its business.  Our reputation and our ability to be an excellent, successful Company depend on the behavior of our people.  This Ethics Policy establishes policies and procedures that are intended to guide the Company’s employees, officers, and directors in the performance of their duties and responsibilities to ensure compliance with the Company’s commitment to ethical and lawful conduct.

This Ethics Policy provides specific direction in the following areas:

1. 1. Anti-bribery
   2. Fair Competition and Anti-trust
   3. Gifts, Entertainment and Gratuities
   4. Financial recordkeeping
   5. Export Controls and Economic Sanctions
   6. Political contributions
   7. Conflict of interest
   8. Equal Employment Opportunity
   9. Payments
   10. Confidential and proprietary business information
   11. Trademarks, copyrights, inventions and corporate identity
   12. Disclosure of Information
   13. Internet/Intranet Access
   14. Alcohol and Illegal Drugs
   15. Open door
   16. Whistleblowers
   17. Violations
   18. Declaration

2. Responsibilities:

3. Policy Statement:

Adhering to our Code of Conduct and this Ethics Policy takes precedence over profits, sales, or other such standards of success.  We believe, in fact, that conducting our business ethically and in compliance with applicable law is not only right, but also will result in success for our Company under any standard.  All officers, directors, employees, and representatives of the Company (which are together referred to in this policy as “employees” or alone as an “employee”) are subject to the Company’s Code of Conduct and this Ethics Policy. In addition; consultants, suppliers, and contractors conducting business for or with, or on behalf of the Company, are expected to comply with these policies wherever applicable.

4. Basic Policies

         4.1 Anti-bribery

a) Employees of the Company must abide by all applicable anti-bribery laws, including the U.S. Foreign Corrupt Practices Act (“FCPA”) and the U.K. Bribery Act of 2010 (“UKBA”), and the Local Laws in every other country in which we do operate, including Mexican anti-corruption laws such as the General Law of Administrative Responsibilities. While the FCPA only prohibits bribery of foreign government officials, the UKBA and other applicable laws prohibit bribery of both foreign government officials, as does the Mexican Federal Criminal Code, as well as the bribery of private persons (sometimes referred to as “commercial” bribery). Further, whereas the FCPA only prohibits making bribes to foreign government officials, the UKBA and other applicable laws prohibit both the making and taking of bribes.

b) Even where applicable law allows it, the Company prohibits directly or indirectly offering, promising, authorizing, providing or receiving “anything of value” to domestic and foreign “government officials”. Likewise, the prohibition extends to any of the Company’s customers, distributors, business partners, vendors or other third parties (referred to herein as our “commercial partners”) to induce or reward the improper performance of an activity connected with our business.

c) It is important to note that the term “government official” is broadly defined to include:

i) Any officer or employee of any national, state or local government entity, national, state or municipal department or agency, or constitutionally autonomous institute;

ii) Any employee of a state or government-owned or -controlled entity, including commercial and non-profit organizations (for example, a school, college or university, hospital or state-owned company);

iii) Any political party or official thereof;

iv) Any candidate for political office;

v) Any holder of an elected or appointed political or governmental office;

vi) Any member of a royal family;

vii) Any officer or employee of a public international organization or any department or agency thereof (for example, the United Nations, the World Bank or the World Trade Organization); and

viii) Any person acting in an official capacity on behalf of a national, state or local government entity.

Employees of state-owned or -controlled commercial enterprises (e.g., seemingly private entities with some level of government ownership or influence) generally are considered government officials under applicable law.  It is important to keep in mind that persons who are not classified to be “officials” under local law may still be considered government officials under the FCPA or UKBA or other applicable laws. Because the relevant anti-corruption laws and regulations around the world vary greatly, employees should always contact the Vice President, Human Resources when there is any doubt as to whether an official is a government official.  Employees should also consult the Vice President, Human Resources when dealing with the immediate family member of a government official.

