Our 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

Text Box: What is a “bribe”? It includes money, a favor or anything of value used to influence the judgment or conduct
of a government official or to ensure a particular outcome or action.
Remember,
a bribe does not have to be cash. It also includes lavish entertainment, such as paying an inflated price to purchase a
government official’s property or services, or making a donation in a government official’s name.
Who is considered
a “government official”? This term describes federal, state and local government employees, political candidates and employees
of government- or state owned businesses.
What is a “kickback”? It is the return of a sum already paid or due to be paid
as part of a legal contract as a reward for making or fostering business arrangements.

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 products, services and technology may not cross borders or transfer between particular citizens of different countries.

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 the import.

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 common examples:

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 orders.

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.