Pall Corporation Employee Complaint Procedures for Financial Matters
Pall Corporation Directors Code of Business Conduct and Ethics
The Board of Directors of Pall Corporation (“Board”) has adopted this Code of Business Conduct and Ethics for Directors of Pall Corporation (“Code”).
This Code is intended to provide guidance to Directors to help them recognize and deal with ethical issues, provide mechanisms to report possible compliance issues and foster a culture of honesty and accountability. Each Director is expected to comply with the letter and spirit of this Code. Good common sense is the best guide.
No code can anticipate every situation that may arise. Therefore, this Code is intended to serve as a source of guiding principles for Directors. Directors are expected to bring questions about particular circumstances that may be relevant to provisions of this Code to the attention of the Chairman of the Board. The Chairman may consult with the Company’s Corporate Compliance Officer and inside or outside legal counsel as appropriate.
Directors who also serve as officers of Pall Corporation (“Company”) should read this Code in conjunction with the Pall Corporation Code of Ethical Behavior.2. Conflict of Interest
Directors must avoid any conflicts of interest between themselves and the Company. If a Director believes he or she has an actual or potential conflict of interest with the Company, the Director shall notify the Chairman of the Board as promptly as practicable and shall not participate in any decision by the Board that in any way relates to the matter that gives rise to the conflict of interest.
A “conflict of interest” can occur when a Director’s personal interest interferes in any way – or even appears to interfere with – the interests of the Company. A conflict situation can arise when a Director takes actions or has interests that may make it difficult to perform his or her work as a Company Director objectively and effectively. Conflicts of interest also arise when a Director, or a member of his or her immediate family, receives improper personal benefits as a result of his or her position as a Director of the Company. “Immediate family” includes a Director’s spouse, parents, children, siblings, mothers-inlaw and fathers-in-law, sons and daughters-in-law, brothers and sisters-in-law, and anyone (other than domestic employees) who shares such Director’s home.3. Corporate Opportunities
Directors are prohibited from (a) taking for themselves opportunities that are discovered through the use of Company property, information or position, (b) using Company property, information or position for personal gain, and (c) competing with the Company for business opportunities.4. Confidentiality
Directors shall maintain during his or her term of office, and after leaving the Board, the confidentiality of confidential information entrusted to them by the Company and any other confidential information about the Company that comes to them, except when disclosure is authorized by the Chairman of the Board or Lead Director or legally mandated. For purposes of this Code, “confidential information” includes all nonpublic or proprietary information relating to the Company.5. Compliance with Laws, Rules and Regulations
Directors shall comply with laws, rules and regulations applicable to them as Directors of the Company.6. Competition and Fair Dealing
Directors shall endeavor to deal fairly with the Company’s customers, suppliers, competitors and employees. No Director should take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any other intentional unfairdealing practice.7. Protection and Proper Use of Company Assets
Directors shall not use Company assets, labor or information for their personal benefit or gain.8. Insider Trading
Directors shall not engage in transactions in Company stock (whether for their own account, for the Company’s account or otherwise) while in possession of material, nonpublic information and shall not communicate such information to third parties that may use such information in the decision to purchase or sell Company stock (“tipping”). This policy also applies to information relating to any other company, including the Company’s customers and suppliers, that a Director obtains in the course of serving on the Board of Directors. In addition to violating Company policy, insider trading and tipping are illegal.
Information may be material if there is a substantial likelihood that the information would affect the price of the Company stock or that a reasonable investor would consider the information significant in deciding whether to buy or sell the Company stock. Such information includes information relating to capital structure, major management changes, contemplated acquisitions or divestitures, and information concerning earnings or other financial information. Information is considered to be non-public if it has not been disclosed to the public. Generally, information is considered disclosed to the public if it has been published in newspapers or the media, has been the subject of a press release or a public filing with the SEC and, in all cases, at least 24 hours has passed since the publication, release or filing.9. Compliance Procedures
Directors shall communicate any suspected violations of this Code, including any violation of law or governmental rule or regulation, promptly to the Chairman of the Board or the Company’s General Counsel. Alleged violations shall be investigated by the Board or by a person or persons designated by the Board and appropriate action shall be taken in the event of any violations of the Code.10. Waivers
Waivers of this Code shall be granted only under exceptional circumstances. A waiver of this Code may be made only by the Board, and must be promptly disclosed in accordance with applicable law and the requirements of the New York Stock Exchange Corporate Governance Standards.11. Annual Review
The Board shall review and reassess the adequacy of this Code annually and make any amendments to this Code that the Board deems appropriate.
Pall Corporation Copyrights, Trademarks, Forward-Looking Statements, Disclaimers
© Copyright 2013 by Pall Corporation. All rights reserved.
Permission is granted to copy and distribute all documents and related graphics contained in this World Wide Web site subject to the following provisions:
® The Pall Corporation name and logo and all related product and service names, design marks and slogans are the trademarks, service marks or registered trademarks of Pall Corporation. Other manufacturers' products contained on this WWW server are trademarks of their respective companies.
