Company Policy
TERMS OF USE
WELCOME TO THE AXEL JOHNSON INC. (“AXEL JOHNSON”) WEB SITE. PLEASE CONSIDER THE FOLLOWING TERMS OF USE AND DISCLAIMERS CAREFULLY WHILE USING THIS SITE.
Use of this Web site is subject to the following Terms of Use, which may be updated at any time without further notice. By using this Web site you agree to these Terms of Use. If you do not agree to these Terms of Use, please do not use this Web site.
You may download content for noncommercial, personal use only, provided copyright, trademark or other proprietary notices remain unchanged and visible. No right, title or interest in any download materials is transferred to you as a result of such downloading or copying. Axel Johnson may periodically revise information contained in this Web site without any obligation to notify past, current or prospective users, and while Axel Johnson makes every effort to ensure that the information contained in this Web site is accurate and reliable, Axel Johnson makes no warranties or representations as to the accuracy, correctness, reliability or otherwise with respect to such information, and assumes no liability or responsibility for any errors or omissions in the content of this Web site.
As a condition of your use of this Web site, you will not use this Web site for any purpose that is unlawful or prohibited by these Terms of Use, and you agree not to post, relay or send any unsolicited advertising, fraudulent or misleading offers; threaten, harass, defame, embarrass, or distress any person or group; distribute computer viruses, worms, or any software intended to damage or alter any computer system; transmit any pornographic, obscene or vulgar material, or any other material in violation of applicable law or regulation.
AXEL JOHNSON, ITS SUBSIDIARIES AND AFFILIATES EXPRESSLY DISCLAIM ANY WARRANTY OF ANY KIND, WHETHER EXPRESS OR IMPLIED, AS TO ANY MATTER WHATSOEVER RELATING TO THIS WEB SITE, INCLUDING WITHOUT LIMITATION ANY IMPLIED WARRANTY OF MERCHANTABILITY, FITNESS FOR ANY PARTICULAR USE OR NON-INFRINGEMENT. IF YOU DOWNLOAD MATERIAL FROM THIS WEB SITE, YOU DO SO AT YOUR OWN RISK, AND YOU WILL BE SOLELY RESPONSIBLE FOR ANY DAMAGE TO YOUR COMPUTER SYSTEM OR LOSS OF DATA THAT RESULTS FROM THE DOWNLOAD OF SUCH MATERIAL. IN NO EVENT SHALL AXEL JOHNSON BE LIABLE AT LAW OR IN EQUITY FOR ANY DIRECT, INDIRECT, SPECIAL, INCIDENTAL, OR CONSEQUENTIAL DAMAGES ARISING OUT OF ANY USE OF THE INFORMATION CONTAINED HEREIN, INCLUDING, WITHOUT LIMITATION, DAMAGES FOR LOST PROFITS, LOSS OF GOODWILL, LOSS OF DATA, WORK STOPPAGE, ACCURACY OF RESULTS, COMPUTER FAILURE OR MALFUNCTION. YOU AGREE TO INDEMNIFY, DEFEND AND HOLD HARMLESS AXEL JOHNSON FROM AND AGAINST ANY AND ALL CLAIMS, DAMAGES, COSTS, AND EXPENSES, INCLUDING ATTORNEY’S FEES, ARISING FROM OR IN CONNECTION WITH YOUR USE OF THIS WEB SITE.
Axel Johnson maintains and operates this Web site from its offices in New York, New York, United States of America. These Terms of Use are governed and interpreted by the laws of the State of New York, United States of America. By using this Web site you consent to the jurisdiction of the courts located in New York for any action arising from these Terms of Use. Any cause of action or claim, which you may have with respect to this Web site must be commenced within one (1) year after the claim or cause of action arises. If any portion of these Terms of Use is deemed unlawful, void, or unenforceable, then that part shall be deemed severable and shall be construed in accordance with applicable law. Such a term will not affect the validity, and enforceability of any remaining provisions. Axel Johnson’s failure to act with respect to a breach of these Terms of Use shall not constitute a waiver and shall not limit Axel Johnson's rights with respect to such breach or any subsequent breaches.
Return to TopPRIVACY POLICY
The following is Axel Johnson’s privacy policy regarding any personal information that you may supply to us through this Web site. Our goal is to protect your privacy and the information you submit to us through the Internet. Axel Johnson operates this Web site from its offices in New York, New York. All matters pertaining to this Web site are governed and interpreted under the laws of the State of New York, United States of America. By accessing this Web site, you indicate your acceptance of this privacy policy.
