“Complying with applicable laws, regulations, and standards in both our personal and business conduct is everyone’s responsibility. We all count on each other to do the right thing and act with integrity –– doing so is in line with our history, good for our business, and critical to our future.”

Tom Davison, President, UPI

Trusted and Reliable Choice

Central to UPI’s corporate culture are our core values, captured in our Code of Ethics and Business Conduct. Those values: Integrity, safety, honesty, engagement, responsibility and performance, influence every decision that we make. Our commitment putting our values first and living by high ethical standards echoes through our work.

OpenLine

By asking questions and reporting potential concerns, our employees know they play an important role in helping us meet the standards reflected in our Code of Ethics and Business Conduct. The OpenLINE hotline allows concerns to be reported confidentially 24 hours a day, 7 days a week in many languages. Calls can be made anonymously and will not be recorded.
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Our Approach to the Code of Ethics

At UPI, we believe that the “tone from the top” is essential to the continued growth of an ethical workforce. Our compliance program places a number of responsibilities on every member of the workforce. We view compliance as a responsibility of every employee.

We follow a series of policies and procedures that serve as the framework for the anti-corruption compliance program, including: (i) a comprehensive anti-corruption policy; (ii) a policy for the giving and receipt of gifts to ensure that such transactions are not subterfuge for bribery; (iii) a policy on gifts and gratuities; and (iv) a policy on potential conflicts of interest.

Where necessary, these policies are strengthened with procedures and work instructions so that our employees have a clear understanding of their responsibilities. To ensure that these policies and procedures are widely understood and followed, we formally train our entire workforce annually on the Code of Ethics. Specific at risk groups are given training on anti-corruption and other risks. Our training program is designed to ensure that employees in sensitive positions receive targeted training to meet the risks inherent in their duties.

Suppliers

As a Company, we care about our relationships with our vendors and subcontractors and encourage Subcontractors to adopt the same core values that we so highly prize in our work. Our Supplier in a Code of Conduct defines the conduct we expect of non-employees who act on the company’s behalf in any capacity

Our commitment to compliance is such that we demand an equal commitment from the companies with which we conduct business. UPI’s procedures require that, prior to engaging any business partners, we perform diligence to ensure that our business partners share our commitment to ethical business practices. Our due diligence is a strict requirements apply to all Companies, regardless of location and scope.

We believe a commitment to ethical business practices is key to our continued to success as a company and will continue to enhance our compliance program as needed to meet the evolving risks and challenges facing our Company. For more information about our compliance program, please contact: Fermeen Fazal, UPI’s head of compliance.