Management uses certain non-GAAP measurements to assess the Company’s current and future financial performance. The non-GAAP measurements do not replace the presentation of Pall’s GAAP financial results. These measurements provide supplemental information to assist management in analyzing the Company’s financial position and results of operations. The Company has chosen to provide this information to facilitate meaningful comparisons of past, present and future operating results and as a means to emphasize the results of ongoing operations.Disclaimer
All of the information, text, graphics, and links provided on this WWW server are the property of Pall Corporation, provided by Pall Corporation expressly for the use of its customers. Pall Corporation does not warrant the accuracy, or completeness of the information, text, graphics, links, and other items contained on this WWW server.
If you should have any questions concerning legal issues contained in these terms and conditions, please contact the Pall Corporation Legal Department at (516) 484-5400.
Pall Corporation Corporate Safety Policy
Safety in the workplace and in the communities where we do business is our highest priority. To help ensure the health and safety of our employees, our management team is committed to do all that is necessary to provide an environment where people feel safe and have the proper training and tools required to maintain our safety standards.
The managers at each facility are responsible for making safety-first practices a part of daily management. Local (site) management ensures that we are in compliance with all health and safety regulations and corporate health and safety policies. As pad of this effort, management is required to assign responsibilities for health and safety in their organizations and provide adequate resources to sustain continuous improvement.
Pall Corporation's safety policy is aimed at preventing or limiting the exposure of employees, customers, and other visitors to our facilities to health or safety risks. Each Pall facility has implemented a plan to reduce the accident and lost time case rate with the long-term goal of achieving zero accidents and zero lost time cases. To accomplish this objective, all employees are expected to work diligently to maintain safe and healthful working conditions and to adhere to proper operating practices and procedures designed to prevent injuries and illnesses. The responsibilities of all Pall personnel in this regard include:
Chairman and Chief Executive Officer
Pall Corporation Equal Employment Opportunity Policy
Pall Corporation Hiring Policy for Former Employees of Independent Audit Firm
Pall Corporation Procurement Policy
As business people, we know that living up to or exceeding our customers’ expectations of quality and service requires a constant commitment, both from suppliers and from everybody within the Company.
Pall is committed to Quality through its product performance, its manufacturing systems and its people.
Our wide range of products; filter assemblies, separations systems, diagnostic devices, and oil purifiers are used to remove contaminants (solid, liquid or airborne) in a very broad range of markets and critical applications, from the use of filters for the Healthcare, Pharmaceutical, Food and Beverage industries, Semiconductors, Industrial Chemicals, to Hydraulics, Power generation and Aerospace applications.
All our manufacturing plants globally maintain internationally recognised Quality Approvals/Accreditations, in particular ISO9001, and are transitioning to ISO 9001:2000 certification.
We build quality into every process, from research and development to production, testing, distribution and after market support.
To endorse our commitment to service and quality, along with our reputation for customer satisfaction, our manufacturing plants also hold other specific Healthcare, Aerospace, Automotive and Industrial Sector Scheme Approvals such as FDA, FAR-145, JAR-145, JAR-21, ISO/TS 16949 etc. To further demonstrate our commitment to continual improvement, Pall will continue to maintain and develop these systems whilst additionally implementing ISO 14001 Environmental Management systems.
Our vision is to be a world class supplier in our chosen markets and to be the obvious first choice for all our customers’ filtration needs. We are committed to continuous improvement in all our business processes and activities, in order to deliver real benefits to our company, customers and suppliers.
Our expectations of our suppliers are equally demanding, we aim to work with profitable and financially stable companies who have a clear and consistent vision and synergy with our strategic business development and who also have a commitment to the development of people, to total quality and to continuous improvement, with the emphasis on providing the lowest total cost of ownership covering the supply and use of raw materials and services and where appropriate, to integrate their procedures with ours in order to eliminate further non-valve adding activities.
We believe this integration, which we refer to as the ‘supply chain’ concept, is fundamental to the achievement of our joint goals and is the best way to help secure the future for all of us.
“With ever increasing global competition, we must continue to strive for excellence with innovative strategies and policies that fully involve and support our supplier base”.
The Procurement and Supply Policy of Pall Corporation is based on the concept of a single chain consisting of interdependent links joining our suppliers, our manufacturing processes and our customers. Fundamental to the strengths of these links is a solid supplier relationship. This ‘supply chain’ approach has been designed to meet the Company’s business needs into the future and is an extension of our commitment to providing the highest possible levels of Customer Satisfaction and Continual Improvement. This process aims to meet Pall’s requirements and those of our customers first time, every time.
In order for this policy to be successful we will encourage the development of mutually agreed business goals with our suppliers and over a period of time we will form even closer working relationships through confidence building founded on mutual trust, with the emphasis on problem prevention and continual improvement to provide the lowest total cost of ownership. We expect prospective suppliers to work with us to achieve this objective and thus welcome any suggestions that provide for our customers the highest levels of Quality, Service, and Delivery.
