REVISED JANUARY 15, 2020 - LKQ Corp
←
→
Page content transcription
If your browser does not render page correctly, please read the page content below
REVISED JANUARY 15, 2020
I am proud to introduce our
updated Code of Ethics (the
“Code”). LKQ is a leader in our
industry because we have earned
the trust of our customers,
suppliers and business partners
by putting Integrity first in our
business practices. Our Code is
our global guide to keeping that
trust by doing the right thing and
always acting with a high level
of Integrity.
Our Code will help you find
and understand the principles,
standards and LKQ policies
that apply in your work with LKQ.
Please take time to learn the Code and to
understand your personal responsibilities.
Finally, in addition to acting ethically yourself, if you see or
hear something that does not seem right to you, please Speak Up.
This helps us to investigate and take action before something more
serious happens.
Thank you for supporting our commitment to doing business the right way.
Dominick P. Zarcone
President and Chief Executive Officer
1
I. The Code Mission Statement...............................................................4 The LKQ Code of Ethics......................................................4 II. Living Our Code About Our Code...................................................................5 Your Responsibilities...........................................................5 Making Good Decisions.....................................................7 Avoiding Bad Decisions......................................................8 Speaking Up..........................................................................9 III. Our Core Policies We Care about Others........................................................11 Health and Safety | Positive Work Environment | Privacy and Data Protection | Social Responsibility We Do the Right Thing........................................................17 Fair Dealing | Gifts and Entertainment | Bribery and Corruption | Conflicts of Interest We Protect Our Company..................................................25 Controllership | Trade Compliance | Protecting LKQ Property | Speaking on Behalf of LKQ TABLE OF CONTENTS 3
About Our Code
We are a global company with operations in many different countries where different laws,
cultures, values and traditions apply. We believe that a commitment to honesty, ethical
conduct and integrity is a valuable asset that builds trust with our customers, suppliers,
employees, shareholders and the communities in which we operate.
Living the Code. Our Code is an expression of our shared values and the way we do
business worldwide. It applies to everyone in our company, at every level, including
employees, supervisors, board members, and subsidiaries we control.
Winning with Integrity. At LKQ, we are committed to Winning with Integrity, which means
making decisions that are consistent with both our Code and the law. Our Code is your
guide to Winning with Integrity and provides a summary of our core policies. Employees can
visit the LKQ Compliance Site for detailed policy information and resources.
The Code and the Law. As a global company, there may be times where local law differs
from our Code. If local laws are less restrictive than our Code, you should follow our Code,
even if your conduct would be legal under applicable laws or an accepted local practice. On
the other hand, if a local law is more restrictive than our Code, you should comply with the
applicable laws. If at any time you feel our Code conflicts with local law, please contact our
Legal Department for guidance.
Mission Statement
To be the leading value-added global distributor of vehicle parts and accessories offering
our customers the most comprehensive and cost-effective parts solutions while building
strong partnerships with our employees and the communities in which we operate.
The LKQ Code of Ethics
We are honest, fair and trustworthy in all of our LKQ activities
and relationships
We obey the laws and regulations governing our business
We treat everyone with respect and dignity
We promptly report any concerns we have about compliance with the law,
LKQ policies or this Code
LIVING OUR CODE 5
Making Good Decisions
Often, we face ethical dilemmas or need to make decisions at work when there is no
specific rule or clear guidance. In these situations, we still need to make the right decision.
Although our Code cannot offer an answer for every situation, it will help you navigate
them. Refer to it often in your work, use good judgment, and always ask for guidance if you
need it.
Does it feel right?
Is it legal and consistent with our Code?
Is it good for LKQ, its employees and customers?
Your Responsibilities
Be Knowledgeable Am I being truthful and honest?
• Know the Code. If it were made public, would I still feel okay about it?
• Learn the details of any policy that is relevant to your job responsibilities.
• Understand your business and regional policies and procedures and how they apply to
your job. Answer Action
If you answered “yes” to all of these questions, then the decision to
Be Aware Yes
move forward is probably okay.
• Stay attuned to developments in your area or industry that might impact our compliance If you answered “No” to any of these questions, the action could have
with laws, regulations or reputation. No serious consequences. Reach out to your manager, Human Resources
• Speak Up. If you see something, say something. Promptly raise any concerns about Department or the LKQ Legal department.
potential violation of law, our Code or policies. Seek guidance. Reach out to your manager, Human Resources
Maybe
department or the LKQ Legal Department.