d) It is crucial that we avoid even the appearance of an improper interaction with government officials and our commercial partners. The Company’s prohibition on bribery applies to the offering, promising, giving and/or receiving of “anything of value”, not only money.  “Anything of value” includes, but is not limited to, the following:

i) Business opportunities;

ii) Favorable contracts;

iii) Stock or stock options;

iv) Cash, cash equivalents (for example, gift cards or gift checks) or loans;

v) Payments for improper gifts, meals, travel and entertainment;

vi) Favors, including offers of employment or internships;

vii) Sponsorships;

viii) Promises to pay/give;

ix) Donations to a charity affiliated with or sponsored by a government official or commercial partner; and

x) Political contributions.

e) Prohibited payments can take many different shapes and forms, but they typically involve a “quid pro quo” – that is, payment will be offered or paid in exchange for some improper advantage or benefit. Prohibited payments include, but are not limited to, those designed to:

i) Induce the recipient to award a contract to the Company (even if in the end the company is not awarded the contract);

ii) Obtain advantageous treatment (for example, on tax, customs, permits, or licenses) that would not otherwise be available to the Company; or

iii) Circumvent or cause non-enforcement of laws or regulations applicable to the Company.

f) The Company’s prohibition on bribery applies to all improper payments regardless of size or purpose, including “facilitating” or expediting payments. Facilitating payments are small payments to government officials to expedite or facilitate non-discretionary actions or services, such as obtaining an ordinary license or business permit, processing government papers such as visas, customs clearance, providing telephone, power or water service, or loading or unloading of cargo.  Although there is a narrow exception for facilitating payments under the FCPA, such payments are prohibited under the UKBA and the laws of most countries.  Therefore, to ensure compliance with all applicable anti-bribery laws, our Company prohibits all kinds of facilitating payments.

g) Applicable anti-bribery laws prohibit corrupt payments made directly by Company employees or indirectly through an agent, consultant, distributor, or any other third-party representative acting for or on behalf of the Company (collectively, “third parties”). This includes subcontractors or consultants hired by third parties to perform work on the Company’s behalf.  Any third parties that act on the Company’s behalf must operate in accordance with the Company’s anti-bribery policy.  Accordingly, it is Company policy that:

i) Third parties may not do things that are prohibited by this anti-bribery policy, this Ethics Policy or other Company policies;

ii) Each third party must be carefully selected and evaluated before a business relationship is established;

iii) Commissions, compensation, reimbursement and other payments to third parties will be customary and reasonable in relation to the services required, and will be properly reflected in the Company’s records, books of account and financial statements; and

iv) Payments to third parties may not be made in cash or cash equivalents, or to bank accounts that are not in the third party’s name, without prior written approval from the Chief Financial Officer.

The Company does not need to have actual knowledge that a third party is violating applicable anti-bribery laws in order to be held criminally liable for that third party’s actions. The Company and its individual employees may be found to have violated the FCPA if they have reason to know or should have known that a third party would bribe a foreign government official.  Under the UKBA, the Company and its employees can be held criminally liable for the actions of the Company’s third-party agents even if the Company has no knowledge of the bribe.  Accordingly, it is crucial for the Company to carefully choose its third-party partners and agents to protect itself from liability for improper payments made by third parties.

Under the FCPA, the U.S. Department of Justice (“DOJ”) has identified the following “red flags” that may suggest reason to know that a third party is making payments in violation of the FCPA:

i) The transaction involves a country known for corrupt payments;

ii) The third party has a close family, personal or professional relationship with a government official or relative of an official;

iii) The third party objects to making anti-bribery representations in Company agreements;

iv) The third party’s majority shareholders, directors or officers are government officials;

v) The third party lacks the qualifications to perform the required services;

vi) The third party lacks transparency in its accounting records;

vii) The third party requests unusual contract terms or payment arrangements that raise local law issues, such as payment in cash, payment in another country’s currency, or payment in a third country;

viii) The third party is suggested by a government official, particularly one with discretionary authority over the business at issue; or

ix) The third party’s commission or fee exceeds fair and reasonable compensation for the work to be performed.

