Code of Business Conduct

This code sets out how TPML Automation, Inc. (TPMLA) does business. It applies to every TPMLA employee, officer and director, and to anyone who acts for TPMLA, such as a contractor or a Certified Integrator when they represent TPMLA to a customer.

It sits alongside TPMLA-HR-001 Employee handbook, which covers employment matters. Where this code, the handbook, the law or a customer's own rules set different standards, follow the strictest.

TPMLA shares this code with customers, suppliers and Certified Integrators when they ask for it. Section 12 sets out what TPMLA expects of its own suppliers.

Be honest, follow the law, and keep every promise TPMLA makes inside what TPMLA actually does. If you are not sure whether something is right, stop and ask the President before you act. Asking is never the wrong answer.

3.1TPMLA supplies and services the ROKAE robot arm. It does not design, build, install, commission or sign off on automation cells. No one at TPMLA may say or imply otherwise, in a quote, an email, a meeting or on a plant floor (TPMLA-SVC-001).

3.2Describe ROKAE products accurately. Use ROKAE's published specifications, and never claim a certification, listing, test result or performance figure that TPMLA cannot show in writing (TPMLA-SAF-003).

3.3Never promise a warranty, delivery date, price or service level beyond what TPMLA's written terms support (TPMLA-CTR-001, TPMLA-CTR-002, TPMLA-CTR-011).

4.1Never offer, promise, give, ask for or accept anything of value to win or keep business improperly, or to influence a decision. This applies to government officials, including customs officials, and to buyers, engineers and managers at private companies alike. The U.S. Foreign Corrupt Practices Act and similar laws apply wherever TPMLA does business.

4.2Do not make facilitation payments to speed up a routine action, such as a customs clearance, even if someone says it is normal.

4.3Gifts and hospitality must be modest, infrequent and given openly, and never while a quotation, bid or tender with that party is open. Many customers have stricter rules for their own staff; follow them. Tell the President about any gift or hospitality given or received worth more than $100 (TPMLA-HR-001 §7.4).

4.4Anyone who deals with officials on TPMLA's behalf, such as a customs broker or consultant, is engaged under a written agreement approved by the President, and is held to this section.

5.1Win business on product, price, service and honesty. Never agree with a competitor, formally or informally, on prices, bids, territories or customers, and never share TPMLA's pricing or bidding plans with a competitor.

5.2Do not obtain a competitor's confidential information improperly, and do not make false statements about a competitor or its products.

6.1As importer of record, TPMLA declares every import accurately: classification, value, quantity and country of origin (TPMLA-TRD-001, TPMLA-TRD-002, TPMLA-TRD-005). Never under-declare, misdescribe or mislabel goods to reduce duty or avoid a restriction.

6.2Screen customers, integrators and known end users against U.S. restricted party lists before quoting or shipping (TPMLA-TRD-004). Do not sell to a prohibited party, a sanctioned destination or for a prohibited end use, and do not help anyone else to.

6.3TPMLA will not knowingly import goods made in whole or in part with forced labor. TPMLA asks its suppliers for the supply chain information needed to show this, and keeps it with the import file.

6.4Keep customs records for the period TPMLA-TRD-003 requires.

7.1TPMLA does not use forced, bonded, prison or child labor, and does not do business with anyone it knows does.

7.2TPMLA pays at least what the law requires, records working time accurately, and treats people without discrimination or harassment (TPMLA-HR-001 §3 and §4).

7.3Treat customers', integrators' and suppliers' people with the same respect you expect at TPMLA.

8.1Safety comes before schedule. Anyone may stop work they believe is unsafe and will never be criticized for it (TPMLA-HR-001 §6).

8.2Follow each customer site's safety rules and induction. Report any injury, near miss or safety concern the same day (TPMLA-INS-004).

9.1Follow the environmental laws that apply to TPMLA's work, and handle packaging, batteries, lubricants and replaced parts responsibly and as local rules require.

9.2When a customer asks about TPMLA's environmental practices, answer accurately. Do not claim a measurement, target or certification TPMLA does not have.

10.1Keep books, time records, service reports, customs entries and every other record complete and accurate. Never falsify, backdate or destroy a record to hide something.

10.2Customers' information and TPMLA's own pricing and supplier terms are confidential (TPMLA-HR-001 §7.1 and §7.2). Protect personal information and TPMLA systems as TPMLA-GOV-007 requires.

10.3Keep records for the periods in TPMLA-GOV-003, and never destroy a record that is subject to an audit, claim, investigation or legal hold.

11.1Tell the President before doing paid work for, or holding a significant interest in, a customer, integrator, competitor or supplier of TPMLA (TPMLA-HR-001 §7.4).

11.2TPMLA is a subsidiary of Borgdorff Management, Inc. and shares ownership with other companies. Dealings between TPMLA and those companies follow written intercompany agreements (TPMLA-GOV-002), and TPMLA discloses them to a customer that asks.

12.1TPMLA expects its suppliers, contractors and Certified Integrators to meet the standards in Sections 4 to 10 of this code, and flows them down in its agreements (TPMLA-CTR-005, TPMLA-CTR-010).

12.2TPMLA may ask a supplier or partner for information to confirm it meets these standards, and may end a relationship over a serious breach.

13.1TPMLA funds, property and time are not used for political contributions or campaigns without the President's written approval and compliance with the law. Your personal political activity is your own, on your own time.

13.2Only the President speaks for TPMLA to the media, investigators or regulators (TPMLA-HR-001 §7.5).

14.1If you think something breaks this code or the law, say so. Tell the President, in person or by email to njborgdorff@tpmlauto.com. If the concern is about the President, email S. Sundaram at ssundaram@tpmlauto.com.

14.2You do not have to give your name. You may send a concern by email from a personal account that does not identify you. TPMLA will not try to find out who sent it.

14.3TPMLA looks into every concern promptly and as confidentially as it can, and acts on what it finds.

14.4No one is penalized for raising a concern in good faith or for helping with an investigation. Retaliation is itself a breach of this code.

14.5Nothing in this code stops anyone from reporting a possible breach of law to a government agency, or requires them to tell TPMLA first.

A breach of this code may lead to discipline, up to and including dismissal, and may be reported to the authorities where the law requires it. A serious breach by a supplier or partner may end the relationship.

Every TPMLA employee, officer and director acknowledges this code in the TPMLA document repository, within 10 working days of each new revision or before starting work, whichever is first (TPMLA-QA-001). The President reviews it at least once a year.