ANTI-CORRUPTION POLICY

Midwest Mill Co. is committed to conducting business transparently, honestly and with the highest level of integrity while adhering to all applicable anti-corruption and anti-bribery laws. Midwest Mill Co. will not conduct business or associate with any entities or persons who indulge in illegal or immoral practices which violate company policy. Any employee found to be involved or in any form associated with scandalous activity or communication will be immediately suspended and placed under investigation which may include the involvement of local and possibly Federal authorities. The company board of directors will perform the necessary protocol involving discipline, legal action, and investigation of offenses. All third parties involved in a nefarious activity may also be reported to local and possibly Federal authorities and will be prohibited from conducting current and future business and communication.

1. What is Corruption and Bribery?

Bribery can be generally defined as the offering, promising, giving, accepting or soliciting of an advantage as an inducement or reward for an action which is illegal or a breach of trust. For example:

A.   Accepting non-cash gifts without company approval
B.   Accepting lavish entertainment or hospitality without company approval
C.   Accepting any type of donation, discount or incentive without company approval
D.   Accepting any of the aforementioned with the intention of returning business related or personal favors.
E.   Offering any of the aforementioned with the intention of obtaining business related or personal favors.

2. Employee and Associate Restrictions


All of the following restrictions apply to any persons or entities including but not limited to corporations, contractors, vendors, and associates who are conducting business or personal activities with Midwest Mill Co.

A.   Giving, promising to give, or offer, entertainment, cash, gifts of hospitality or favors with the expectation or intention of receiving business-related advantages or favors.
B.   Giving, promising to give, or offer, entertainment, cash, gifts of hospitality or favors with the expectation or intention of rewarding a business advantage already provided.
C.   Giving, promise to give, or offer, entertainment, cash, gifts of hospitality or favors with the expectation or intention of receiving political, procedural or legislative advantages from government officials and employees or parties representing or related to government officials and employees.
D.   Accepting entertainment, cash, gifts of hospitality or favors from third parties with the expectation or intention of receiving business-related advantages or favors.
E.   Threats or retaliation against any party who has refused to commit bribery, illegal activity, or activity which violates company policy.
F.   Threats or retaliation against any party related or associated with persons or entities who have refused to commit bribery, illegal activity, or activity which violates company policy.
G.   The term, “third party” means any individual, entities or organizations you come into contact with during the course of your work for or with the Midwest Mill Co. and includes actual and potential member companies, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies, including their advisors, representatives and officials, politicians and political parties.
H.   Midwest Mill Co. employees, board members or representatives are not to accept cash, entertainment, or hospitality gifts exceeding $300 USD. Any gift offered exceeding $300 USD must be documented and approved by all members of the management staff and the board of directors. Board members are not excluded from this policy. Accepting any such gifts or favors without prior approval and documentation is grounds for immediate termination.
I.   Political or charitable donations with the expectation or intention of gaining business, personal or political advantages. Charitable donations will be allowed only with the approval of applicable management staff members and the board of directors.
J.   All charitable donations will require receipts issued by the donee along with a statement containing the organization’s mission statement and explanation of how the funds will be allocated.


3. Employee Company and Associate Responsibility

All employees, vendors, contractors, associates, and entities conducting business with Midwest Mill Co. are required to fully read and comprehend all company policies regarding corruption and bribery. Ignorance of policy or law will not suffice in the event of an offense. Any offense will result in the termination of employment, association, or contract. The aforementioned and terms herein must be agreed upon before any business matters or relations are contracted or conducted.

A.   Employees, associates and all parties conducting business with Midwest Mill Co. must immediately report any suspicion or acts of bribery and corruption to a board member.
B.   An employee will be required to complete an incident report documenting all offensive activity, all parties involved and the timeframe in which they occurred.
C.   Board of Directors will utilize employee’s data regarding an incident to determine whether any involved parties may be of threat to an individual’s safety. A measure of severity will be used to determine whether the incident warrants the involvement of local or Federal authorities.
D.   Midwest Millworks will provide training to employees and associates to ensure that all parties are educated on policy and procedure regarding corruption and bribery.