Ignoring these red flags or other suspicious facts may give rise to a presumption that the Company has knowledge of a third party’s illegal behavior. In all cases where risk factors are or become present, consult the Chief Financial Officer prior to taking action.

h) Although the Company’s anti-bribery policy is intended to provide guidance, anti-bribery matters are not always clear and must often be addressed on a case-by-case basis. In all situations where there is a question, ambiguity or uncertainty, employees must consult the Chief Financial Officer prior to taking action.

4.2 Fair Competition and Anti-trust

The Company is committed to promoting fair and open competition in every market where we operate. We believe that ethical conduct, integrity, and compliance with antitrust and competition laws are fundamental to our long-term success and reputation.

We strictly prohibit any business practices that seek to unlawfully restrict competition or violate applicable antitrust laws, including those enforced by authorities in the United States, the European Union, and other jurisdictions.

The primary principles are as follows:

a) Compliance with Laws: We will fully comply with all applicable antitrust and competition laws, which are designed to protect consumers, foster innovation, and ensure a level playing field for all businesses.

b) Prohibited Conduct: The following behaviors are strictly forbidden:

• • Price Fixing: Agreeing with competitors on pricing or pricing strategies.
  • Market Allocation: Dividing markets, customers, or territories with competitors.
  • Bid Rigging: Colluding with others to fix or manipulate bidding processes.
  • Boycotts: Coordinating with others to exclude or avoid doing business with specific companies or individuals.

c) Independent Decision-Making: All business decisions regarding pricing, marketing, sales, and customer relationships must be made independently and in the best interest of Bergstrom, not in coordination with competitors.

d) Trade Association Conduct: Participation in industry or trade associations must be conducted in a manner that complies with antitrust laws. Discussions of competitive practices, pricing, or other sensitive topics are strictly prohibited in these settings.

e) As in other areas of the policy, concerns or suspected violations must be reported through appropriate internal channels, see section 4.15 and 4.16. All reports will be investigated and appropriate action taken where required. Retaliation against individuals who report concerns in good faith is strictly prohibited.

4.3 Gifts, Entertainment and Gratuities

a) Consistent with the Company’s anti-bribery policy, which is detailed in Section 4.1 of this Ethics Policy, it is never permissible to provide or receive gifts, meals, travel, or entertainment to improperly influence anyone, particularly a government official, or in exchange for any improper favor or benefit (i.e., as a “quid pro quo”). There is no de minimis exception under the FCPA or UKBA – a bribe of any size is illegal if given for an improper purpose.

b) Under certain circumstances, it may be permissible, with prior approval from the Vice President, Human Resources to provide or receive modest gifts, reasonably-priced meals, modest travel and lodging to or from a government official or commercial partner if:

• • There is no possibility it could be construed as being given in exchange for any return favor or business advantage (i.e., quid pro quo);
  • It is infrequent, modest, and reasonable in amount under the circumstances;

• • It conforms with applicable law, local custom and business practice;

• • It conforms with applicable law, local custom and business practice;
  • ances;avor or business advantage (i.e., quid pro quo) mealst was not solicited by the recipient; and
  • It is reported and documented accurately in the Company’s books and records.

c) Whether a gift could be perceived as a bribe depends on the timing and context surrounding the gifting, including the past, pending or future business or administrative matters that are within the recipient’s realm of influence. For example, it may be appropriate to give a modest gift to a commercial partner in celebration of a special event (e.g., an anniversary of our business relationship with that commercial partner), but not to secure a contract that is up for renewal.

d) Unsolicited gifts should be reported to the Vice President, Human Resources, who may permit gifts of nominal value to be retained by the employee based upon the purpose, timing, value, frequency and source of such gifts. Gifts of cash or cash equivalents are never acceptable in any amount. Failure to report a gift or gratuity shall result in disciplinary action up to, and including, termination.

