Commitment Statement

LDLNET LLC is committed to high standards of ethics, social and environmental responsibility, and integrity as reflected in this Code. This commitment extends to continual improvement and the implementation of systems designed to manage and ensure compliance and facilitate continuous improvement.

Laws and Regulations:

LDLNET LLC operates in full compliance with all applicable laws and regulations of the countries in which it operates.

A. Labor

Child Labor
LDLNET LLC does not and will not employ child labor. LDLNET LLC defines child labor as employing anyone under the age of fifteen. If local law is more restrictive than LDLNET LLC’s policy, LDLNET LLC will comply with the applicable local law.

Forced Labor
LDLNET LLC does not and will not employ any type of involuntary or forced labor, including indentured, bonded, or prison labor.

Wage and Benefits
LDLNET LLC pays employees at least the minimum compensation required by local law and provides all legally mandated benefits. In addition to payment for regular hours of work, employees are paid for overtime hours at such premium rate as is legally required or, in those countries where such laws do not exist, at least equal to their regular hourly payment rate.

Hours of Work
Except in extraordinary business circumstances, employees are not required to work more than the limits for regular and overtime hours set forth by applicable local law. Except in extraordinary business circumstances, all employees are entitled to at least one day off in every seven-day period.

Humane Treatment
LDLNET LLC treats all employees with respect and dignity. LDLNET LLC prohibits all forms of harassment of employees by fellow employees, employees of outside contractors, or visitors. No employee, contractor, customer, or visitor shall be subject to hostile physical contact, corporal punishment, physical, sexual, psychological, or verbal harassment or abuse.

LDLNET LLC specifically bans unwelcome sexual advances or physical contact, sexually oriented gestures or statements, and the display or circulation of sexually oriented pictures, cartoons, jokes, or other materials. Retaliation against an employee who rejects, protests, or complains about sexual harassment is absolutely prohibited. LDLNET LLC has a formal complaint procedure for employees to report harassment.

Nondiscrimination
All employment practices, including hiring, payment, benefits, advancement, termination and retirement, shall be based on ability and not on beliefs or any other personal characteristics prohibited by applicable law.

Women's Rights
Female employees receive equal treatment in all aspects of employment.

Freedom of Association and Collective Bargaining
LDLNET LLC recognizes and respects any rights of employees to exercise lawful rights of free association, including joining or not joining any association. LDLNET LLC also respects any legal right of employees to bargain collectively.

Drug Free Workplace
LDLNET LLC prohibits the manufacture, distribution, sale, purchase, transfer, possession, or use of illegal drugs in the workplace and/or while representing LDLNET LLC.

B. Health and Safety

LDLNET LLC is committed to providing a safe and healthy work environment and to manage its business in ways that are sensitive to the environment. LDLNET LLC will comply with all applicable regulatory requirements regarding health, safety, and protection of the environment.

Occupational Safety, Injury and Illness
LDLNET LLC has and will continue to provide a clean, safe, and healthy work environment for its employees.

Emergency Preparedness
LDLNET LLC has implemented emergency plans and response procedures in an effort to minimize the impact in emergencies.

Industrial Hygiene, Physically Demanding Work, Machine Safeguarding

As part of its integrated Quality, Environmental, Health and Safety Management Systems, LDLNET LLC has and will continue to identify, evaluate, and endeavor to control employee exposure to:

- chemical, biological and physical agents at LDLNET LLC’s facilities;
- physically demanding tasks, including manual material handling and heavy or repetitive lifting, prolonged standing and highly repetitive or forceful assembly tasks; and/or
- machinery presenting an injury hazard to employees.

Facilities
LDLNET LLC provides employees with ready access to clean toilet facilities, potable water and sanitary food preparation, storage and eating facilities.

C. Environmental Responsibility

LDLNET LLC is committed to environmental protection and conducts its business in an environmentally sensitive way.

Environmental Permits and Reporting
LDLNET LLC has and will continue to obtain, maintain, and keep current applicable environmental permits, approvals, and registrations, as required by applicable law.

Pollution Prevention and Resource Reduction
LDLNET LLC is committing to reducing or eliminating at the source waste of all types, including water and energy.

Hazardous Substances
LDLNET LLC will identify, control and endeavor to manage the use of hazardous materials, chemicals and other materials that pose a hazard if released to the environment, wastewater or sold waste generated from its operations, and air emissions of volatile organic chemicals, aerosols, corrosives, particulates, ozone depleting chemicals

Product Content Restrictions
LDLNET LLC will adhere to applicable laws, and regulations regarding prohibition or restriction of specific substances.

D. Business Ethics

Business Integrity
LDLNET LLC will conduct its business in an ethical manner in accordance with applicable rules and regulations and the Better Business Bureau. LDLNET LLC will refrain from any forms of corruption, extortion, and embezzlement.

No Improper Advantage
LDLNET LLC employees are strictly prohibited from offering, paying or accepting any kickbacks, fees, commissions, or any form of “bribe” or illegal gratuity or payment directly or indirectly, to any person, organization, or governmental representative.

Disclosure of Information
LDLNET LLC employees have access to and special knowledge of certain information that is confidential and constitutes valuable, special, and unique property of LDLNET LLC. Because confidentiality is critical to LDLNET LLC business, all employees are prohibited from disclosing confidential information or discussing anything concerning LDLNET LLC suppliers or customers or any LDLNET LLC business with any third party, unless otherwise authorized by management or local law.

Intellectual Property
LDLNET LLC observes obligations of confidentiality and non-disclosure of confidential information and trade secrets of others, including suppliers and customers. LDLNET LLC respects the legitimate intellectual property rights of others and will not reproduce or use software or other technology licensed from suppliers except as permitted by the applicable license agreement or by law.

Fair Business, Advertising, and Competition
LDLNET LLC employees are expected to deal fairly with customers, suppliers, competitors and other employees. No employee should take unfair advantage of anyone through manipulation, concealment, abuse of privileged/confidential information, misrepresentation, fraudulent behavior or any other unfair dealing practices.

Protection of Identity
LDLNET LLC prohibits retaliation against any person for reporting good faith integrity concerns. LDLNET LLC recognizes that the privacy of the individuals involved is important and the information surrounding the report and investigation will be kept as confidential as possible, with access limited to an as needed basis.

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