Generally, we do not obtain any personally identifiable information about you unless you choose to reveal it to us. "Personally identifiable information" means information that would allow someone to identify or contact you, including, for example, your name, address, telephone number or email address. You are able to voluntarily give us contact information on this Web site, and we also collect data regarding your interest in particular Axel Johnson products or services. We may also collect and store demographic, profile and other statistics and data on an aggregate (collective) basis which is not personally identifiable. Other information may be gathered and logged, including your Internet Protocol (IP) address, the type of operating system (OS) which you are using, your browser type, your (OS) version, and the site that referred you to this Web site.
Our servers also automatically collect generic (general) information about which parts of this Web site users visit, and which pages are viewed, but we do not obtain any personally identifiable information about you. We may use a feature of your browser called a "cookie" to assign a User ID that automatically identifies your computer when you visit this Web site. Cookies are small pieces of information stored on your hard drive, not our Web site. Cookies make your Internet experience quicker and more convenient. You are always free to decline our cookies if your browser permits, but some parts of our Web site may not work properly if you do.
We do not provide your personal information to third parties, except as needed to carry out your requests. We do not sell your email address or your name and personal demographic information to mass marketers. In some cases we use your personal information to provide information to you, such as to send newsletters or brochures at your request. We may also use this data, both aggregated and personally identifiable, to enhance your on-site experience by displaying content and marketing messages that we believe will be of interest to you. Please note that if you provide any personally identifiable information to parties who provide links or services to our Web site, different rules may apply to their use or disclosure of the information you disclose to them. We encourage you to investigate and ask questions before disclosing information to third parties. You can opt out of receiving email about our products and services by contacting the Web site administrator at admin@axeljohnson.com.
Your privacy is very important to us; however due to the current legal, regulatory and security environment, we cannot fully guarantee that third parties will not obtain your communications and personal information. We may be required to disclose information to the government or third parties under certain circumstances, or third parties may unlawfully intercept or access transmissions or private communications. Also, in the unlikely event we need to investigate or resolve possible problems or inquiries, we may disclose any available information to responsible third parties, including law enforcement and other government officials.
We may amend this privacy policy at any time, and will post revisions to this policy on our Web site so that you are aware of the change. Questions regarding content or application of this privacy policy should be directed to the Web site administrator at admin@axeljohnson.com.
Return to TopCODE OF BUSINESS CONDUCT AND COMPLIANCE PROGRAM
It is the objective of Axel Johnson Inc. and all of its subsidiaries, affiliates and employees to operate according to the highest possible standards. All employees have an important responsibility to ensure that their personal conduct is above reproach. The standards set forth in this Code of Business Conduct and Compliance Program will be enforced at all levels fairly and without prejudice. Axel Johnson will keep confidential the identity of employees about or against whom allegations of violations are brought unless or until it has been determined that a violation has occurred. Similarly, Axel Johnson shall take all reasonable steps to keep confidential the identity of anyone reporting a possible violation.
If you have any questions or wish to discuss anything in relation to this Code of Business Conduct and Compliance Program, please call the Company’s General Counsel at 203.326.5225, or your business’s law department.
General Business Ethics
All persons employed by, or associated with Axel Johnson Inc., its subsidiaries and affiliates (the Company), are expected to deal honestly, truthfully and fairly with others in business. False or intentionally misleading statements or omissions of any kind should never be made. False or intentionally misleading entries should never be made in the books and records of the Company.
Confidential Information
Trade secrets and other proprietary information about the Company, its business activities, or its customers and suppliers, and information about such customers and suppliers, should be treated as confidential. Except to the extent legally required, such information, or confidential employee data, should not be disclosed to people inside or outside the Company who do not have a legitimate work-related need to know.
Compliance with Laws
All employees are expected to comply with local, state and federal laws applicable to the Company’s business and operations. This includes among others, all rules and regulations governing environmental, workplace safety, discrimination, and employment matters. Employees working overseas are also expected to comply with the laws of each country in which they operate. The fact that in some countries certain standards of conduct are legally prohibited but such prohibitions are not enforced in practice or that violations are not subject to public criticism or censure does not excuse illegal actions.
Conflicts of Interest - Employees, and their families, should avoid any transaction or business relationship that may create a conflict between their own interests and those of the Company. Employees should not take for themselves personally any opportunity that they have discovered through the use of corporate information or their position with the Company, nor should they use corporate property, corporate information or their position with the Company for their own personal gain. Employees should also refrain from competing with the Company.