4.4 Financial recordkeeping

a) The Company’s books and records must accurately, completely and properly reflect all assets, liabilities, revenues and expenses. No undisclosed, unreported or unrecorded funds of the Company shall be established for any purpose. Attempts to create false or misleading records are forbidden, and no false or misleading entries shall be made in the Company’s books and records for any reason, or the destruction of such books, records or working papers. Any violation is grounds for immediate termination.  Violation of this policy may also mean breaking the law, subjecting individuals to criminal penalties or civil sanctions. 

b) No employee may conceal information from authorized auditors or regulatory agencies. Each employee will disclose, on a timely basis, information required to evaluate the fairness of the Company’s financial presentation and soundness of its financial condition and the propriety of its operation.

c) No payment or transfer of Company funds or assets shall be made which is not authorized, properly accounted for, and clearly identified on the Company’s books. Furthermore, no payment or transfer of Company funds or assets shall be made or approved with the intention or understanding that any part of such payment or transfer is to be used except as specified in the supporting documents. 

4.5 Export Controls and Economic Sanctions

Bergstrom is committed to conducting business in full compliance with all applicable export control laws and economic sanction regulations of the countries in which it operates, including but not limited to those administered by the United States, the European Union, United Kingdom, Mexico, China, and the United Nations.

We recognize that export controls and sanctions are vital tools for maintaining national security, supporting foreign policy, and preventing the proliferation of weapons and other sensitive technologies. As such, we will not engage in any transaction, directly or indirectly, that violates applicable export laws or sanctions.

We expect all individuals acting on behalf of the company to uphold this commitment and ensure that our global operations do not compromise these core values.

4.6 Political contributions

The Company supports active participation in the political process and urges its employees to support the candidates and issues of their choice.

4.7 Conflict of Interest

a) A conflict of interest is any circumstance that could cast doubt on an employee’s ability to act totally objectively regarding the Company’s interest or any situation, and benefits the individual to the detriment of the Company. Employees are expected to deal with suppliers, clients, contractors and all others doing business with the Company on the sole basis of what is in the best interest of the Company, without favor or preference based on personal considerations.  Avoiding the appearance of a conflict can be just as important as avoiding an actual conflict.

b) Relationships involving an employee’s immediate family or relative may be relevant. “Immediate family” or “relative” includes any of the following:  Parents, spouse, brother(s), sister(s), son(s), daughter(s), uncle(s), aunt(s), grandparent(s), in-laws, i.e. mother-, father-, sister-, brother-in-law, and members of the same household.  In addition, romantic or other personal relationships that may create a conflict of interest with the employee’s Bergstrom responsibilities or compromise the Company’s legal or business interests are not permitted.

c) To prevent problems of perceived or actual conflicts of interests the Company reserves full discretion to (1) decline applications from relatives, (2) restrict job placement, (3) reassign related employees, (4) modify the supervisor’s role or the chain of authority, and (5) take other reasonable precautions management deems appropriate.

d) Each employee must disclose any actual or potential conflicts of interest to their local Human Resources representative. If acting in the capacity of a manager, when you learn of possible conflicts of interest, you must take timely remedial and investigative action to mitigate the potential conflict, implement necessary compensating controls to ensure continuing compliance.  Ensure that employees understand their continuing responsibilities under this policy.

e) Each employee must be sure that any outside financial or business interest – either as investments or operating businesses – does not conflict with his or her obligations to the Company.

f) Before accepting any position as an officer or director of an outside business concern, consider the advantages and disadvantages to the Company, including the appearance of possible conflicts of interest, and consider your responsibilities as a director as specified by laws and regulations.

g) Obtain the written approval from the CFO when accepting a board position with a not-for-profit entity, when there may be a Bergstrom business relationship with the entity or an expectation of financial or other support from Bergstrom.

h) Disclose your outside activities, financial interests or relationships that may present a possible conflict of interest (or appearance of a conflict) to the CFO. Make these disclosures in writing.

The following are not permitted:

Taking a part-time job or other position where you may be tempted to spend time on that job or position during your normal Bergstrom working hours or to use Bergstrom equipment or materials.

Using Bergstrom proprietary or confidential information in an outside business, consulting activity, or for any other purpose other than the performance of your duties on behalf of Bergstrom. (This provision in no way diminishes your obligations under this policy or any other Confidential and Proprietary information restrictions signed by you with Bergstrom or any of its subsidiaries.)

