The Zurn Elkay Code of Business Conduct and Ethics
guides our behavior across all business units and levels of the company, defining responsibilities, providing resources and guiding training on various areas, including our Anti-Corruption Law Policy and procedures. The Code covers a range of topics, including conflicts of interest, insider trading, data privacy, employment practices such as harassment and discrimination, and our Human Rights Statement.
We developed the compliance and ethics policies in our ESG strategy to reflect the values and principles laid out in the United Nations Global Compact Human Rights and Anti-Corruption Principles
Businesses should support and respect the protection of internationally proclaimed human rights
Make sure that they are not complicit in human rights abuses
Businesses should work against corruption in all its forms, including extortion and bribery
In 2022, we also made our Human Rights Statement
a stand-alone policy that we communicate to our associates and suppliers, and we added human rights training for all associates. Our Human Rights Statement aligns with United Nations Global Compact Principles 1 and 2, the Universal Declaration of Human Rights and the International Labor Organization’s Declaration on Fundamental Principles and Rights at Work.
Our Anti-Corruption Law Policy
is an integral part of our Compliance and Ethics Program. As a multinational company, Zurn Elkay operates under several different regulatory and legal regimes, including the U.S. Foreign Corrupt Practices Act (FCPA) and other local and international bribery and corruption laws. We provide our Anti-Corruption Law Policy to associates in multiple languages to deliver the guidance needed to remain in compliance with various laws. We require biennial anti-corruption training for associates in several relevant job functions, including legal, finance, sales, business development, supply chain and logistics. Associates who undergo training must sign off on our Anti-Corruption Law Policy and receive a certificate of completion.
We also employ a strong due diligence process to protect the company against bribes and other unlawful offers made to potential customers by third-party intermediaries such as sales agents, customs brokers and freight forwarders. Any associate hiring a third-party intermediary must perform an anti-corruption review process and risk assessment. Our contracts with third-party intermediaries also include standard provisions such as anti-corruption representations, audit rights and termination rights for any violations of applicable anti-corruption laws. We repeat this process when existing contracts or relationships come up for renewal.
Regular reviews of anti-corruption activities and processes allow us to evaluate compliance with our corporate procedures and policies, helping drive continuous improvement in our Compliance and Ethics Program each year.
To support our commitment to our Code of Business Conduct and Ethics, we maintain a reporting program that allows associates and vendors to report claims through various methods, including a 24/7 confidential hotline, website, email, mail, in person or externally through government regulators. This same reporting program is accessible to associates to report interactions and transactions with suppliers and other supply chain partners. We have established processes to ensure that we address and investigate all hotline and whistleblower concerns in a timely fashion and then report out to the appropriate level of the organization. Our Internal Audit function reviews compliance with aspects of our code as part of its activities, including site audits. The ethics reporting program provides guidelines for reporting material ethics claims to the Audit Committee of the Board of Directors. The Board of Directors receives an annual report on the Company’s Compliance and Ethics program.