Hunt enjoys an excellent record of ethical business practices consistent with its core values as a Company and is committed to achieving its business goals in accordance with the laws and regulations applicable to its operations.
This approach is reflected in our Code of Business Conduct (the “Code”), one of the governing documents built upon the foundation of integrity and the commitment to conduct business ethically throughout the Company.
Our Code sets forth the standards of conduct and corporate policies to be followed by each employee, officer and director of the Company worldwide and expresses our commitment to uphold, promote and honor all human rights in our activities. All employees receive training regarding the Code as part of the hiring and onboarding process and are required to reaffirm their commitment to follow the standards in the Code annually.
Preventing Bribery and Corruption
The Company’s anti-corruption framework consists of a set of requirements and procedures designed to detect, prevent and address potential violations of anti-corruption and bribery laws. This framework includes our Anti-Corruption Policy and supporting Due Diligence Procedures. The Policy sets forth specific prohibitions, including the prohibition of bribery and facilitation payments, as well as processes for addressing and reporting potential corruption risk. The Due Diligence Procedures provide the steps that employees and representatives must take when engaging business partners to mitigate corruption and sanctions violation risks. Training is provided to all employees to ensure that they understand the Anti-Corruption Policy and Due Diligence Procedures and remain vigilant in identifying potential anticorruption and sanctions issues.
Additional procedures and controls have been developed in connection with Hunt’s operations in Peru in accordance with Peruvian law to mitigate corruption risks. For example, Hunt’s Peruvian affiliates have implemented a policy for the prevention of corruption together with a System for Prevention of Corruption (“System”) aimed to promote zero tolerance against corruption.
Reporting Mechanism
The Company’s Chief Compliance Officer is responsible for implementing our Code of Business Conduct and Anti-Corruption Policy, with oversight from our Board of Directors.
Suspected violations of the Code of Business Conduct or Anti-Corruption Policy can be reported in several ways, including but not limited to contacting:
- The Chief Compliance Officer
- The HR Department, Legal Department, or other departments referenced in the Code and Anti-Corruption Policy
- A direct supervisor or manager within the Company
- The Ethics and Compliance Helpline via phone or at huntconsolidated.ethicspoint.com
The Company does not tolerate retaliation for good faith reporting of potential Code or Policy violations and considers such retaliation for good faith reporting a violation of the Code.