Be Accountable
• Live the Code by always doing the right thing. Failure to comply with the Code may result
in discipline up to and including termination of employment.
Exclamation-Triangle Warning Signs
• Cooperate fully and honestly in LKQ investigations related to violations of the law, our
Code or our policies and procedures. If you hear any of these comments, reconsider your “Yes” answers.
“The policy doesn’t say we can’t, “Our competition does it, so it
Helping You Win with Integrity so it’s okay.” must be okay.”
Sometimes you may be in a position where you aren’t sure of the best course of action. Our “We need to do whatever it takes.”
“The law doesn’t say we can’t do it,
Code provides information on a range of topics and the LKQ Compliance Site provides
so it’s okay.” “That’s how they do business here.”
guidance through policies, procedures and training resources. If, after reviewing this
information, you’re still unsure what to do, reach out to your manager, HR, Legal, Corporate “Don’t worry about it. Who’s going “We’ve always done it this way and no
Audit or Speak Up. It’s always better to ask for help, then to say nothing at all. to know?” one has been disciplined.”
LIVING OUR CODE 7
Speak Up
If you see something, say something. If you see
a work related situation that is a potential violation
of this Code or the law, it is your responsibility to
report the possible wrongdoing to LKQ.
Confidentiality is respected and your identity
and information will only be shared to the extent
necessary to investigate and address the concern
you raise.
Where permitted by country law, you may even choose to
remain anonymous. However, if you identify yourself, weare able
Avoiding Bad Decisions
to follow up with you and provide feedback.
Avoid these common pitfalls that lead to bad decisions:
Lack of Awareness. We should know the policies and procedures that apply to our specific
job, but it’s not possible to be an expert in everything. Know when and who to ask for help. How to Raise an Integrity Concern How LKQ Handles Integrity Concerns
When in doubt, start with your Compliance site.
LKQ offers several channels for raising LKQ fairly examines every integrity concern.
Work Pressure. Even if we feel we are under performance or time pressures, it is never concerns. You can choose to speak to During the investigation process LKQ:
‘business at any cost’. If you feel under pressure to do something that you think is not right, someone about a potential integrity issue or
• Forms an objective investigation team.
Speak Up. put it in writing. Generally, your supervisor
or manager will be in the best position • Determines the facts through
Group Think. We often want to feel that we belong and don’t want to go against the group.
It can take courage to take a different view. You will be supported when you raise concerns to resolve an integrity concern, but other interviews and/or the review
and Speak Up. resources include LKQ’s: of documents.
Balancing the Scales. We sometimes try to justify unethical behavior because of a • Human Resources Department • Recommends corrective action,
perceived injustice or unfair treatment. We convince ourselves that a bad decision is okay • Legal Department if necessary.
because it gives us something we think we deserve. Two wrongs never make a right. There • Provides the person who raised
• Corporate Audit Department
is no justification for acting unethically. the original concern (if that person
• Next level of management is known) with feedback
No One Will Know. Some people think that doing the wrong thing is okay, as long as you
don’t get caught. At LKQ, we do the right thing… even if no one is looking. • Speak Up on the outcome.
Exclamation-Triangle Warning Signs
“We have no choice.” “It’s for a good cause.” LKQ has zero tolerance for retaliation against those who in good faith report
alleged wrongdoing and/or participate in an investigation of wrongdoing.
“No one will ever know.” “I don’t want to know.”
“Everybody does it.” “We can hide it.” Click here to learn how to raise a concern in your country.