Using Bergstrom facilities, equipment, e-mail, or computer applications for an outside business.

4.8 Equal Employment Opportunity

Bergstrom believes that all persons are entitled to equal opportunity and does not discriminate against its employees or applicants because of sex, race, religion, color, creed, national origin, ancestry, marital status, past or present military service, disability, age, handicap, weight, height or any other characteristic protected by law. All employment decisions at Bergstrom are to be made based on Company needs, job requirements and individual qualifications without regard to any legally protected characteristics or based on any other unlawful basis or purpose.

4.9 Payments

In addition to the prohibitions against improper payments to and from government officials and our commercial partners discussed in Sections 4.1 and 4.3 of this Ethics Policy, Employees shall not make any payments outside the normal payroll or accounts payable process to any employee or service provider for work performed.

4.10 Confidential and Proprietary Business Information

a) Information regarding the Company’s operations, business, planning, techniques, know-how and financial status, both short and long term, must be kept confidential unless prior written approval is received from Human Resources.

b) Confidential information shall include any information, matter, or thing that is of a secret, confidential or non-public nature connected with the business of Bergstrom, its subsidiaries, or any of its customers or suppliers including, but not limited to, matters of a technical nature (including inventions, formula, computer programs, concepts, developments, contributions, devices, discoveries, software and documentation, secret processes or machines, including any improvements thereof and know-how related thereto, and research projects), and matters of a business nature (such as information about the identity of clients, client preferences, client contacts, client procedures, contracts, contract forms, price lists, costs, profits, tax information, financial records, advertising methods, vendors, potential vendors, and employees, and plans for further development) and other information not generally available to the public.

c) This confidential information is proprietary, and any unauthorized disclosure will be considered loss of private property, and a serious offense. Therefore, confidential business information relating to the Company and its subsidiaries and affiliates must be kept secure, used solely as authorized by the Company, and must not be given to unauthorized outsiders or used for personal interest or profit. In addition, this confidentiality requirement continues even after employment has ended with the Company. In the event of a violation of this confidentiality requirement after termination of employment, whether voluntary or involuntary, the Company may take action to enforce this policy, including seeking both injunctive relief and/or monetary damages as appropriate.d) The following are some examples[1] of the type of information concerning the Company, whether oral, written or contained in any software or other form, which are confidential:

• • Proposed or advance business plans;
  • Projected earnings, important management or organizational changes, acquisitions or joint ventures and any other information which would affect the above;
  • Information relating to strategic service solutions or service design and development or training;
  • Computer software and systems developed by, for or unique to the Company’s business;
  • Customer and members lists and contracts and other information;
  • Organization charts, employee lists, address lists;
  • Information about prospective clients;
  • Advertising, marketing or pricing plans, methods or strategies;
  • Cost structures;
  • Financial information;
  • All analyses, compilations, studies or other documents, whether or not prepared by the employee, which contain or otherwise reflect confidential information.

e) Here are some factors which you may consider in determining whether information may be proprietary:

• • Does it reveal marketing strategies, decisions or an assessment of the marketplace?
  • Is it technical information, which we might want to release under licensing arrangements?
  • Does it relate to future plans?
  • Is it information, which has been taken from another Company document containing proprietary information?
  • Does it contain something relating to software or computer programs?
  • Would it be of value to others?
  • Was it costly to develop?
  • Is the information preliminary, speculative, subject to change or interpretation?
  • Does it refer to documentation and equipment not available to others?
  • Does it contain information relating to customers and their accounts, employee personnel date, employee health records, shareowner information or financial recommendations or projections?
  • Although these are not the only considerations, if you answer “yes” to any of the above questions, then you should not provide such information to outside sources, and the document should be labeled with the appropriate proprietary information marking. Any request for such information should be referred to General Counsel.
  • As to any matter pertaining to the Company’s business, an employee may not appear as a witness, give testimony or sign a statement advocating a position at the request of outside parties, except as required by law, or lobby before any government, legislative, judicial or administrative body without specific, prior approval from the President & CEO.
  • Any request for speeches, newspaper or magazine articles and media interviews or comments should be referred to Human Resources. Any request to submit comments to a public official or governmental body should be referred to Human Resources.

