CODE OF ETHICS
Working with External Partners
Transparent Communication
Communicating Only the Facts
Our communications and our behaviors must be based upon facts. It is vitally important that you never misrepresent matters on behalf of the Company. When you are not sure of a fact or cannot describe a matter with certainty, it is important that you communicate the uncertainty. It is improper for you to gain any unfair advantage based upon omission, manipulation, concealment, or misrepresentations.
Cooperation with Government Agencies
Prompt Notification
You are required to promptly notify a supervisor of any contact with or from a government agency or official. Company policy is to cooperate fully and forthrightly with government agencies or departments. Your supervisor will help determine who can most appropriately and effectively respond to the official or agency.
Fair Competition and Antitrust
Antitrust Dos and Don'ts
DOs
Do ensure that discussions at trade association meetings are limited to the points set out in the agenda
Do object to and terminate any discussion that you think is or may be questionable or inappropriate and report it to the General Counsel
Do exercise common sense and careful judgment in all written and oral communications including (but not limited to) internal memos, personal notes, emails, and text messages, and avoid aggressive, ambiguous or speculative language suggesting an anti-competitive intent or purpose. Highlight the pro-competitive purposes for all such collaborative activities.
Do consult Legal any time you have concerns
DONTs
Don’t facilitate any agreements or discussions among competitors about current or future prices, credit terms, discounts, warranties, or production capacities
Don’t discuss, actively divide or allocate markets or customers during trade meetings
Don’t allow bid information to be exchanged among competitors (even historical information)
Don’t allow conversations regarding suppliers to take place
Don’t prepare documents or presentations without considering antitrust implications
LP complies with all aspects of federal and state antitrust laws and with antitrust laws of any foreign country in which it does business. LP Personnel are prohibited from participating or appearing to participate in practices which would restrain trade, lessen, or restrict competition.
Antitrust laws apply to a wide range of activities, including marketing, procurement, contracting, mergers and acquisitions, and the location and operation of facilities. Prohibited activities include participating in:
- Price Fixing
- Group Boycotts of specified suppliers or customers
- Allocating Products, Territories, or Markets
- Limiting or Reducing Production
- Bid Rigging
Violation can lead to severe penalties and criminal sanctions, including heavy fines and imprisonment.
Ask Before You Act
You should ask LP management when there is any question about the legality of a proposed action. If you become aware of a situation that may expose you or LP to liability, you should immediately contact LP’s Legal Department for consultation and advice.
Gathering Competitive Information
Fair Competition
LP understands the importance of fair competition and conducts its business in compliance with all applicable fair competition laws. LP does not seek competitive information by illegal or unethical means or attempt to restrict or distort competition in any way. Actions that have either the object or the practical effect of restricting fair and free competition can carry civil, criminal, and personal liability for you and the Company. Any employee who finds that LP has information that may have been obtained illegally or unethically, such as information provided to us in violation of a confidentiality agreement, should immediately inform the Legal Department.
International Business Conduct – Bribery and Corruption
Anti-Bribery
Corruption and bribery may look like:
GIFTS
Giving small, personal gifts is often a part of local culture. Gifts may not be linked (or appear to be linked) to a competitive bidding process or RFP. Gifts of cash are strictly prohibited.
TRAVEL
Travel, lodging, and legitimate hospitality expenses may be required as part of doing business to promote a product, provide training, etc. Luxury travel or travel for personal entertainment is not permitted.
MEALS
Although doing business over a meal is accepted practice, lavish or frequent meals are prohibited.
ENTERTAINMENT
Invitations to entertainment events (e.g., plays, concerts, sporting events) tend to have limited direct relevance to business and may create an appearance of impropriety.
LP does not permit the offering or receiving of bribes in any format whether you are dealing with government officials, public authorities, business partners, or other third parties.
US Foreign Corrupt Practices Act (“FCPA”) and UK Bribery Act 2010 (“UKBA”) makes it a crime for companies, their subsidiaries, Directors, Officers, employees, and agents (such as independent contractors, general sales agents, customs brokers, immigration agents, and tax agents, among others) to bribe non-US government officials to gain an advantage in obtaining or retaining business.
You may not offer, promise, authorize, give, or accept money or anything of value to or from a third party in an attempt to influence the judgment or the conduct of that person (or entity) for either actual or perceived favorable treatment or advantage.
Must Report Questionable Conduct
All of LP’s employees are responsible for preventing and reporting bribery or other forms of corruption. Any offer or request for a bribe, or anything that may reasonably be perceived as an attempt to improperly influence business decisions or outcomes must be immediately reported to the Compliance or Legal Departments.
Export/Import Control or Trade Compliance
Trade Compliance
We are all responsible for complying with U.S. federal import and export laws and regulations and all applicable laws that govern international trade, which are complex and may change quickly as governments adjust to new political and security issues. If your work is governed by U.S. custom laws, it is your responsibility to understand the laws and regulations that relate to international trade. We also expect our vendors to know and understand the laws that apply to their products, including those of customs and any other U.S. government agencies. If you work in supply chain, you need to make sure you (and our vendors) provide accurate product descriptions, correct tariff classifications, valuation information and country of origin statements for all items we import or export, whenever required. If you have a question or concern, report it immediately.
Political Activity
LP encourages participation in the political process by its employees. However, using Company funds for direct contributions to political candidates is prohibited under the Code and under the law.
Certain corporate-sponsored groups, such as political action committees, also known as PACs, can take voluntary political contributions under specific guidelines. Likewise, individuals are permitted to make voluntary, personal contributions to candidates running for public office, or to volunteer their time in support of candidates.
When individuals are engaging in personal, political activity, they must make it clear that they are not representing the interests of LP. We all must respect the rights of others who exercise their rights of political expression in an appropriate and lawful manner. The Company will not interfere with personal exercise of a political viewpoint in terms of an employee’s private contributions and other support for the candidates or political organization of his or her choice.
Charitable Contributions
Must Benefit Company Interests
Charitable contributions should support corporate objectives, follow giving guidelines and processes, and should support communities in localities where we operate. Charitable donations are meant to benefit the Company and our communities and must avoid the appearance of any conflict of interest or personal benefit to any LP personnel.
Frequently Asked Questions
You should not participate in or remain at a trade association meeting of competitors at which current or future pricing, supply, or capacity is discussed. Clearly voice your objection to such discussions, leave the meeting if the discussion continues despite your objection, and report the incident to LP’s Legal Department. There may be instances at larger trade shows where independent third parties, such as consultants or industry analysts, may permissibly make such presentations, provided they are speaking for themselves and not on behalf of any competitive producer.
There are permissible ways for associations to collect historical data. Contact LP’s Legal Department for guidance before providing any commercial company data to an association.