Code of Conduct

A. Introduction

Epic Piping, LLC, and its subsidiaries and affiliates (collectively, “EPIC”) is in the business of creating quality products and services for our customers. As an EPIC team member, employees are expected to accept certain responsibilities, follow acceptable business principles in matters of conduct, and always exhibit a high degree of integrity. This not only requires that employees conduct themselves in an ethical fashion, but also demands that employees refrain from any behavior that might be harmful, disrespectful, or intimidating to themselves, co-workers, EPIC, or that might be viewed unfavorably by current or potential customers or by the public at large. Employee conduct – both inside and outside of work – reflects on EPIC. This Code is a guide only and does not cover every possible circumstance, especially when issues arise with contracts or local laws that apply to you and EPIC. At some point you may face a situation where the right thing to do is not obvious. While the Code cannot answer every question, it can show you where to go for guidance when the answer is not clear.

Who Is Covered Under the Code

It does not matter where you work or what you do for EPIC – you have a responsibility to use good judgment and follow our Code. That includes every full-time or part-time employee at every level of EPIC, all the way up to and including executive management. All employees, and any others subject to the Code, must acknowledge that they have read and agree to uphold the Code.

When a Code Violation Occurs

When one of our employees fails to follow our Code or applicable laws, ignores someone else’s failure to follow the Code or pressures someone else to violate the Code, a violation has occurred. This can harm EPIC’s reputation and our business. We take all potential Code violations seriously. Code violations may lead to disciplinary action that matches the nature and circumstances of the violation, up to and including termination of employment. If an act violates the law, it could result in fines or criminal prosecution. Code violations are also documented in your employee record. EPIC has other policies and processes governing performance, conduct and behavior. Policy violations that are not Code violations will be handled under the appropriate policy or procedure.

What You Need to Do

As employees, each of us has as a responsibility to:

  • Follow the Code. Read it and follow it, along with any other policies that apply to your job.
  • Think before you act. Use good judgment, being honest and ethical in every action you take. If you are asked to violate the Code, do not do it. Report the concern as soon as possible using the resources available to you.
  • Follow the law. Understand laws that apply to your job and our business. If you are ever unclear about a law or regulation, contact the Legal Department. Ask for help. When an answer is not clear, ask for guidance before taking action.
  • Stay alert. Pay close attention to any activity that is inconsistent with our Code, our policies, or the law.
  • Report concerns. Do not ignore a violation. Prevent harm to EPIC and its reputation by reporting your concerns immediately.

B. Code of Conduct

1. COMPLIANCE WITH LAWS AND REGULATIONS

We comply with all applicable laws and regulations in the jurisdictions in which we operate. Employees are expected to seek advice from supervisors, managers or other appropriate personnel if they are unclear as to what they should do in order to comply with all applicable laws and regulations. If you observe or become aware that a law or regulation is being violated in the workplace, you should immediately report such violations bring the matter to the attention of his or her supervisor, who will be responsible for contacting EPIC’s Legal Department for appropriate guidance. In the event a law conflicts with a policy in this Code, you must comply with the law. No disciplinary or other retaliatory action will be taken against anyone for reporting a suspected violation of law, policies, or this Code.

2. HEALTH AND SAFETY

We are committed to maintaining a healthy and safe workplace for all employees. We must comply with the health and safety laws and policies that apply to our jobs and take proactive measures to prevent unsafe working conditions.

What you must do:

    • Protect your own health and safety and the health and safety of others in the workplace.
    • Speak up when you see unsafe work practices.
    • Take responsibility for getting the job done safely and efficiently.

We are all responsible for reporting unsafe working conditions. Report concerns about workplace health or safety to your supervisor, your safety specialist, Human Resources or the Legal Department.

3. CONFLICT OF INTEREST

Employees of EPIC should act in the best interests of EPIC. Accordingly, employees should have no relationship, financial or otherwise, that might conflict, or appear to conflict, with the employee’s obligation to act in the best interests of EPIC. A conflict situation can arise when an employee, officer or director of EPIC takes actions or has interests that may make it difficult to perform his or her work objectively and effectively or when an employee, officer or director, or members of his or her family, receives improper personal benefits as a result of his or her position in EPIC. Conflicts of interest are generally prohibited as a matter of EPIC policy. If any employee, officer or director finds himself or herself in a situation where a conflict of interest exists, may exist, or is perceived to exist, he or she should immediately bring the matter to the attention of his or her supervisor, who will be responsible for contacting EPIC’s Legal Department and/or Human Resources for appropriate guidance.

