Turning Ethics Into Action: Ethics and Integrity Defined
The following principles define our core value of ethics and integrity:
We tell the truth. If we make a mistake, we do not try to hide it. We behave so that all of our stakeholders can rely on us to do what we say we will do. Whether preparing a financial report, responding to a question from auditors, talking to a customer or dealing with a supplier or other stakeholder, we are always truthful. We refrain from any conduct that is questionable on ethical grounds.
We buy and sell based on our business merits without unethical practices. We understand that our Company’s business interests, opportunities and information belong to Timken and should only be used in the Company’s best interests. We avoid conflicts of interest. We always advance the Company’s legitimate business interests when the opportunity to do so arises.
We treat each other with dignity. We operate safely with environmental responsibility and respect our fellow associates, our suppliers, our customers and the communities where we operate.
We are guardians of The Timken Company’s outstanding reputation for ethics and integrity. We act responsibly, exercise sound judgment and do what is necessary to preserve and enhance that reputation. We do not wait for others to tell us what we need to do. We follow our Standards of Business Ethics and understand how the law affects our actions.
The Timken Company’s Standards of Business Ethics Policy, our Code of Conduct
The Standards of Business Ethics policy, our Company’s code of conduct, is the foundation of our outstanding reputation for ethics, integrity and respect for the law. It is the framework for Turning Ethics Into Action in our workplace, with our customers and shareholders, and in the global community. The policy contains the moral and ethical standards by which each associate, officer and director of the Company and its subsidiaries is to conduct the business activities of The Timken Company. Our code of conduct is available in all of the languages in which we conduct business.
We Are All Responsible for Turning Ethics into Action
All of us must act according to the principles set forth in our code of conduct, the Standards of Business Ethics policy. We also expect everyone working on our Company’s behalf, including consultants, agents, suppliers and business partners, to adhere to our ethical standards.
Applying for Waivers
If you feel a waiver of this policy is necessary or appropriate, including but not limited to any potential or actual conflict of interest, you may submit a request for a waiver and the reasons for the request to the Company’s ethics and compliance office at firstname.lastname@example.org. Any waiver of this policy for executive officers and directors may be made only by the board of directors or the nominating and corporate governance committee of the board and will be promptly disclosed in accordance with applicable law and rules of the New York Stock Exchange.
Reporting Concerns and Seeking Guidance: Our Open Door Policy
See Something? Say Something!
At Timken, Turning Ethics into Action is everyone’s responsibility. To help protect our Company’s values and reputation, speak up if something just doesn’t seem right or when you have a question. Customers, suppliers, and other third parties with whom we interact, may contact one of our ethics reporting resources. These include:
When Should I Say Something?
Examples of situations you should report:
- Questionable accounting or auditing matters
- Inappropriate gifts or gratuities
- Environmental, health or safety concerns
- Conflicts of interest
- Theft of company or personal property
- Discrimination or harassment
- Verbal or physical threats
- Product quality concerns
- Regulatory violations and insider trading
How Reports Are Handled?
We investigate all reports promptly, thoroughly and fairly, and take appropriate action whenever necessary. We expect associates to participate in such an investigation when asked. Keep in mind that every effort is made to safeguard confidentiality both during and after the investigation.
You should never fear retaliation. Our Company does not tolerate acts of retaliation for any legally protected activity against anyone who makes a good faith report. Making a report in “good faith” means that the information you provided is complete and accurate, and you believe it to be true. Retaliation against anyone who participates in investigations in good faith is also prohibited. Such acts may lead to disciplinary action against the person responsible for the retaliation, up to and including termination. If you believe you have experienced retaliation, report it to one of the available Ethics Reporting Resources immediately. Anyone making a report not in good faith may also be subject to disciplinary action.
Our Company recognizes that there may be times when you might be reluctant to discuss concerns or questions with your supervisor or manager or other company leader. For this reason, the Timken HelpLine is available online and via telephone. The Timken HelpLine is answered by an external third party and the reports are investigated by an independent representative from our Company. Reports made to the Timken HelpLine are not traced or recorded. We encourage you to report your concerns, sharing as much information as possible, including your name, so that we can conduct a thorough investigation. However, even if you are not comfortable sharing your name, your report is still valuable. Therefore, you may choose to submit it anonymously, where allowed by local law. If you do so, you will receive a reference number to check the status of your report.
You may contact the Timken HelpLine by telephone or submit a report online at www.timkenhelpline.com.
A Proud TRACE Corporate Member
Timken is dedicated to ensuring transparency in all business transactions. As a member of TRACE,