Miriam V. Gold
March 30, 2009
Riordan Manufacturing recognizes that being a global plastic producer involves significant legal and ethical responsibility. This responsibility extends not only to their consumers, but also to the many companies and agencies Riordan works with, as well as fellow employees, and indeed, the public at large. The following Compliance Plan was adopted as a guide for each employee’s conduct so that Riordan may fulfill its obligations to observe the laws and public policies affecting its business; and to deal fairly with Riordan employees and communities it operates in. This Compliance Plan will contain resources to help resolve any question about appropriate conduct in the work place, as well as provide guidance which will ensure that our work is done in an ethical and legal manner. For the Compliance Plan to be effective, it must have the cooperation of all employees. Your adherence to its spirit, as well as its specific provisions is absolutely critical to Riordan’s future.
Directives for Key Personnel
The effectiveness of the Compliance Plan depends largely on the leadership efforts of key personnel at Riordan. The officers and directors of Riordan must ensure that those on their team have sufficient information to comply with the laws, regulations, and policies, as well as the resources to resolve ethical dilemmas. It is the responsibility of the key personnel to create a culture within Riordan which promotes the highest standards of ethics and compliance; Riordan expects its leaders to set an example and be in every respect a model. We must never sacrifice ethical and complaint behavior in the pursuit of business objectives. The key personnel of Riordan will be held responsible for ensuring and accomplishing the following goals:
•Maintain compliance standards and procedures reasonably designed to reduce the risk of criminal conduct and other violations •Never to delegate discretionary authority to any individual whom it knows, or through the exercise of due diligence should have known, had a propensity to engage in legal activities. •Always to take reasonable steps to communicate effectively in order to achieve compliance for all employees, consumers, and companies and agencies Riordan works with. •Implement and maintain monitoring and auditing systems that are reasonably (without the fear of retribution) designed to detect unethical/wrongful behavior or criminal conduct by employees and other third parties that Riordan works with. •Cooperate to the fullest extent reasonable and practical with appropriate federal, state, and local authorities investigating a potential violation of law; never to conceal, destroy, or tamper with evidence.
Reporting Potential Compliance Plan Violations
It is Riordan’s desire for the Compliance Plan to aid in the identification and correction of any actual or perceived violations of any applicable rules and regulations. In order to attain this goal, the Plan imposes a duty on all employees to report to designated individuals listed below. 1.Compliance Officer
2.Director of Human Resources Yvonne McMillan (YM@Riordan.com ) 3.Safety Manager Chad Sterkin (CS@Riordan.com )
4.Employee Relations Manager Andrea Gamby (AG@Riordan.com ) Corporate Compliance Officer - responsible for overseeing the Corporate Compliance Plan; reviewing agency policies and procedures, recommending changes or new policies and procedures; overseeing administration of agency risk assessment relative to Compliance issues and recommending changes in procedures as a result of Risk Assessment; developing and implementing internal audit procedures relative to Corporate Compliance issues; maintaining a library of regulations, agency policies and procedures; Overseeing the implementation of Corporate Compliance training program, including conducting of training sessions for staff; investigating matters...