LIVING OUR CODE 9
We Care
About Others
HealthAND
HEALTH Positive Work
POSITIVE Privacy and
WORK PRIVACY AND Social
SOCIAL
and Safety
SAFETY Environment
ENVIRONMENT DataPROTECTION
DATA Protection Responsibility
RESPONSIBILITY
OUR CORE POLICIES 11
Health and Safety Positive Work Environment
HEALTH AND POSITIVE WORK
TheSAFETY
Policy ENVIRONMENT
The Policy
We are committed to providing all of our What You Should Know Diversity and Inclusion. We value and What You Should Know
!
employees with a safe and secure work Red Flags for potential Health promote diversity in our workplace. Our
environment where no one is subject to and Safety Risks include: people are our most valuable asset.
unnecessary risk. We recognize that a diverse mix of
• Deviations from known safety backgrounds, skills and experiences drives
All LKQ Employees are required to maintain procedures are visible Your
new ideas, products and services. We Your
a safe workplace by following all health and Team’s
• Inadequate security or recruit, hire, promote and retain based on Ideas
safety policies, completing required safety Ideas
training, and reporting accidents/injuries emergency preparedness merit and demonstrated skills.
or illnesses. • Poorly maintained tools or Non-Discrimination. We strictly prohibit
equipment discrimination based on race, color,
Your Role ethnicity, national origin, ancestry, The Best Ideas
• Poor general facility housekeeping
• Understand and comply with all health citizenship status, religion, sex (including
• Failure to provide standard breast feeding and related medical
and safety policies that apply to you and Q: As a manager, you
safety equipment conditions), gender identity and expression,
engage in safety training/awareness. discover that one of your
• Improper handling of waste or age, disability, protected medical condition,
• Be mindful of your own personal top performers is not open to
hazardous materials marital status, veteran or military status,
safety, don’t take shortcuts around safe the ideas of her colleagues,
sexual orientation, pregnancy, genetic
practices for the sake of productivity. • Encouragement to take shortcuts if they are different from her
information or any other characteristic
that cause unneeded risk own. What should you do?
• Following procedures to timely report protected by applicable law.
accidents/injuries. Preventing Harassment. We do not allow A: How we do things is just as
Q: I brought up a serious safety behavior that creates an offensive, hostile important as what we do. The
concern to my supervisor, or intimidating work environment. performance review for this
which has been ignored. What Human Rights. We respect the rights and individual should acknowledge
should I do? dignity of people and stand strongly against the strong results but clearly
human trafficking, as well as any form of balance this against her failure
A: Safety must be everyone’s forced or child labor. We do not do business to meet the expected behavior
priority. Raise a concern by with any contractors or suppliers who use of inclusiveness.
Speaking Up. You can also forced or child labor.
contact Human Resources or
the VP of Risk Management No Retaliation. LKQ has zero tolerance for
at the LKQ North American retaliation against anyone who reports this
Headquarters in the USA. type of conduct in good faith.
Your Role
Treat everyone with respect and dignity.
OUR CORE POLICIES 13
Privacy and Data Protection Social Responsibility
PRIVACY AND SOCIAL
DATA
The PROTECTION
Policy RESPONSIBILITY
The Policy
We respect and protect the personal What You Should Know We protect the environment and care about What You Should Know
information that we handle. Personally Identifiable Information (PII) the wellbeing of our communities. Communities: Ensuring LKQ takes
We need to collect and use Personally is any information that identifies or As we strive for future profitable growth part in the growth of the communities
Identifiable Information (PII) to run our can be used to identify an individual. and continued success, we are committed that we operate. LKQ’s most valuable
business. We commit to only collect and It can relate to employees, customers, to contributing to sustainable development asset are our employees and the
retain PII that is necessary for legitimate suppliers or other individuals. by assuming our social and environmental communities that they live and work
business purposes and in compliance Examples of PII include name, email responsibilities. in are equally as important. LKQ is
with the law. We also ensure that address, location, date of birth and, The Environment. We have a duty to committed to the growth and well-
this information is protected through in some instances, IP addresses. In protect the limited resources that sustain being of these communities.
appropriate security measures. the European Union, business contact our businesses and to operate in a manner Recycling: Environmental protection
information of an individual (e.g., that will preserve these resources to the is at the heart of LKQ, since its roots
Your Role jane.doe@lkqcorp.com) is considered PII. greatest extent practical. At a minimum we are in recycling of vehicles across
• Only use PII if you need it for your job. will operate in accordance with applicable North America. As we expand
• Keep PII secure. national, regional and local environmental globally, we keep that same LKQ
Q: LKQ is considering purchasing
laws and regulations. commitment to protecting the
• Only keep PII for as long as you need it to a Customer Relationship
Corporate Investment. We can make environment by extending those
do your job. Management (CRM) tool from
an important contribution to the social same values to our partners and
a well-known vendor. Given the
• Never share PII with a person who does and economic development of our local colleagues around the World.
