Tracking Innovations Commitments to Our Communities
We are all encouraged to work to make a positive difference in the communities where
Tracking Innovations does business. This includes involving ourselves in political
activities and causes, as well as working to protect our environment. Most importantly,
it means operating as good citizens of our global community and following the international
laws that apply to our work.
Following Anti-Bribery Laws
Bribery negatively affects not only our business, but also the communities where
we live and work. For this reason, our Company has enacted a zero tolerance policy
for all forms of bribes and kickbacks. In short, this means we can never offer,
authorize, give or promise a bribe or kickback when conducting business on behalf
of Tracking Innovations, regardless of whether we are dealing with a government
official or a commercial customer. In addition, we may not engage a third party
to perform any such activity on our behalf.
We have an obligation to strictly follow all anti-bribery laws, such as the U.S.
Foreign Corrupt Practices Act (FCPA), that apply to our Company’s operations globally.
These laws dictate that we may not offer, authorize, give or promise a government
official any form of bribe or kickback.
A situation may occur where you are asked for a “facilitating” or “grease” payment
to expedite routine government services under certain circumstances. While some
local laws and customs may allow this practice, Tracking Innovation’s policy strictly
prohibits all such payments.
The consequences for violating anti-bribery laws are severe, including fines for
both the individual making the payment and our Company, as well as possible jail
time for the individuals involved. Be sure to raise any questions or concerns you
may have regarding anti-bribery laws with our CIO.
Complying with Trade Controls
As our work expands outside the United States, we must ensure that we strictly comply
with all restrictions affecting international trade. This includes import and export
control laws and trade sanction rules. These laws and rules dictate that certain
and technology may not cross borders or transfer between particular citizens of
In order to comply with these laws and rules, we must abide by all licensing and
customs requirements. This means that, prior to importing a product, service or
technology; we must always verify whether it is subject to any prohibition or restriction.
In addition, we need to ensure exact recordkeeping of specific information concerning
In exporting situations, we must first verify that the recipient is eligible to
receive the item in question. We must also ensure that we screen our customers,
contractors, vendors, agents and representatives against applicable government lists
of parties restricted from trade.
Because we work for a U.S.-based company, we must refrain from participating in
foreign boycotts that the United States does not support. An example of a non-sanctioned
boycott is the Arab League Boycott of Israel. These anti-boycott provisions apply
to interstate or foreign commerce activities, as well as to transactions that occur
entirely outside of the United States. Prohibited conduct includes the following
- Refusing or agreeing to refuse to conduct business with a boycotted country
- Agreeing to terms or conditions in contracts or lettersof credit that state that
boycotted vendors will not be used
- Furnishing a letter of credit that states that a shipment contains no items made
in or originating from a boycotted country
- Declining for boycott purposes to consider a financial or commercial opportunity
in a boycotted country Requests to participate in a boycott may be subtle and often
appear in letters of credit, contracts, requests for quotes or bids, and purchase
Report any request to participate in a boycott to our CIO or EthicsPoint immediately.
Practicing Environmental Stewardship
As good corporate citizens, we must comply with the environmental laws, rules and
regulations in effect in the locations where we do business. In addition to meeting
these requirements, we look to exceed them whenever possible. To reduce our environmental
footprint, we constantly strive to maximize the efficient use of natural resources
during our workday and when designing our business products and processes. Submit
any suggestions and ideas regarding ways to bring our practices closer to these
goals to our CIO.
Engaging in Political Activities
Each of us is encouraged to be active in our communities by becoming involved in
political activities. However, when engaging in personal civic and political affairs,
we must be clear that our views and actions are our own, and not those of our Company.
We may not use our Company’s resources (including work time) to support political
parties, causes or candidates, or to promote our personal political views.