Supplier Approval and Assessment Policy
The development of a new source of supply is an undertaking of considerable magnitude. New suppliers with an unproven performance record will be required to demonstrate that they can provide an outstanding ‘Quality, Cost and Delivery’ (QCD) package.
As the Pall Corporation production procurement requirements are based on many common and international procurement specifications, a supplier to a particular Pall facility could become a world-wide supplier to other Pall locations.
Before this can become a reality, a full evaluation of the supplier will be made. Procurement performance at Pall is measured by the success of suppliers and their ability to ensure the following:
Most items used in our manufacturing processes are purchased (except for certain filter media) and quotations are regularly invited from a wide selection of possible suppliers, but competitive bids do not guarantee that an order will be awarded to the lowest bidder. We recognise that price is only one component of total acquisition cost. Quality, delivery, Time-to-Market and after-sales service also have a significant effect upon value.
Pall, as a minimum, expects suppliers to meet the requirements of ISO9000 for Quality Management Systems and may require additional sector scheme Approvals for Healthcare, Aerospace, Automotive etc., as appropriate for particular purchase contracts. This standard may be supplemented as necessary by specific customer or regulatory requirement.
The approval process starts with the assessment of potential new suppliers to Pall. They will be sent a request to provide information on their management systems and capabilities and their responses will be evaluated by the relevant Pall Procurement and Quality functions. Dependant upon the type of product to be supplied, in many cases the reply will provide sufficient information and the supplier’s name will be added to Pall’s List of Approved Suppliers. In other cases Pall staff will make an assessment visit. The supplier will always be informed of Pall’s decision.
Some suppliers have either a significant volume of business with Pall or supply critical products or services, and with these suppliers we will move to the second stage of the process. Procurement and Quality representatives will visit the supplier and will carry out a more detailed assessment of the supplier’s systems and capabilities. They will require from the supplier an agreement on performance monitoring, and the signing of a confidentiality agreement. If this further assessment is successful, and the supplier’s performance continues to meet our defined requirements, the supplier will receive formal Pall recognition, which forms the basis of a partnership approach. The supplier’s deliveries to Pall will continue to be monitored and reported.
Those core and strategic suppliers who continue to excel will be invited to join with Pall in the final stage of the recognition and improvement process, this includes the formation of Cross Functional continuous Improvement Teams and the development of mutual Supplier Development Plans. The aim of these Plans is to make managing our joint activities easier and to provide the lowest total cost of ownership for both parties with a series of mutual goals and targets. Supported by a long term supply agreement.
Supplier Performance Monitoring
It is the policy of Pall Corporation to ensure maximum communication with their approved core and strategic suppliers. An integral part of this is the feed back of information gathered when goods and services are received by Pall, and through supplier performance programmes.
In return, Pall welcomes feed back from their supplier’s assessment of Pall’s performance.
The main focus areas for measuring supplier performance are the key elements of total cost of ownership, including:
In designing their Supplier Monitoring System Pall have tried to ensure that the efforts of good suppliers are clearly reflected in their Performance Rating.
Commodity Requirement Matrix (50 KB Microsoft Excel Spreadsheet)
Pall Corporation Quality Policy
For each of our products and services, we will meet the requirements of our customers in all areas of the world. We will always ask what can be done better - for our customers, our distributors, our suppliers, our shareholders, our employees and the general public. Our personal commitment is to continually advance our processes through measurable improvements.
Pall Corporation Revised Notice of Privacy Practices for Comprehensive Welfare Benefits Plan, Cafeteria Plan - Health Care Account, and First Aid Office
Pall Corporation Web Linking Policy
Bookmark Our Site
Pall Corporation encourages you to bookmark our site so that you can return easily and often. To bookmark this site simply go to the Pall home page and follow these simple instructions.
If you are using a PC press CTRL+D; if using a MAC, press COMMAND+D.
Link To pall.com
We also encourage you to link to pall.com from your Web site by clicking on the link below and accepting the Pall Logo Usage Agreement. By doing so, you will be able to download the Pall Web Banner of your choice or copy the block of HTML code on the following pages right into your page.
When you do link to the site, please contact the Pall Webmaster and let us know so that, if appropriate, we can offer a reciprocal link back to your site.
Continue on to the Pall Logo Usage Agreement...
Pall Corporation Web Privacy Statement
At Pall Corporation, we intend to give you as much control as possible over your personal information. In general, you can visit pall.com without telling us who you are or revealing any information about yourself. There are times, however, when we may need information from you (such as your name and address) to be able to provide you with the information, service or product you have requested.
We do keep track of the domains from which people visit our site. We analyze this data for trends and statistics about site traffic. We also may use your IP address to help diagnose problems with our server, and to administer our Web site. Your IP address may be used to help identify you and your shopping cart and to gather broad demographic information.
We, or one of our business partners, may from time to time also ask for other personal information via the Internet. We may use this information to correspond with you to process an order or to provide you with a subscription to an online newsletter, for example.
If you tell us that you do not wish to have this information used as a basis for further contact with you, we will respect your wishes. Users may choose to opt-out of receiving future e-mail or mailings by e-mailing us at firstname.lastname@example.org.