vendor’s strong reputation, do
not have a business need, the authority, we really need approval from the communities as an employer and also Supply Chain: LKQ relies on a
or, where required, the subject’s consent. Privacy and Cybersecurity teams? by collaborating with and investing in complex global supply chain and
• Never share passwords. these communities. LKQ encourages its is dedicated to working with our
A: Yes. Although the CRM vendor businesses to undertake a community suppliers and customers to ensure
• Consult with your Privacy and
may have a good reputation, investment program, offering both time and labor standards are upheld and a
Cybersecurity teams if you are designing
we are still responsible for funds to support the communities where we conflict-free supply chain is supported.
or modifying processes that use PII.
ensuring that the vendor’s live and work.
system has appropriate security
to store and process PII. Your Role
Additionally, most CRM tools LKQ encourages our employees to match in action what LKQ is willing to invest in capital.
provide considerable flexibility Please do your part by minimizing waste, recycling and reusing material wherever feasible.
in what information is collected We encourage you to get involved in community non-profit and charitable activities during
and how it is used. We are your free time and in your personal capacity.
responsible for configuring
the tool to minimize what PII is
collected and ensuring that we
are only using it for legitimate
business purposes.
OUR CORE POLICIES 15
We Do the
Right Thing
Fair Gifts and
GIFTS AND Bribery and
BRIBERY AND Conflicts of OF
CONFLICTS
FAIRDealing
DEALING Entertainment
ENTERTAINMENT Corruption
CORRUPTION Interest
INTEREST
OUR CORE POLICIES 17Fair Dealing Gifts and Entertainment
GIFTS AND
FAIR DEALING
The Policy ENTERTAINMENT
The Policy
We deal fairly with LKQ’s customers, What You Should Know We do not accept any gift or entertainment What You Should Know
suppliers and competitors and we do not Care should be taken to ensure that, of more than nominal value from any Certain gifts or entertainment may be
take unfair advantage of anyone through in meetings of trade associations and competitors or person or company that accepted if they are unsolicited and if
manipulation, concealment, abuse of other industry groups, competitive already does or seeks to do business with the personal benefit falls into one of
privileged information, misrepresentation of practices, supply plans and prices are LKQ. Examples of gifts and entertainment the following categories:
material facts or any other unfair not discussed. include loans or cash in any amount,
dealing practice. excessive entertainment or travel, free or • Normal business courtesies, such as
discounted services, or other substantial or a meal, golf game, or sporting event
On legal as well as ethical grounds, we involving no more than ordinary
refrain from all dealings with competitors Q: A former coworker left LKQ unusual favors.
to work for a competitor. She amenities;
for the purpose of setting or controlling Similarly, LKQ employees may not provide
prices, rates, trade practices, costs or any recently approached me with gifts or entertainment above nominal value, • Paid trips or guest accommodations
other activity prohibited by laws regulating a potentially anti-competitive or any gifts or entertainment that may that involve formal representation
competition. proposal. I refused to engage create the appearance of impropriety. of LKQ (provided prior approval
in the discussion, but I don’t is obtained from the proper
Your Role want to get her in trouble. Your Role supervisory authority)
• Do not communicate with competitors • Do not offer or accept a payment, benefit • Non-cash gifts with a nominal value,
A: Your former coworker
for the purpose of setting or controlling or gift that is intended to improperly such as those received at holiday
has exposed both her
prices, rates, trade practices, costs or influence an outcome. time; or
current employer and LKQ
any other activities prohibited by laws to unnecessary risk. You • Fees or other compensation received
regulating competition. are obligated to report this from an organization in which
• If you find yourself in a situation with incident to Legal. membership or an official position is
a competitor that could create the held, as approved by LKQ.
appearance of improper agreements or
understandings, announce that you are
leaving and why, then promptly inform
your Legal team.
