The Black Box "Standards of Business Conduct", developed early in our Company’s history, are still part of our business philosophy today and reflect our commitment to ethical business practices and regulatory compliance.
Our "Code of Ethics for Directors, Officers and Employees" identifies the standards that apply to all Team Members, everywhere, and in every circumstance. The ethical conduct of each and every Black Box Team Member is a cornerstone of our efforts toward corporate sustainability. We pursue our business mission in order to ensure the success and lasting presence of our Company for the benefit of our customers, suppliers, stockholders and Team Members. Our uncompromising ethics are a critical component of our ability to accomplish this objective.
A Team Member should report the following events or transactions to their supervisor or manager, Human Resources, General Counsel or the Black Box Ethics Helpline (“Helpline”):
• Code of the Ethics violations
• Internal controls violations
• Improper conduct
• Fraud
• Bribery and kickbacks
• Conflicts of interest
• Misuse of company property
• Theft or embezzlement
• Violation of company policy
• Violation of law
• Falsification of contracts, reports or records
Regular business issues and matters not requiring anonymity should be directed to the Team Member’s supervisor or the Human Resources Department.
Additionally, as set forth in the Team Member Handbook, the Company promotes an “Open Door Policy” as a means to resolve job or ethical concerns with the next higher-level supervisor, Human Resources or successively higher levels of management, up to and including a Vice President or the CEO, if necessary. The intent in maintaining this “Open Door Policy” is to ensure everyone the opportunity to be heard at all times, and to effectively resolve any concerns.
Any Team Member can contact the Helpline via phone (1-855-833-0005 for Team Members in the United States and Canada) or an internet web link (Black Box Ethics Helpline). The Helpline is hosted by an outside firm and is confidential, anonymous and available 24 hours a day every day of the year.
A Team Member who contacts the Helpline will be asked a series of questions to better understand the nature of the concern. The concern will be summarized and forwarded to the appropriate Black Box department for review and, if necessary, investigation. At the end of the call, the Team Member will be provided with a unique identification number which allows the Team Member to track the status or provide additional information relating to the concern.
To encourage Team Members to report potential ethical or integrity concerns, Black Box prohibits retaliation for reports of misconduct made in good faith by a Team Member. However, if a Team Member makes a knowingly false or inaccurate report, such Team Member may be subject to disciplinary action.