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July 15, 2004
Business Conduct
Policy – Questions or Concerns
Dear Republic Employees,
Critical to Republic Engineered Products success is the way in which
we conduct ourselves as we do business. Each of us must strive to
handle the business affairs of the Company in an ethical as well
as legal manner. Not only does the Company have a stake in your and
my proper conduct, but also to the extent any of us engages in illegal
activities we expose ourselves and the Company to criminal prosecution.
Thus, in an effort to remind us of what is expected of us by Republic
and also to clearly state what conduct will not be permitted or tolerated,
the attached Business Conduct Policy has been adopted. Republic's
Business Conduct Policy illustrates the shared accountability each
of us has in respect to conducting business with honesty and integrity.
In today's global market, it is often difficult to keep up with
the new challenges our organization faces or to adequately deal with
all complex situations. Nobody has all the answers. But we do know
that the best answers will evolve in an organization whose guiding
values are known, and where an environment is cultivated that supports
ethically sound behaviors.
You should never hesitate to ask a question or report a concern.
If you become aware of a situation in which you believe Republic's
ethical and legal guidelines have been violated or if you feel you
are being pressured or being asked to compromise your values, it
is your responsibility to communicate this concern to the Company.
It is important for you to know that you will not be disciplined,
lose your job or be retaliated against in any way for asking questions
or voicing concerns about our ethical or legal obligations, as long
as you are acting in good faith. Good faith does
not mean that you have to be right – but it does mean that
you believe you are providing truthful information.
There are a number of people you can contact to ask questions or
voice concerns. Your most immediate resource is your supervisor.
He or she may have the information you need or may be able to refer
the question to another appropriate source. There may, however, be
times when you prefer not to go to your supervisor. In situations
where you choose not to go to your supervisor, either because your
supervisor does not have the information you need or because you
desire confidential advice about an ethical or legal dilemma facing
you, the issue should be raised to the highest-ranking individual
at your facility. If you are uncomfortable with that, you can contact
the Vice President, Human Resources and Corporate Relations, who
has been designated as Republic's Ethics Officer (330-670-3007),
or the Ethics Hotline (800-582-0029). You can leave your message
on voicemail. You may, but need not, leave your name and/or telephone
number so the Ethics Officer can get back to you for more facts or
response. If you prefer, you can also leave a message via email to ethics@republicengineered.com (be
aware that the sending email address will be identified); or you
may send your issue via regular or company mail to Republic’s
Ethics Officer, c/o J. Willoughby in Fairlawn.
When you make a contact, this is what you can expect:
- Your report or concern will be taken seriously.
- The accuracy and completeness of your report will be investigated
by persons who are not in the chain of supervision over you.
Each report will be carefully evaluated before it is referred
for investigation or resolution.
- Your report will be handled promptly, discreetly and professionally.
Discussions and inquiries will be kept in confidence to the
extent appropriate or permitted by law.
- If you wish, you can obtain certain follow-up information
about how the Company addressed your report. In the event
that an investigation is initiated, employees have a shared
accountability to answer any questions truthfully and to
the best of their ability. Concealing or covering up an ethical
or legal violation is itself a violation of our guidelines.
If an individual engages in concealing or covering up such
violations, in the absence of significant mitigating circumstances,
the penalty for such conduct would generally be immediate
discharge. It also is expected that employees will cooperate
fully in an investigation if requested to do so. Failure
to cooperate could be construed as participating in concealment
or cover-up activities. Your cooperation is appreciated.
Sincerely,
John A. Willoughby
Vice President, Human Resources and Corporate Relations
Joseph F. Lapinsky
President and Chief Executive Officer
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