CODE OF ETHICS
Navigating the LP Code of Business Conduct and Ethics
The Code
Purpose
The purpose of LP’s Code of Business Conduct and Ethics, or Code, is to promote honest and ethical conduct throughout the organization, providing the framework for how we conduct our business, how we interact with one another and our external business partners, how we realize our vision and values, and how we ensure a positive reputation in the marketplace.
Who Must Follow the Code?
Applicability of the Code
Employees, Officers, and Directors of Louisiana-Pacific, or any of its subsidiaries ("LP Personnel") are required to comply with the letter and the spirit of the Code. If you are authorized to conduct business for or on behalf of LP, or any of its entities, including but not limited to, agents, foreign sales representatives, independent contractors, temporary workers, or other third parties, this Code applies to you.
Managing or Supervising under the Code
If you supervise others, you have a heightened responsibility of leading by example and demonstrating, through your everyday actions, how to comply with the Code. Managers are expected to keep lines of communication open so that employees feel comfortable asking questions and reporting concerns. As a leader of people, you are expected to foster a team environment that is open, transparent, and collaborative.
Responsibilities Under the Code
Each of us must be aware of, understand, and comply with LP's Code, the underlying applicable policies, standards, regulations, and laws that apply to our jobs. Though aspects of the Code may be more applicable to some jobs than to others, the underlying principles and values that guide our decisions and actions are relevant no matter what role you occupy. You have a responsibility to read and understand the Code, think about how it applies to your job, and ask questions if you need clarification or more information. Doing the right thing does not stop with doing your own job. Ensuring ethical behavior throughout the workplace is a shared responsibility. LP will provide training to employees on the Code and topics found in the Code including, but not limited to Anti-Corruption and Harassment on an annual basis.
Every person has a part to play. Speaking up is a critical component in safeguarding LP’s assets, its reputation, and our work environment. We rely on all our employees to do the right thing by reporting any concerns that potentially require management’s attention. You have an obligation to speak up if you see or hear of actions that may violate the Code.
The earlier we know about an issue, the better. We understand that speaking up is not always comfortable, and we are appreciative of the collective effort it takes to make an ethical culture a reality.
We rely on all our employees to do the right thing by reporting any concerns that potentially require management’s attention. Do not assume that someone else will raise a concern. We encourage dialog, and any form of retaliation for good faith reports is simply not tolerated.
The Code serves as our shared framework for working with each other and with our external partners in an ethical and legal manner. However, the Code is not intended to answer every question or describe every scenario. When in doubt, ask yourself:
- Is the conduct legal?
- Does the conduct comply with LP’s Code and its policies and procedures?
- Does the conduct serve a legitimate business purpose?
- Will the conduct reflect negatively on LP?
- Will the conduct negatively affect consumers, shareholders, or other employees?
If you see or suspect that an activity that may be a violation of the Code, LP’s policies, or the law, say something. If you are not sure if something that you see or hear is a violation, raise it in any case. Identification is the first step to resolution, and we count on you to do the right thing, whether or not it affects you personally.
Reporting a Concern
Avenues for Help
LP offers numerous ways in which to report concerns. Talk to:
Your Supervisor or Manager
The Human Resources Department
Compliance Department
The Legal Department
Functional area leaders, like Finance, Safety, or Environmental
LP's confidential reporting service
Knowing When to Speak Up
I see or suspect activity that may be a violation.
YES
You should always speak up when you suspect activity that may be a violation of this Code or applicable law.
I have a concern, but I do not have all the details and it doesn't really affect me personally.
YES
You do not need to have all of the facts to speak up and the concern does not have to affect you personally.
I suspect a violation, but I think someone else will report it.
YES
You should never assume that someone else will report it.
I don't have a concern.
NO
You should familiarize yourself with what to do in case you ever have a concern.
If you have an ethics or compliance concern, speaking up demonstrates your care for LP and your co-workers. Speak up if you see or suspect activity that may be a violation of this Code or applicable law.
First Line of Communication
Many issues can be effectively addressed in person, by speaking to your supervisor or a member of your management team. If this is not possible, then you are encouraged to discuss the issue with a member of the business team, or with corporate employees in the relevant functional area such as environmental, safety, finance, human resources, quality, etc.
Confidential Reporting
You may also use LP’s confidential reporting service ("LP Confidential" 800-496-4892 or Click Here), available 24 hours a day, 365 days a year. The telephone number is posted in all Company facilities, and translation services are available for those who wish to report in a language other than English.
Anonymity
You should be prepared to identify your facility and to provide a detailed description of your concern. LP is committed to preserving your anonymity, and no attempt will be made to ascertain a caller’s identity. If you choose to remain anonymous, you will receive a call-back date. You will also receive an identifying code to be used at the time of the call back that you may use for further communication.
Investigating a Concern
What Happens Next?
Every concern is taken seriously. LP is committed to adequately and appropriately responding to allegations of wrongdoing. In some cases, it may be necessary to conduct investigations to determine what happened and the best course of action to take. In such instances, employees are required to fully participate in the investigative process.
Cooperation
LP employees are expected to cooperate if asked to give interviews, answer questions, or provide relevant records and documents for review by the investigator(s). LP’s goal is simple, to detect and prevent misconduct by determining the facts and circumstances related to any investigation and to act in accordance with its findings.
Management’s Role
We are committed to ensuring that those who make good faith reports are not punished for doing so. If you are a manager, you must listen carefully and respectfully to communication from employees reporting to you. You must be open to listening and be diligent to ensure you neither directly nor inadvertently take action to punish the person(s) for communicating or reporting the information. By creating a healthy work environment and maintaining an open-door policy, you help LP achieve its compliance goals, as well as making the Code a part of your teams’ day-to-day operations.
No Retaliation
Zero Tolerance
LP strictly prohibits unlawful retaliation, including any form of discipline, reprisal, or intimidation for participating in any activity protected by the Code or the law. You will not be treated adversely or retaliated against for expressing good-faith concerns about suspected problems or violations of Company policy, the Code, or the law. "Good faith" means you are acting with honest and forthright intentions and without an improper motive, such as personal gain.
Reporting Concerns is Encouraged
LP will not tolerate efforts by managers, supervisors, or co-workers to retaliate against an employee who has reported a concern or to discover the identity of a reporting employee. Likewise, efforts to discourage or prevent someone from filing a concern will not be tolerated. Any such efforts will result in appropriate disciplinary action. LP will investigate any instances of possible retaliation, and will take appropriate disciplinary action.
Frequently Asked Questions
Regardless of who asks you, never do anything illegal. You should always speak up when you suspect activity is occurring that may violate this Code or applicable law. If your concern is not appropriately addressed, you must report it to one of the many options available to you, including the LP Hotline 800-496-4892, LPConfidential.lpcorp.com or your HR representative.
No. As long as you honestly have a good-faith concern, our policy prohibits you from being retaliated against for simply raising your concern. We expect you to voice your concerns and questions about compliance and ethics issues. If you feel that you are being retaliated against, you must contact one of the options available to you
While the Code strives to be comprehensive, it cannot anticipate every situation that you may encounter. For additional information, review the relevant policies, contact the LP Compliance Department, or submit a question through the LP Hotline at 800-496-4892.