1. Policy

The “Code of Conduct for Business Partners” is a policy, or document, explaining how anyone doing business with or on behalf of Titan is expected to behave.  It’s about “doing the right thing” in general – following the law, acting honorably and treating others with respect.

2. Scope of Policy

This policy applies to anyone doing business with or acting on behalf of Titan, worldwide.

3. Business partners / Third parties / Counterparties

By “business partners” means any individual or organization Titan deals with during planning or doing business, anywhere in the world.

This include (but is not limited to) actual or potential suppliers, customers, agents, logistics providers, joint venture partners, contractors, sub-contractors, brokers, distributors, banks, financial institutions, professional advisors (such as lawyers and accountants), government and public bodies (including their officials, representatives, politicians, and political parties), directors and interns, among other.

4. Trade compliance and Sanctions

Trade compliance refers to the actual business transactions and involve following regulations regarding sanctions, anti-bribery and corruption, tax evasion and money laundering, human rights, and the environment, among other things. Sanctions are restrictions put in place and enforced mainly by the US, the EU and the UN. Some sanctions prohibit doing business with specific countries, while some prohibit doing business with certain persons or certain products. Business should not be conducted with any sanctioned party, including re-selling or diverting products to sanctioned parties or territories.

5. Bribery and corruption

To offer a bribe means offering something of value to a business partner, with the condition of doing business.

To receive a bribe means receiving something of value from a business partner, with the expectation of a benefit in return.

‘Something of value’ could include money, gifts, loans, fees, hospitality, services, discounts, the award of a contract or anything else of value.

It is a criminal offence to offer, promise, give, request or accept a bribe.

Corruption is the abuse of entrusted power or position for personal gain.

Titan is committed to, and require its Business Partners to, comply with national and international anti-bribery and corruptions laws around the world, including but not limited to, the Foreign Corrupt Practices Act of 1977 (“FCPA”) and the “UK Bribery Act 2010”.  These laws can apply to acts wherever in the world they take place and irrespective of local standards or cultural norms.

6. Business gifts, entertainment, and hospitality

Neither Titan nor its Business Partners will give, promise, offer or pay gifts, entertainment or hospitality with the expectation or hope that a business advantage will be received or to reward a business advantage already given.

Neither Titan nor its Business Partners will request or accept gifts, entertainment, or hospitality from a third-party with the expectation that it will provide a business advantage for them or anyone else in return.

Neither Titan nor its Business Partners will accept unduly lavish or under the circumstance extravagant gifts, entertainment, or hospitality from a third-party relating to any business involving Titan.

Titan will not offer nor accept a gift to or from government officials or representatives, or politicians or political parties, without the prior approval of the Compliance Team.

Neither Titan nor its Business Partners will threaten or retaliate against another individual who has refused to commit a bribery offence or who has raised concerns under this policy.

Neither Titan nor its Business Partners will engage in any other activity that might lead to a breach of this policy.

7. Money laundering and tax evasion

To prevent becoming part of money laundering and tax evasion schemes, restrictions for payments to and from business partners are in place.

Payments are only permitted to business partners registered in the Titan systems and will be screened by the due diligence program used by Titan Compliance.  Payments are only permitted to a bank accounts in the name of the business partner in the country of residency.

Incoming payments from other than registered customers are not allowed.
Any exception to the above must be approved by the Compliance Team in advance.

8. Conflict of Interest

A conflict of interest arises when personal, social, financial, or political activities or business relationships interfere with a business partner’s objectivity and dedication to Titan. Actual conflicts, as well as the appearance of conflicts, must be avoided or reported to Titan Compliance.

9. Antitrust and competition laws

It is Titan’s policy to comply with applicable antitrust and competition laws of each country in which it does business, to prohibit efforts and actions to restrain or limit competition including, but not limited to, price fixing, bid rigging, market division and unlawful information sharing arrangements that unreasonably restrain trade.  Titan requires that its Business Partners comply with all applicable antitrust and competition laws.