f) Each employee must protect against unauthorized disclosure of confidential information to which he or she has access. Access in itself never confers the privilege to disclose the information without proper authorization from Human Resources. In addition, employees should refrain from discussing confidential information with acquaintances or business and professional associates.

g) Upon termination of employment or other contractual relationship with the Company, for any reason, whether voluntary or involuntary, the employee shall promptly deliver to the Company all manuals, letters, notes, drawings, photographs, reports, recordings, emails, and other materials, including all copies, containing confidential information.

4.11Trademarks, Copyrights, Inventions, and Corporate Identity

a) Each employee acknowledges that he or she has no rights to any product, invention or process of a proprietary nature, regardless of whether patented, copyrighted, trademarked or licensed. In addition, employees shall protect against the improper use of such Company products by others.

b) The Company will refrain from claiming rights over an employee’s invention, creation or other licensable activity which the employee created or developed solely on his or her own time, not on the Company’s premises, not using Company resources, and not related to the employee’s work for the Company.

c) Employees shall respect the proprietary information and property of other companies, including, but not limited to, patents trademarks and copyrighted materials.

4.12Disclosure of Information

The Company is committed to transparency, honesty, and integrity in all communications. We recognize that accurate and timely disclosure of information is essential to maintaining the trust of our stakeholders, complying with legal obligations, and protecting our corporate reputation.

We are dedicated to ensuring that all disclosures, whether to regulators, investors, employees, customers, or the public—are truthful, complete, and made in accordance with applicable laws regulations and company policies.

The Key principles are as follows:

• • Accuracy and Honesty: All information disclosed by the company must be accurate, complete, and not misleading. We prohibit the intentional omission or misrepresentation of material facts in any internal or external communications.
  • Timely Disclosures: Disclosures must be made promptly, appropriately, and as soon as practicable, particularly when required by law, to meet compliance obligations, or in response to regulatory requirements.
  • Compliance with Legal and Regulatory Requirements: We will comply with all applicable laws, regulations, and industry standards governing the disclosure of financial, operational, and other material information.
  • Confidential and Proprietary Information: While we are committed to transparency, we also respect the need to protect sensitive, confidential, and proprietary information, see section 4.10. Disclosures will be made with careful consideration of legal protections and competitive interests.
  • Authorized Spokespersons: Only designated individuals are authorized to make official public statements or disclosures on behalf of Bergstrom. Unauthorized communication of company information may result in disciplinary action.
  • Financial Reporting: Financial disclosures must be prepared in accordance with generally accepted accounting principles (GAAP) or other relevant standards and reviewed through appropriate internal controls to ensure accuracy and consistency, see also section 4.4.
  • Reporting Concerns: In line with sections 4.15 and 4.16 of this policy, employees are encouraged to report any concerns regarding improper disclosures or failures to disclose the required information. Reports will be handled confidentially, investigated promptly, and without fear of retaliation.

4.13 Internet/Intranet Access and Use

The Company provides employees with computer equipment and/or on-line access to networks including the global internet as needed to do their job.  Computer equipment and on-line access are tools to help the Company attain its goals of providing products and support to customers, allowing effective communications with coworkers, customers, suppliers, and sales reps while publicizing the Company’s products and services to the world.

Your use of computer equipment and on-line access at the Company is subject to the Company’s Information Technology Policy.

4.14 Alcohol and Illegal Drugs

Alcohol and illegal drugs have no place in the workplace and are not consistent with a safe and productive working environment.  Employees are prohibited from consuming alcohol or using, possessing, or distributing illegal drugs while working or operating Bergstrom equipment (including company vehicles). 

