Introduction
Tracking Innovations is committed to the pursuit of excellence and to our shared
values—the principles on which our Company was founded. Our Code is designed to
guide each of us as we strive to do business in accordance with these values and
the law. Our Code is structured around our commitments to our Company; our customers
and business partners; our communities and each other. Upholding these commitments
should be at the heart of every business action we take.
Our Code applies to all Company associates, officers and directors. To ensure ethical
and legal practices throughout our Company’s operations, we seek out vendors and
other business partners who share our values and uphold our Code in the work they
do on our Company’s behalf.
It is vital that we know and comply with the various laws and regulations that apply
to our work. We should also keep in mind that, depending on our job function and
the locations where we are doing business, local practices may differ from our Code,
Company policy or U.S. law. If this is the case, seek guidance from our Chief Information
Officer (“CIO”) before acting.
Additional Expectations for Managers
Managers must make a special commitment to uphold our Code. If you are a manager,
you are expected to model integrity and our values for the associates who report
to you at all times. Ensure that your conduct complies with applicable laws and
regulations, as well.
Managers have additional obligations that go beyond upholding our Code, our values
and the law. If you are a manager, you are also expected to communicate frequently
with associates about ethics and compliance. Engaging in such dialogue creates a
positive work environment in which asking questions and reporting concerns is accepted
and encouraged. Always take reports or questions regarding ethical or legal misconduct
seriously and ensure that associates’ concerns are properly resolved. If you become
aware of a legal or ethical issue in the workplace, whether through a rumor, personal
observation or a report, you need to take appropriate steps promptly. If you are
unsure how respond, contact our CIO for guidance as soon as possible.
Seeking Guidance and Reporting Concerns
In the course of doing business for our Company, you may face a dilemma or suspect
legal or ethical misconduct. In these situations, you have a duty to your fellow
associates and our Company to seek guidance or make a report. Consider discussing
the situation first with your manager or department head. These people know you,
are familiar with the work you do and are likely best equipped to resolve the situation
you face.
However, if you feel uncomfortable discussing the issue with your manager or department
head, or if doing so is impracticable or does not lead to an adequate resolution,
please contact any of the following resources:
• Another manager
• Our CIO Randy Kraft in person, or via email at rkraft@trackinginnovations.com
• Our Chief Executive Officer (“CEO”) Lori Alf in person, or via email at lalf@trackinginnovations.com
• The EthicsPoint hotline by telephone at (877) 254-1702 or online at www.ethicspoint.com The EthicsPoint hotline is operated by
an independent company and is available 24 hours a day, 7 days a week for you to
seek guidance or make a report. You may make an anonymous report where local law
allows. However, please remember that maintaining your anonymity may limit our Company’s
ability to undertake a full investigation of your report.
Non-Retaliation Policy
Anyone who reports actual or suspected misconduct provides our Company an opportunity
to respond to the issue before it becomes a larger problem. Our Company values and
respects associates who report misconduct in good faith and has made a commitment
to protect them from any acts of retaliation. You make a report in “good faith”
when you provide all the information you have and believe your report to be true.
Our Company will also protect from retaliation anyone who in good faith participates
in an investigation of a report.
Investigating Reports and Handling Violations
Tracking Innovations takes all reports of illegal or unethical behavior very seriously,
responding to all reports quickly and conducting thorough investigations when necessary.
We must participate in the investigation of reports, as requested. All reports will
remain confidential, consistent with local law and proper resolution of the issue.
Disciplinary Action
If conduct is determined to be in violation of our Code, Company policy or the law,
the individuals involved will be subject to disciplinary action, up to and including
termination. Keep in mind that, if the conduct violates applicable laws or regulations,
those involved may also be subject to civil and/or criminal liability.