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2017 SUSTAINABILITY REPORT

Ensuring a culture of responsibility,
integrity and accountability across
our organization and promoting
ethical behavior.

Ethics & Compliance
“Doing the right thing” is central to who we are as a company. It drives our decision making at all levels and it is a non-negotiable element of what we expect from our employees. From senior management to entry-level employees at our subsidiaries, the ultimate responsibility for ethical behavior and compliance with the ESCO Code of Business Conduct & Ethics resides with each and every one of our employees.
Management of Ethics and Compliance

Instilling a culture of ethical decision making and compliance with our expectations and applicable regulations begins with high-quality training. ESCO and its subsidiaries provide information and training programs that include:

Each year every employee receives a copy of the Code of Business Conduct & Ethics and certifies by signature that they have received the handbook and read the contents. We also require employees to watch an ethics training video reinforcing our principles. We are currently producing a new, updated ethics video that includes a general overview of our Code and contains interviews with our CEO, General Counsel, and Vice President of Human Resources. The new video will be closed captioned in languages appropriate to our locations and will replace our current ethics training video and be required viewing for all our employees.

For day-to-day management of our Ethics program, we have a host of personnel providing guidance. These include ESCO’s General Counsel, Vice President of Human Resources, the ESCO Ethics Ombudsman and ESCO Corporate Ethics Committee as well as Ethics Officers at each of our subsidiaries. Our employees are encouraged to direct any questions to anyone within the chain of command at their subsidiary, their local Human Resources departments, local Ethics officers or any of the ESCO employees listed above. There is also a confidential, anonymous Ethics Hotline. We believe that providing multiple channels for points of contact makes it more likely that employees will raise potential ethics concerns. Our CEO discusses the importance of ethics at every employee presentation and stresses his expectation for all employees to conduct business with the highest ethical conduct and to raise any issues. The ESCO Corporate Ethics Committee meets regularly, reviews every issue raised and provides regular reports to the Board.

Additional information and specifics regarding mechanisms for employees to report concerns regarding ethics issues, and general information about the policies and codes that guide our work include:

In 2018, we will continue to align all ethics-related requirements and training to ensure consistency in enforcement across all ESCO operating units and subsidiaries. Particular attention will be given to integrating recently acquired subsidiaries into ESCO’s systems and culture regarding ethics and compliance.


Ethics Across ESCO

The ESCO’s Code of Business Conduct and Ethics outlines expectations in the following areas:

  • Prohibition of conflicts of interest
  • Protection and proper use of ESCO assets
  • Duty to act with integrity and deal fairly when representing the company
  • Prohibition of improper political payments
  • Duty to comply with applicable laws including insider trading, antitrust, export controls, trade embargoes
    and anti-boycott
  • Duty to ensure all public disclosures by the Company are full, fair, accurate and timely as required by securities laws and to maintain accurate financial records
  • Duty to comply with applicable employment and safety policies
  • Duty to report suspected non-compliance

Many of our subsidiaries manufacture products or operate in sectors that are subject to a high-degree of regulation and oversight. Some products are prohibited from being exported to certain parties or countries, thus requiring a high-level of control and diligence to ensure compliance with all applicable regulations. Each subsidiary is responsible for recognizing the regulatory landscape in which it operates, and for understanding the requirements that it must meet to stay in full compliance with all applicable laws related to its industry and products. For subsidiaries who ship products internationally, each has designated personnel who are responsible to stay abreast of applicable laws, manage exports and screen shipments against appropriate “denied party lists” to ensure ESCO products are not sold to ineligible customers.

ESCO subsidiaries also have processes and procedures to perform appropriate due diligence and vetting of their suppliers and third-party sales agents to ensure that such business partners operate their businesses with the highest ethical standards. These processes may include site visits, background checks or other actions necessary to verify the qualifications and integrity of such business partners. These business partners are also required to sign the ESCO Vendor of Business Conduct and the ESCO Anti-Bribery and Foreign Corrupt Practices Act Compliance Policy, as applicable.


Corporate Resources

Corporate Resources


Code of Ethics for
Senior Financial Officers

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