Ethical policy
Ethical policy

Purpose
Trillium US Inc. is committed to responsible corporate behavior. This governs the way we interact with our key stakeholders: customers, business partners, shareholders, employees, suppliers and the setting in which we operate, including governments, society, local communities, and the environment. The Company’s reputation, together with the trust and confidence of those with whom it deals, is one of its most valuable assets. It is therefore essential that all employees accept responsibility for maintaining Trillium's excellence in this area. Trillium's corporate values, which include Integrity and Responsibility, must underpin all that we do. The policies that we have in place, which provide guidance on the ethical standards by which we operate, must be adhered to. This code is not expected to cover every ethical circumstance so we ask employees to seek advice from their Team Leader/ Manager if they are in any doubt.

Our Customers
We believe that integrity in dealing with customers is a prerequisite for a successful and sustained business relationship. This principle governs all aspects of our approach. We value our customers and the trust that they place in us. We will safeguard the information provided to us by our customers in accordance with relevant laws and contractual commitments. We are honest about the products and services we provide and would never intentionally misrepresent these.

Our Business Partners
We are committed to establishing mutual trust and mutually beneficial relations with our business partners e.g. suppliers, banks, collaborative associates, etc. In our business dealings we expect our partners to respect our business principles and in turn, we respect theirs. Protecting intellectual property would be an example of this.

Our Shareholders
We will provide timely and accurate information to all shareholders on our activities and performance. To deliver shareholder value we will use our assets wisely and maintain these with the utmost care and respect, guarding against waste and abuse. We will be cost-conscious and alert to opportunities for improving performance whilst reducing costs.

Our Employees
Relations with our employees are based on respect. We are committed to a working environment where there is mutual trust and respect and where everyone is accountable for their own actions and believes themselves to be responsible for the performance and reputation of our Company. We aim to recruit, employ and promote employees on the sole basis of their ability and are committed to developing and enhancing each employee’s skills and capabilities. Our policies are designed to provide employees with safe and healthy working conditions and practices, and to enable everyone to work free from discrimination, harassment or bullying of any kind. In return we expect our employees to act with integrity and maintain high ethical standards.

Conflicts of Interest
The receipt of gifts or favours can give rise to embarrassing situations and may be unlawful. Employees must not compromise either themselves or the Company in the conduct of Company business. The following principles should be applied: gifts or favours must not be solicited gifts of money must never be given or accepted reasonable small tokens and hospitality may be accepted provided they do not place the recipient under any obligation, do not breach any applicable law and are not capable of being misconstrued. If an employee receives a gift or offer of hospitality their Team Leader/Manager must be notified to ensure that acceptance is appropriate. Employees cannot engage in an activity for personal gain that is in conflict with the Company’s business interests or applicable law, and must disclose to the Company any personal interest, or interests of their immediate family that could create a potential conflict of interest.

The Environment
We are committed to making continuous improvements in the management of our environmental impact as part of our goal of developing a sustainable business. Indeed many of our products support other organisations in doing this. We work to promote environmental care and awareness, with emphasis on the need to reduce energy consumption and waste production. Action being taken includes recovery of helium gas, recycling of materials, using timing switches to reduce energy consumption and reducing the need to travel -for example, the installation of video conferencing equipment. We monitor and report on environmental issues and compliance with local legislation.

Compliance with the Law and Corporate Governance
We will conduct our operations in accordance with accepted principles of good corporate governance. Financial advice involving investment in the Company must not be given by or to employees. Through our insider dealing policy we comply with the Financial Services Authority “Listing Rules” and inform our employees of their responsibilities and the restrictions on dealing these require. Information received by employees in the course of business dealings cannot be used improperly for personal gain or for any purpose except that for which it was given. All employees have the right and the responsibility to resolve doubts or uncertainties about ethical questions or compliance with the law. We also strongly encourage an “open door” policy to bring any such queries, if necessary, to a higher level of management. All employees have a responsibility to protect the assets of the Company. Specific relevant information from a third party should be immediately reported. The Company is stronger if we all have zero tolerance attitude towards malpractice. We all have a duty to the Company and our fellow workers to report any suspicions that we have (e.g. unusual behaviour, non-adherence to procedures) which will then be investigated fairly. It is the Company's policy to prosecute any employee who takes the Company's assets for their own benefit. Additional guidance on these areas is detailed in our internal Reporting a Business Malpractice Policy. At all times, it is our policy to stay within the laws, rules and regulations of the countries, states or other jurisdictions in which we operate. It is our policy to co-operate fully with relevant public authorities and regulatory bodies as appropriate.