In the event alcohol is served while entertaining customers or at a business function, employees of legal drinking age can choose not to drink, or to drink in moderation by limiting their intake.  Ultimately, employees should never place their safety or the safety of others at risk after consuming alcohol nor should their behavior bring embarrassment to themselves, others, or the Company. 

4.15 Open Door

The Company’s “Open Door” approach is designed to further support this Ethics Policy by ensuring our employees have an open channel of communication with their leadership and to the senior leadership of the Company when they have a question, concern or complaint about any aspect of their employment relationship with the Company.

The intent of this Open Door approach is to ensure employee concerns are addressed promptly and objectively.  It is understood, of course, that using the Open Door will not always result in the action desired.  However, it does provide employees the opportunity to review their concerns with their local leadership, and, if necessary with the senior leadership of the company.  Employees using the Open Door are ensured of freedom from reprisal.

When using the Open Door employees should talk with their manager as soon as a concern or question arises.  Experience has shown that open and direct communication between employee and management is the best way to resolve questions, concerns and misunderstandings.

If the employee and their immediate manager cannot resolve the concern, the manager will help the employee seek resolution through senior management at the facility.  Should the concern still exist, the local Human Resources Representative will assist the employee in pursuing the next “Open Door” at the corporate level.

Although employees are urged to talk with their local leadership first, there may be situations in which you prefer not to do so, or when you are not satisfied with your leadership’s response.  In these instances, you are encouraged to contact your local Human Resources Representative.

4.16 Whistleblower

A whistleblower as defined by this policy is an employee of Bergstrom who reports an activity that the employee considers to be illegal or dishonest to a member of authority outlined in this section.  The whistleblower is not responsible for investigating the activity or for determining fault or corrective measures; appropriate management officials are charged with these responsibilities.

Examples of illegal or dishonest activities are violations of federal, state or local laws; billing for services not performed or for goods not delivered; and other fraudulent financial reporting.

If an employee has knowledge of or a concern of illegal or dishonest fraudulent activity, the employee is to contact his/her immediate supervisor, Human Resources or senior management. The employee must exercise sound judgment to avoid baseless allegations.

Whistleblower protections are provided in two important areas — confidentiality and against retaliation. Insofar as possible, the confidentiality of the whistleblower will be maintained. However, identity may have to be disclosed to conduct a thorough investigation, to comply with the law and to provide accused individuals their legal rights of defense. Bergstrom will not retaliate against a whistleblower. This includes, but is not limited to, protection from retaliation in the form of an adverse employment action such as termination, compensation decreases, or poor work assignments and threats of physical harm. Any whistleblower who believes they are being retaliated against must contact Human Resources immediately. The right of a whistleblower for protection against retaliation does not include immunity for any personal wrongdoing that is alleged and investigated.

4.17     Violations

Due to the importance of these policies, employees found to have violated these policies or intentionally file a false report of wrongdoing will be subject to appropriate disciplinary action up to, and including, termination. If you believe that a violation of this Ethics Policy has occurred or may occur, you should report this information to your Manager, Local Human Resources Representative, Vice President, Human Resources or the CFO.  In any case, where an employee requires more specific guidance the employee should ask the Vice President, Human Resources for clarification and direction.

It shall be the responsibility of all managers to ensure compliance throughout Bergstrom and its subsidiaries with the standards of conduct imposed by this Ethics Policy.  Each manager working with Human Resources shall be responsible for the appropriate distribution of the Ethics Policy for dissemination of any guidelines and for ensuring that they are fully understood and followed.

Reporting channels

Individuals can report violations through various channels, such as:

• Reporting concerns to the local Human Resources Representative
• Email: Ethics@dimgrey-goat-433611.hostingersite.com
• Phone (United States): 1 815 873 4618

[1]    The list is not meant to all-inclusive but merely some examples of the types of information which are clearly confidential in order to assist the individual in assessing what constitutes confidential and proprietary information.  Wherein an individual is not sure if a particular item or piece of information is confidential or proprietary, he or she should treat the material as confidential or proprietary until such time as the individual has had a chance to review the material and obtain written approval to treat the information as not confidential or proprietary from Human Resources or the General Counsel.