OUR CORE POLICIES 19Bribery and Corruption
BRIBERY AND
CORRUPTION
The Policy Your Role
We are committed to complying with • Follow the Know Your Customer What You Should Know
!
applicable money laundering, bribery, procedures and rules applicable to your Red flags for possible money
corruption and terrorist financing laws business on collecting and verifying laundering include:
and regulations. information from our customers and
related parties. • Offers to pay in cash or overpayments followed by
Money Laundering is the process of hiding requests for refunds.
the proceeds of crime or making the source • Do not make facilitation payments (unless
appear legitimate. you are in fear for your personal safety • Payments on behalf of a customer by an
or liberty). unknown person.
Bribery means giving or receiving anything
of value (financial or otherwise) in order to • Do not offer or accept a payment, benefit • Transactions that might have been structured to
improperly influence or reward any person or gift that is intended to improperly avoid recording or reporting requirements.
in the performance of their duties. influence an outcome. • Orders, purchases or payments that are unusual or
A Facilitation Payment is usually a small • Never contribute LKQ funds or other inconsistent with a customer’s trade or business.
payment (or gift) made to public officials LKQ assets for political purposes without • Unusually complex deal structures.
in order to speed up or “facilitate” actions obtaining prior approval from the
• Unusual fund transfers to or from countries
they should already do as part of their Government Affairs Department.
unrelated to the transaction.
routine job. It doesn’t include fees required
to be paid by law.
Corruption means the abuse of a position
! Red flags for potential
bribery include:
of power or responsibility for profit. • A third party demands its commission payment
prior to winning a deal/contract.
We only do business with customers
involved in legitimate business activities, • Instructions to direct LKQ business through a
with funds derived from legitimate sources. specific representative or partner due to a
“special relationship.”
• Requests to make a payment to a person who is
not related to the transaction being discussed —
or a request that payments be made in
another country.
• Commissions that seem too large in relation to the
services provided.
OUR CORE POLICIES 21Conflicts of Interest
CONFLICTS OF
INTEREST
The Policy
A conflict of interest is any circumstance What You Should Know
where an individual’s personal interest Absent appropriate pre-approval,
interferes or even appears to interfere with LKQ Employees are prohibited from:
the interests of LKQ. We act in the best
interest of LKQ and our customers. We • Taking for themselves opportunities
avoid conflicts of interest and never use that are discovered through the use
our position or company assets for of LKQ property, information
personal gain. or position
• Using LKQ property, information or
Your Role position for personal gain
• Always base business decisions on • Competing with LKQ
what is best for LKQ, not what is best for
you personally.
Q: A position at your business
• Do not use LKQ resources, including opens and you believe
equipment, facilities and time, for your friend would be a great
personal gain. candidate. Can you put
• Obtain prior approval before accepting him forward?
officer or director positions with an
outside business or not-for-profit A: Many of our best hires come
organization. This excludes religious or from employee referrals. You
school affiliations. should mention your friend
to local HR and disclose your
• Disclose financial interests you may have
relationship. You should
in a company where you could personally
ensure that you have no
affect LKQ’s business with that company.
involvement in the recruitment
• Do not accept personal discounts or process and that the position
other personal benefits from suppliers is not one you directly or
that are not available to your LKQ peers. indirectly supervise.
• If you believe you might have a
conflict of interest, disclose it to HR or
your supervisor.
OUR CORE POLICIES 23We Protect
Our Company
Trade
TRADE Protecting LKQ
PROTECTING Speaking onON
SPEAKING
Controllership
CONTROLLERSHIP COMPLIANCE
Compliance LKQProperty
PROPERTY Behalf ofOF
BEHALF LKQLKQ
OUR CORE POLICIES 25Controllership Trade Compliance
TRADE
CONTROLLERSHIP COMPLIANCE
The Policy The Policy
We ensure that our company books, records What You Should Know We comply with all import and export What You Should Know
and financial reporting reflect an accurate As a public company, LKQ’s filings control laws, economic sanctions and Some countries, including the US,
and honest picture of our business. with the U.S. Securities and customs laws that regulate the international impose restrictions on exports and
Financial data we can trust is required not Exchange Commission (the “SEC”) transfer and sale of goods and technology. other transactions with certain
only to comply with our policies, external and other federal and state countries, companies and individuals.
accounting standards and all applicable regulatory agencies must be timely, Your Role Non-compliance can lead to serious
laws and regulations, but also to allow us complete and accurate. • Follow all business procedures relating sanctions, such as large fines,
to make informed decisions to grow our Falsifying records or failing to record to the import and export of goods and revocations of permits to export
business and maintain our reputation. funds, assets or transactions could technology. and imprisonment of the
lead to criminal liability and will not • Follow applicable LKQ policies and relevant individuals.
