Under our Code of Conduct, we seek to conduct our business in accordance with the highest standards of business ethics at all of our locations, and we encourage employees to bring ethical questions to management’s attention so that we can maintain our high standards.

The common values of high business ethics that have characterized our approach to business throughout our history demand high professional standards, place a premium on integrity and fair dealing in relationships with customers, suppliers, employees and other persons with whom we have business relationships, and anticipate that we will compete vigorously and fairly in the markets we serve and comply with laws that affect our business.

The Code of Conduct also reinforces our commitment to the spirit and practice of equal employment opportunity and the benefits of a diverse workforce.

PennEngineering has a reputation for conducting its business on a highly ethical level.  It is important that we continue this record of integrity in the future.

Each and every employee of the Company, throughout all of the Company’s locations, is responsible for the maintenance of our fine reputation.  We expect that each employee will support the Company’s principles of business ethics and behave in a manner consistent with these high standards.  We also expect that no employee in a supervisory position will instruct a subordinate to violate the ethical guidelines of the Company.

Each of our employees is expected to comply with the law, and our Code of Conduct.  No list of rules can substitute for the exercise by anyone who represents our Company of common decency, high ethical standards and respect for the law.  If an employee is in doubt about the acceptability of a particular course of action, the following test should be applied: Assuming full public disclosure of the action, would both the employee and the Company feel comfortable form an ethical and legal standpoint?  If the answer is “Yes,” then the action is likely consistent with our Company philosophy.

In the unlikely event that an employee becomes aware of circumstances that appear inconsistent with our Code of Conduct, or the employee is instructed by a supervisor or manager to act in a manner inconsistent with our Code of Conduct, the employee should ordinarily bring the matter to the attention of his/her supervisor.  If, under, the circumstances, the employee feels he/she cannot approach his/her supervisor, or the matter is not resolved as a result of discussions with the supervisor, he/she should immediately contact the PennEngineering Director of Human Resources.  If the facts reveal that such a violation may have occurred, the Company will investigate the situation and take appropriate action.  

The Company is committed to protecting responsible employees who report violations of the Code of Conduct to management from reprisals or retribution.  On the other hand, an employee who participates in or conceals a violation of the Code of Conduct may be subject to disciplinary action, including the possibility of termination of employment.

We are an Equal Opportunity Employer.  We expect all of those who are responsible for making or influencing hiring, promotion or other career decisions for the Company to support our equal employment opportunity commitments.

We expect each employee to practice and promote high professional standards in carrying out his/her tasks and in his/her relationships with other employees, suppliers, customers, and other persons having dealings with the Company.

Excellence in supervision is expected, in a legal, moral, ethical manner and you should do the right thing every day as a valued member of the management team at PennEngineering You are expected to lead with integrity and be a role model for all you do.

Consistent with these standards, PennEngineering respects and supports the United Nations’ Universal Declaration of Human Rights. Specifically, the Company condemns all forms of forced and compulsory labor and will not do business with suppliers that use forced, prison or indentured labor or workers subjected to any form of compulsion or coercion or trafficking in person in violation of the US Government’s zero tolerance policy or other applicable laws or regulations.

Employees are expected to treat each other with dignity and respect.  The responsibility to treat employees with dignity and respect is particularly strong in the case of those employees whose position with the Company may enable them to influence the job security, compensation, promotion or career of other employees.  This responsibility includes, among other things, the responsibility to avoid conduct constituting unlawful harassment and discrimination and conduct demeaning to a person’s race, religious creed, color, gender, national origin or ancestry, physical or mental disability, medical condition (including genetic characteristics), marital status, registered domestic partner status, age, sexual orientation or any other basis protected by federal, state or local law or ordinance or regulation. 

We place a premium on honesty and fair dealing in relationships with and among our employees and in conducting our business activities.  Employees are expected to be truthful in dealing with others.  All factual reports or responses to questions provided within the organization or to outsiders (customers, suppliers, and financial institutions, governmental agencies of all kinds, other organizations and/or people with a need or right to receive information) are expected to be truthful, accurate and not misleading in any way.

