SpeakUp for a Safe and Ethical Workplace

If you know of or suspect a violation of the Code of Conduct (“the Code”), local or international law, or any other policy of Paper Excellence and its subsidiaries (“the Company”), you are required to report it to any of the following contacts:

Your Supervisor or Manager
Your local Human Resources Manager
Our Compliance hotline

The Company takes all reports of possible misconduct seriously. We will investigate the matter confidentially, make a determination whether the Code or the law has been violated, and take appropriate corrective action. If you become involved in a Code investigation, cooperate fully and answer all questions completely and honestly.

No Retaliation Policy

The Company values the help of employees who identify potential problems that the Company needs to address. Any retaliation by another employee against an employee who raises an issue honestly is a violation of the Code. An employee who has raised a concern honestly, or participated in an investigation, cannot be subject to any adverse employment action, including termination, demotion, suspension, loss of benefits, threats, harassment or discrimination.

If you work with someone you suspect may have raised a concern or provided information in an investigation, you should continue to treat the person with courtesy and respect. If you believe someone has retaliated against you, report the matter to your Manager or Company Legal Counsel immediately.

Making False Accusations

The Company will protect the rights of any employee who raises a concern honestly, but intentionally making a false accusation, lying to investigators, or interfering with an investigation may result in disciplinary or legal action. Honest reporting does not mean that you have to have proof or be right when you raise a concern; you just have to believe that the information you are providing is accurate.

Basic Categories of Activities That Can Be Reported

Violations of the Code of Conduct and all applicable government laws, rules and regulations (including, but not limited to, the following):

Harassment of any kind.

Fraudulent acts or theft.

Bribery or corruption.

Risks to health, security, or the reputation of the Company.

Compliance with all applicable environmental legislation, regulation, and other requirements applicable to the Company.

Inaccurate reporting of any Company business or financial records.

Misuse of Company assets or information.

Unauthorized removal of Company product, equipment or information, or theft, through embezzlement or intentional misreporting of time or expenses.

Use of Company assets out of work or in an outside venture or using Company materials or equipment to support personal interests.

Engaging in personal activities during work hours that interfere with or prevent you from fulfilling your job responsibilities.

Use of Company computers and equipment for outside businesses or for illegal or unethical activities such as gambling, pornography, or other offensive subject matter.

Financial gains earned from knowledge due to a position at the Company or through the use of Company property or information.

Disclosure of non-public information to anyone outside the Company.

Conflicts of interest, such as: Investments that could affect, or appear to affect, one’s decision making on behalf of the Company.

Financial investment in a supplier, without prior written approval.

Employment outside of the Company, without prior approval.

Use the Company’s reputation or assets, including one’s time at work, to further your own political activities or interests.

Interaction with identified terrorist organizations or narcotics traffickers, individuals or companies that are sanctioned by any Government.

Inappropriate or preferential treatment during the staffing process, contractual awards to external parties, or any other exercise of responsibility.

Granting preferential treatment or advantages to family, friends, or any other person or entity is considered to give rise to a conflict of interest.

Engaging in any illegal or illicit activity to obtain competitive information.

Speak Up Form

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Incident Report Form:

Your email address*

We almost always have follow-up questions that need to be answered by you. Plus, we want to keep you updated on the progress of the investigation. Please provide your email address or create a new one just for this correspondence at: https://support.google.com/mail/answer/56256?hl=en-EN.

Your name (Optional)

Telephone number (Optional)

Describe the nature of your concern.*

Include sufficient information so that a person who is COMPLETELY unfamiliar with the situation can understand the concern.

Provide details with respect to the location and/or date of the incident and how you became aware of it.*

(e.g., region, event, specific location, department, etc.)

State the full name, title and role of each individual whom you suspect of wrongdoing.*

How many times has this incident taken place (if applicable)?

What approximate date did this behavior (incident, etc.) start happening?

Describe steps, if any, you took prior to completing this report

(e.g., discussing it with individual, informing supervisor).

Do you have any additional comments or suggestions about this form?

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Name

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