WHY MANAGING IT MATTERS

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Ethics, anti-corruption and transparency are the foundation of our strong, sustainable company. As a signatory to the United Nations Global Compact (UNGC), Southwire fully supports Principle 10—Businesses should work against corruption in all its forms, including extortion and bribery. Further, customers compare suppliers according to their own standards or compliance requirements. By operating in an ethical, transparent manner in all our operations globally, we earn our license to operate and minimize risk to our company’s reputation. We expect all our business partners to operate according to our ethical standards.


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Southwire monitors and mitigates risks—both within our business and beyond our operations—by providing robust ethics training to employees, engaging suppliers and adhering to and creating policies to support standards. Our leadership espouses the highest levels of integrity, and employees follow their example. In July 2017, Southwire became a UNGC signatory, providing the company with additional access to best practices and industry experts for ethics, as well as strengthening our commitment to ethical business practices. Read about Southwire’s governance structure and practices. Through our ethics, anti-corruption and transparency, we are strengthening our business while Doing Right.

2021 Sustainability Goal & Target

In 2017, we launched a new goal related to ethics and transparency to ensure the highest standard of ethical business practices within all our operations by achieving recognition on Ethisphere’s World’s Most Ethical Companies list by 2021. Southwire finds it important to have an independently vetted, objective measurement of corporate responsibility and business ethics. Benchmarking against the World’s Most Ethical Companies will inspire and inform advancement in our business practices. In this 2017 Sustainability Report, we provide our first progress report on this goal.



2021 SUSTAINABILITY GOALS & TARGETS

Achieve best in class safety performance at Southwire
2021 Target 2017 Progress
Achieve recognition on Ethisphere’s World’s Most Ethical Companies list by 2021 Completed benchmarking survey with Ethisphere
Communicated status of report to management and convened a team of experts to prioritize strategic initiative and action plans to address areas of opportunity and process improvements

Standards of Conduct

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We demonstrate our commitment to ethical business practices by publishing and providing all employees with an uncompromising ethics statement. Our chief executive officer introduces Southwire’s code of ethics through a 10-minute video during new hire orientation. The Standards of Business Ethics and Conduct outline Southwire’s mission, business philosophy, values and standards. We continually review our Standards, with a plan to provide an updated version in 2018.

Training

Ethics Training

At Southwire, we strive to go beyond compliance requirements. Salaried and hourly employees receive annual ethics training to remain familiar with our ethical code and compliance topics, such as bribery and anti-trust. During our biennial ethics refresher meeting, we share examples of practices that technically comply with the law but do not live up to our values or the spirit of the law. We emphasize that these scenarios conflict with our culture and can undermine our stakeholders’ positive view of Southwire.

As Southwire continues to grow through acquisitions, ensuring aligned codes of business ethics with the acquired companies will help Southwire maintain customer and supplier relationships and the company’s brand and reputation. In 2017, we adopted a policy to train all new employees who join the company in connection with an acquisition on our policies including anti-corruption and ethics.

Anti-Corruption Training

We firmly reject any corrupt business activity and take measures to ensure our business activities advance internationally without ethics incidents. Southwire provides anti-corruption training to executives and other salaried employees based outside the U.S. (particularly beyond North America). Further, we require mandatory training for all employees who travel abroad for business purposes to prepare them for possible encounters with corrupt activities. We conduct training in our employees’ native language to ensure clarity. This training includes safety protocols which, combined with our travel policies and procedures, allows us to track the locations of our employees as they travel and to swiftly extract an employee in the case of an in-country emergency.

Reporting Ethics Concerns

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Southwire completed implementation of an online Code of Ethics training and conducted an employee survey for all salaried employees. All individuals are asked to indicate if they are aware of any ethics violations. Employees and stakeholders may report any ethics concerns to supervisors or our legal department via hotline or email. In the U.S., these reports can remain anonymous. Southwire thoroughly investigates all indications of ethics violations. For a company of our size, historically we have had few incidents, violations or litigation.

Holding Suppliers Accountable

To demonstrate our commitment to ethical business along our supply chain, Southwire enforces our conflict minerals and human trafficking policies, both of which are publicly available on our corporate website. Additional detail about our supplier policies and programs can be found here.

“I’ve never worked with a company with higher ethics and integrity.”- Southwire Supplier, 2017

Transparency

Southwire believes in providing accurate and transparent reporting regarding company performance, challenges and opportunities for improvement. By continuing to communicate via our annual sustainability report and other channels, Southwire will further build support and respect for the company.

For greater transparency, we engage our stakeholders in a variety of ways. In the infrequent case of a spill or other release to the environment, Southwire notifies the appropriate regulatory authorities and informs leadership via text and email as soon as possible, as well as its board of directors at regular board meetings. In the case of a high-visibility event, we will inform the public via local press releases.

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2017 Regulatory Actions
Date Location Incident Actions Taken Monetary Value
March 2017 Denton, Texas Letter of Non-Compliance from the City of Denton for copper discharges to the sanitary sewer in excess of their permit limit. The plant is investigating the cause of the violation and will take the necessary steps to eliminate the potential for future exceedances. $0
September 2017 Carrollton, Ga. Notice of Violation by the Georgia Environmental Protection Division related to two air permit deviations:

  1. A temperature monitoring system was out of service for 5.75% of the operating time during the reporting period, which exceeded the 5% acceptable threshold.
  2. An electrical failure triggered the startup of an emergency generator, and the unit could operate in excess of the 100-hour annual limit.
Impact to the environment was minimal in both cases.
  1. The monitoring system has been replaced with redundant backups to prevent a recurrence of this deviation.
  2. The electrical issue has corrected, and new procedures have been implemented to prevent excessive engine run time in the future.
$0
October 2017 Houston, Texas Notice of Violation by the Harris County Pollution Services department related to a sanitary sewer discharge event. Remediation of the affected areas was conducted immediately, and a plumber was contracted to address the broken clean out caps. Weekly inspections were initiated to ensure no discharges have occurred or are occurring. $0

We are pleased to report that Southwire paid no fines for non-compliance in 2017. For more information on other regulatory actions in 2017, click here.