4. CORRUPTION, IMPROPER PAYMENTS AND BRIBES

We are committed to conducting business fairly and legally and oppose all forms of public and private corruption. We comply with anti-corruption laws and will not offer or pay improper payments or bribes to influence a business decision or gain a business advantage. We will not participate in illegal influence peddling by offering or accepting gifts, entertainment, travel, employment, charitable donations or other benefits to or from an intermediary to influence a government decision or gain a business advantage. We will not request or accept any bribe, kickback, commission or improper payment to award an EPIC contract or business to a third party. If you are asked to make an improper payment or bribe or offered a bribe or kickback to award an EPIC contract or business, immediately contact your supervisor who will be responsible for contacting EPIC’s Legal Department for appropriate guidance, and report the request or offer.

5. GIFTS, MEALS AND ENTERTAINMENT

Employees of EPIC are prohibited from accepting anything more than modest gifts, meals and entertainment from suppliers. Modest entertainment expenses or gifts of nominal value (pens, mugs, etc.) are permissible, but employees should not accept travel, frequent meals, or expensive gifts. Gifts of cash or cash equivalents, such as gift cards, are never allowed to be accepted by EPIC employees. If the acceptance of gifts, favors, or entertainment would have the appearance of influencing the employee or EPIC, they must not be accepted. Also, employees must not accept gifts, favors, or entertainment if they are not willing to have others know of the acceptance.

Specific rules apply when offering gifts, meals, travel, or entertainment to government officials. EPIC’s Anti-Corruption Policy strictly prohibits EPIC, and its officers, directors, employees and agents, from giving or offering money or anything of value to government officials in order to influence the official’s acts or decisions, to secure any improper advantage, or to obtain or retain business.

In all other cases, employees may offer or provide gifts, meals or entertainment to third parties only for legitimate business purposes, provided that it complies with the following guidelines:

    • Is not given as a bribe, payoff or kickback.
    • Does not create the appearance of impropriety.
    • Is in good taste and occurs at a business-appropriate venue.
    • Is reasonable and appropriate to the circumstances and your position at EPIC.
    • Is properly documented in EPIC’s books and records.
    • It meets the rules or code of ethics of the receiving organization.
    • It conforms to the laws of the country where it is made and any other applicable law.
    • Gifts of cash or cash equivalents (gift cards or gift certificates) are never appropriate and may not be offered.

6. EPIC RECORDS

EPIC business records must always be prepared accurately and reliably. We all handle EPIC “records,” from resumes, time sheets and benefit claim forms to expense reports, quality assurance records, and budget forecasts. Be sure to follow all internal processes, policies, and generally accepted accounting principles so that our records accurately reflect all transactions. Be honest, accurate and complete in what you record. Accurate record keeping and reporting helps us meet our legal and regulatory requirements. Maintaining financial integrity also reflects positively on our reputation and credibility.

Manage records properly. Never destroy or dispose of information that might be needed for an investigation, an audit or a legal proceeding. If you receive a legal hold notice, follow the guidelines in the notification. And, if you are not sure about what is required, check with Human Resources or the Legal Department.

7. PROTECTION OF NON-PUBLIC INFORMATION

We consider any non-public information about EPIC as well as certain information about our customers, suppliers, other business partners or consumers that you may have (or access) as part of your job, to be confidential information. Confidential information can be written, spoken or electronic.

What you must do or not do:

    • Do not share confidential information with friends or family or discuss it in public places or on social media.
    • Share confidential information only with those who have both the authorization to access it and are bound by a duty of confidentiality.
    • Take appropriate steps to protect classified information such as asking companies or individuals outside of EPIC to sign a confidentiality agreement before gaining access to our information.

If you are not sure whether information can be shared or how to share it, ask your supervisor who will be responsible for contacting EPIC’s Legal Department for appropriate guidance.

8. REPORTING ILLEGAL OR UNETHICAL BEHAVIOR

Maybe you sense that something is not right at work. Maybe you saw something or heard about an act that may violate our Code, our policies, or the law. If so, you have a responsibility to share your concerns by reporting right away – even if you are not sure that a Code violation has occurred. The Speak Up Hotline is available to report concerns at (225) 424-2999. You may choose to remain anonymous or identify yourself. You may also contact the EPIC General Counsel:

When you report concerns, you help us handle issues properly, fix problems before they occur and remedy situations that have already happened. You also help build trust with each other and with our customers, our suppliers and other business partners.

9. QUESTIONS AND INTERPRETATIONS OF THE CODE

This Code does not constitute a comprehensive, full, or complete explanation of all laws and regulations applicable to EPIC and its employees and does not include all of EPIC’s applicable policies and bases for discipline or discharge. This Code is intended to be applied globally to all of our business activities and corporate operations in accordance with the cultural, social, and economic differences in the various countries where EPIC operates. Where local laws and regulations contain mandatory requirements that differ from the provisions of this Code, such requirements will prevail. Any inquiries regarding the application of the Code, applicable law or other policies of EPIC should be directed to EPIC’s Legal Department.