10. Confidentiality

Confidential information and trade secrets include any material and information that Titan does not make or want to make publicly known at a given time.

This is among the company’s most valuable assets and business partners must protect them in the highest regard as disclosure may cause irreparable harm.

11. Human rights

Titan believes that all people have the right to be treated with respect and have the same value and should have the same rights and possibilities, regardless of gender, race, political views, sexual orientation, religion, and ethnic background.

Discrimination of any kind is forbidden at Titan and we expect the same from our Business Partners.

Other important human rights subjects are freedom of association and collective bargaining, safe and healthy workplace, workplace security, forced labor and human trafficking (modern slavery), child labor, work hours, wages, and benefits.  International laws regarding these issues must be followed.

12. Environment

The requirements of local and national environmental laws and regulations must be followed.

13. Due diligence and screening

All business partners to Titan are screened for “flags” (sanctions and warning signs of bribery, corruption and crimes against human rights and the environment).

Further due diligence in the form of investigations and legal advice will be performed as needed.

14. Whistleblowing service

The Titan Whistleblowing service allows for reporting to be made in confidence.  The service is handled by an external third-party company and complete anonymity is guaranteed.  Any reports are encrypted and can only be accessed by Titan Compliance, who is not able to trace the whistleblower.

Titan is committed to protect the rights of those individuals who report any complaint in good faith or who are asked to participate in any internal investigation resulting from such a complaint.  Titan will prohibit any discrimination or retaliation against such individuals.

15. Possible consequences

Any relationship with individuals and organizations working on behalf of Titan could be terminated if this policy is breached.  By agreeing to this policy, Business Partners acknowledge and agree that any breach of this policy gives Titan the right to immediately terminate any business relation on written notice and with no liability due to such termination.  This does not affect any other legal rights that Titan may have such as claiming damages.

Decisions to prosecute or refer the examination results to the appropriate law enforcement and/or regulatory agencies for independent investigation will be made together by senior management and other designated advisors.

Punishment for individuals found guilty of bribery and corruption could be fines and/or imprisonment for up to ten years.

Punishment for companies failing to prevent bribery and corruption could result in unlimited fines.

16. The UN Global Compact

Titan has also agreed to comply with the UN Global Compact's principles in the areas of human rights, labor, the environment, and anti-corruption (see below).

Ten Principles of the UN Global Compact Human Rights

Principle #1:  Businesses should support and respect the protection of internationally proclaimed human rights; and

Principle #2:  Make sure that they are not complicit in human rights abuses.

Labor

Principle #3:  Businesses should uphold the freedom of association and the effective recognition of the right to collective bargaining.

Principle #4:  The elimination of all forms of forced and compulsory labor.

Principle #5:  The effective abolition of child labor; and

Principle #6:  The elimination of discrimination in respect of employment and occupation.

Environment

Principle #7:  Businesses should support a precautionary approach to environmental challenges.

Principle #8:  Undertake initiatives to promote greater environmental responsibility; and

Principle #9:  Encourage the development and diffusion of environmentally friendly technologies.

Anti-Corruption

Principle #10:  Businesses should work against corruption in all its forms, including extortion and bribery.

“Corporate sustainability starts with a company’s value system and a principled approach to doing business.  This means operating in ways that, at a minimum, meet fundamental responsibilities in the areas of human rights, labor, environment and anti-corruption.  Responsible businesses enact the same values and principles wherever they have a presence and know that good practices in one area do not offset harm in another.  By incorporating the Global Compact principles into strategies, policies, and procedures, and establishing a culture of integrity, companies are not only upholding their basic responsibilities to people and the planet, but also setting the stage for long-term success.

The UN Global Compact’s Ten Principles are derived from: “The Universal Declaration of Human Rights, the International Labor Organization’s Declaration on Fundamental Principles and Rights at Work, the Rio Declaration on Environment and Development, and the United Nations Convention Against Corruption.”