Your Role be tolerated by LKQ. procedures to ensure we do not do
• Be honest and careful when submitting business with people or companies on Q: My customer is located
expense claims and, where appropriate, Q: On December 31, you receive government restricted party lists. domestically (US, CANADA
timesheets. an invoice that relates to the • Do not cooperate with any boycott or or EU). Do I need to worry
• Ensure that any contractual commitments current year. How should you restrictive trade practice not authorized about what he does with
you make on behalf of LKQ are within handle this invoice? by the US government. LKQ’s product?
your authority level. • Report accurate, complete and timely
A: Either submit the invoice to A: Yes. LKQ Corporation is a
• If you are responsible for preparing information on import declarations. US-based organization and
Accounts Payable on or before
public financial disclosures, make sure US Export laws follow the
December 31 or alert your
that the information we report is clear, product extra-territorially; if
accounting team to accrue
complete and timely. you know or have reason to
the expense in the current
• Execute internal controls assigned to your year. You should not hold the believe that your customer will
position in a thorough manner. invoice until the following year sell the item internationally,
to make your current year you must report the final ship
profitability look better. to/sell to party through Trade
Compliance for screening at
TradeCompliance@lkqcorp.com
and/or any licensing
requirements to the final
destination country.
OUR CORE POLICIES 27Protecting LKQ Property Speaking on Behalf of LKQ
PROTECTING SPEAKING ON
LKQ PROPERTY
The Policy BEHALF OF LKQ
The Policy
We protect LKQ property, including assets What You Should Know Everything we communicate about our What You Should Know
and Confidential Information, and do not LKQ assets include everything that company can have an impact on our Users are prohibited from using
use them for personal gain. our company owns or uses to conduct reputation, coworkers, and brand. We make social media while on work time,
business. Physical and electronic sure the information we communicate is which is the time they are engaged
Your Role assets such as furniture, equipment, reliable, consistent and accurate, which is in work, unless it is being done for
Do: tools, inventory, computer hardware why only certain people are authorized to Company business and with the
and software are provided in order for speak on our company’s behalf. authorization of their supervisor.
• Take steps to protect our IT and
communication systems and assets you to do your job. We use social media in a way that’s You are responsible for what you
against loss, damage or theft “Confidential Information” means consistent with our values and policies. We publish on social media, so exercise
information not publicly available never tolerate the use of social media to good judgment. If you would not
• Promptly report any loss of IT equipment intimidate, harass or discriminate against
or security incidents that you either developed or gained communicate it at work, then don’t
knowledge of as a result of your fellow employees. share it online and, more specifically,
• Maintain the confidentiality of information employment or other association do not:
entrusted to you with LKQ. Examples of Confidential Your Role
• Make comments about co-workers,
Don’t: Information include historical, current • Do not speak on behalf of LKQ, unless customers, vendors, suppliers, and
or potential business, products, you are authorized to do so. members of management that are
• Disclose Confidential Information to a
services, plans, strategies, suppliers, • When communicating with colleagues, obscene, physically threatening
third party without the prior consent of
business relationships, employees, consider carefully which information can or intimidating, or constitutes
senior management
customers, cost or pricing be disclosed to whom. Look at it from a a violation of the company’s
• Use LKQ property for any inappropriate information, internal deliberations, need-to-know basis. workplace policies
or illegal purpose, including accessing, prospects and business or financial
downloading or disseminating material affairs of LKQ. • Do not respond to rumors or speculation. • Make an intentional public attack
which is offensive, sexually explicit, If you are asked to comment, respond on the quality of the Company’s
Where legally permitted, LKQ may “No Comment” or “LKQ does not products and/or services
defamatory, discriminatory, or racially or
review, audit, intercept, access and comment on market rumors as a matter
otherwise abusive • Disclose trade secret information or
disclose information processed of principle.”
• Share your login details with others, or stored on LKQ equipment and proprietary information
including colleagues technology, or other devices with
access to LKQ’s network.
OUR CORE POLICIES 29www.LKQCorp.com ©2020 LKQ Corporation
You can also read
