We Encourage Our People to Speak Up
Reporting Actual or Potential Violations
The Company’s directors and the Executive Team shall promptly report any actual or potential violations of this Code to the Chairperson of the Company’s Audit Committee. All other Team Members shall promptly report any actual or potential violations of this Code as outlined below under “Compliance Procedures.” No retaliatory action of any kind will be permitted against anyone making such a report in good faith. The Company’s Audit Committee will strictly enforce this prohibition. All members of the Company’s Executive Team are responsible for ensuring that their own conduct complies with this Code.
Accountability for Violations
Anyone who violates the provisions of this Code by engaging in unethical conduct, failing to report conduct that potentially violates this Code or refusing to participate in any investigation of such conduct, will be subject to disciplinary actions, up to and including termination of service with the Company. If the Company’s Audit Committee or its designee determines that this Code has been violated, either by failure to report a violation, or by withholding information related to a violation, the offending Team Member may be disciplined for non-compliance with penalties up to and including removal from the office or dismissal.
Such penalties may include written notices to the individual involved that a violation has been determined, censure by the Audit Committee, demotion or re-assignment of the individual involved and suspension without pay or benefits. Violations of this Code may also constitute violations of the law and may result in criminal penalties and civil liabilities for the offending Team Member and the Company. All Team Members are expected to cooperate in internal investigations of misconduct.
We must all work together to ensure prompt and consistent action against violation of this Code. In some situations, however, it is difficult to know if a violation has occurred. Because we cannot anticipate every situation that will arise, it is important that we have a way to approach a new question or problem. These are the steps to keep in mind:
- Make sure you have all the facts. In order to reach the right solution, we must be as informed as possible.
- Ask yourself: What specifically am I being asked to do? Does it seem unethical or improper? Use your judgment and common sense. If something seems unethical or improper, you must be willing to step forward and ask the question until the issue is resolved or confirmed to fall within the guidelines of this or other applicable documents.
- Clarify your responsibility and role. In most situations there is a shared responsibility. Are your fellow workers informed? It is your responsibility as a Team Member at Patrick to hold yourself and your teammates accountable to uphold the standards set forth in this document. In uncertain situations it may be helpful to get others involved and discuss the problem openly.
- Discuss the problem with your supervisor and/or another manager. This is the basic guidance for all situations. In many cases, they will be more knowledgeable about the questions, and will appreciate being consulted as part of the decision-making process. Should you still feel that the problem has not been adequately resolved or uncomfortable addressing the matter in this way, you may contact the Company’s Chief Human Resources Officer or another member of senior management or email or voice your concern to the Patrick Industries Audit Committee as follows: (1) in the case of an accounting issue at email@example.com or at (574) 206- 7796; or (2) in the case of any actual or potential illegal or unethical behavior at firstname.lastname@example.org or at (574) 206 - 7793.
- You may report ethical violations in confidence without fear of retaliation. If your situation requires that your identity be kept secret, your anonymity will be protected to the maximum extent consistent with the Company’s legal obligations. The Company in all circumstances prohibits retaliation of any kind against those who report ethical violations in good faith.
- Ask first, act later. If you are unsure of what to do in any situation, seek guidance before you act.
Reports can also be submitted directly through the Ethics Hotline via:
Web: email@example.com or at (574) 206 - 7793
Reports can also be submitted directly through the Compliance Hotline via:
Web: firstname.lastname@example.org or at (574) 206- 7796