Our products and services will be sold on their merits.  We will compete vigorously and fairly in the markets we serve.  We will afford our competitors the degree of respect that we expect them to afford us. Employees will not use improper or illegal methods to obtain information regarding our competitors.  We will not ask or encourage employees or prospective employees to divulge confidential information to which they may have had access as a result of associations with other companies. To avoid a violation of anti-trust laws, employees must not discuss any of the following topics with a competitor, directly or indirectly including prices, bids, sales, territory, terms or conditions, of sale, costs, profits or profit margins, and market share.

We are committed to providing safe working conditions for our employees, to promoting safe design, use and handling of our products and to complying with laws relating to protection of the environment.  Each employee is expected to promote these goals in carrying out his or her tasks.

In the course of performing their duties, employees may have access to personal, confidential information concerning other employees such as information appearing on job applications, salary information or other confidential information concerning the employee. Unless the employee chooses to disclose it or to discuss it with others, this information will be treated as confidential, used only for proper purposes, and divulged only to those having a “need to know”.

The Company’s tools, equipment, facilities and inventories, as well as its know-how, technology, market information and business plans, are all valuable assets.  It is the responsibility of every employee to preserve and protect the Company’s assets and confidential business information and to see that they are not misused or made available to outsiders in any fashion that could be detrimental to the interests of the Company or our clients.

No Company employee will place himself or herself in a position where his or her loyalty to the Company becomes divided such as due to a financial interest in a competitor, supplier, or customer.

Employees may entertain customers, suppliers and other persons, and may be entertained by such persons, in a manner that is customary and necessary for conducting business and is consistent with the Company’s policies.

PennEngineering forbids its employees to make illegal bribes, gifts, or kickbacks intended to secure favored treatment for the Company from customers, suppliers, or others. This rule also applies to the use of intermediaries to make such payments. Any employee who finds themselves in a situation calling for payments which might be construed as illegal bribes or kickbacks must so advise their supervisor and/or the Director of Human Resources. 

The acceptance of gifts from suppliers, customers or others having business dealings with the Company may involve a conflict of interest or create an appearance of impropriety.  Accordingly, Company employees shall not accept any cash payments from persons having a business relationship with the Company.

Employees may accept reasonable non-cash gifts having a token or nominal value from any company or individual which has, or might have, a business relationship with the Company provided that they are not intended and cannot be construed as a bribe, kickback, or other form of compensation to the recipient.

The Company makes no political contributions anywhere in the world.  The Company encourages its employees to exercise their individual rights to be active in local or national politics, however no political postings of any nature will be allowed on Company property.

It is our policy to comply with the laws that affect the conduct of our business. It is the responsibility of each employee to have a familiarity with the principles of law that affect the performance of his/her job, to assist the Company in complying with the law, and to seek the advice of the employee’s supervisor or the Director of Human Resources if the employee is uncertain of relevant legal principles.

And we will be mindful of the communities in which we operate and be a part of those communities by supporting local charities, allowing employees to volunteer for fire and rescue services, providing support to local school systems in an effort to encourage the diverse skills needed in a manufacturing environment, etc.

And finally, we will be mindful of the environment at each of our locations and will help preserve and conserve our precious resources. We will conduct our business in an environmentally responsible way managing our facilities in compliance with all environmental laws, rules and regulations, providing management oversight of environmental practices and minimizing the creation of waste, especially hazardous  waste, and disposing of all waste in a safe and responsible manner. We will make all effort to avoid a situation which might lead to an environmental problem, but should a problem occur, we will act immediately with our own personnel and local and state authorities to mitigate the effects of any such problem. We abide by all OSHA standards and environmental laws in all countries that we do business.  Not only do we hold ourselves accountable to the principles set forth in this code, but it is our expectation that our customers and vendors hold these same standards.

The guidelines set forth above cover some, but by no means all, of the situations that might arise.  Periodically, the Company may elaborate upon particular issues in separate policy statements and may adopt additional or amended guidelines.