A full and timely disclosure of the facts pertaining to a potential conflict of interest will help the Company and its employees avoid problems. In instances where the facts are disclosed and no illegal or unethical conduct is involved, the Company could consent to the proposed activity even though a conflict of interest exists.
Company Funds and Records - The use of Company funds or assets for any unlawful purpose or to influence city, state, municipal, federal or other governmental official is strictly prohibited. Company records must always be maintained and presented accurately and reliably. No false entries may be made in any Company record. Company funds must be accurately accounted for, and no unrecorded fund shall be established for any purpose. Employees whose duties involve verification of expenditures of Company money are responsible for the scrutiny and verification of the legitimacy of all expenditures.
Relationships with Vendors and Customers - All vendors and customers are to be treated honestly and fairly. Normal and proper business relations include the offering by Company employees, where permitted, of properly recorded business meals and entertainment or token gifts which are reasonable in nature, frequency and cost, and intended as a legal, ethical means to develop a better understanding and communications regarding the needs, problems, and operations of the business.
Foreign Practices - In some foreign countries, practices, which the United States would characterize as criminal or corrupt, are accepted or tolerated as part of the political and commercial culture. In some foreign countries, customs require the exchange of gifts. In cases where it is desirable, and lawful, to meet such a requirement, the Company will provide the gift, and any gift received by an employee, other than of nominal value, will become the Company's property. Some foreign countries do not condemn bribery the way we do, and permit or tolerate payments to public officials to influence their exercise of discretion. Not only are such practices contrary to Company policy, they are illegal in the United States, even when committed abroad. Axel Johnson Inc. forbids the offering or receiving of any money or anything of value to or from a foreign official to influence that person in the performance of official functions.
Securities and Inside Information - Important information that is not available publicly about the Company, and its affiliates, particularly Larscom, Inc, or other publicly traded companies with which the Company has business dealings is “Inside Information.” Under U.S. securities law and the law of several other countries, if an employee knows inside information about the Company or a company with which the Company has business dealings, the employee should not buy or sell any securities (including stock) of the Company or the other company until the information is generally known by the public. In addition, that employee should not disclose the inside information to others within or outside the Company who do not have an obligation to maintain confidentiality.
Compliance with Antitrust Laws - Axel Johnson is an ardent supporter of free and fair competition, and forbids any conduct, which would unfairly and unlawfully diminish competition in the marketplace. All employees are expected to comply with the antitrust laws of the United States, and when applicable, the antitrust laws of the countries in which the Company or its subsidiaries operate. It is contrary to Axel Johnson policy to have any discussion, communication, agreement, or understanding with any competitor concerning prices, pricing policy, terms or conditions of sale, territorial markets, production costs, bids or bidding proposals or the like. The provisions of the antitrust laws apply to both formal and informal communications. Employees involved in trade associations, industry groups, or professional shows and exhibits, or other situations allowing for less formal communications among competitors, customers, or suppliers must be especially alert to the requirements of the antitrust laws.
Compliance with Environmental Laws and Regulations - All employees of the Company, its subsidiaries and affiliates will act responsibly and ethically in compliance with all applicable environmental laws and regulations. Environmental laws are very complex and extremely important. All Company operations shall be conducted to protect human health and the environment. Officers and employees responsible for Company facilities or operations shall become familiar with regulatory reporting requirements and shall notify and cooperate with appropriate authorities if an incident occurs which threatens the health or safety of our employees or people in the community. The law department should be immediately notified if such an incident should occur. Axel Johnson policy is to communicate openly and honestly with all regulatory agencies. All Company disclosures and compliance records must be accurate and complete, and no false or misleading statement shall be made to any government agency.
Compliance with Equal Employment Opportunity and Gender Discrimination Laws
The Company will uphold its standards of treating employees fairly and ethically by complying with all applicable Equal Employment Opportunity laws and regulations. Federal and state EEO laws prohibit employment discrimination based on race, color, religion, sex, age, national origin, citizenship status, and disability. Axel Johnson requires its employees to support equal opportunity objectives consistent with federal, state and local legislation and regulations regarding employment. The Company’s policy is to extend recruitment, hiring, promotion, assignment and transfer, compensation and all other aspects of employment to qualified applicants and employees on an equal basis.
The Company also requires all officers and employees to comply with all applicable sex or gender discrimination laws and regulations. Axel Johnson is committed to providing a professional work environment for its employees that is free from physical, sexual, or verbal harassment or discrimination of any kind.
Government Inquiries
The Company’s policy is to fully cooperate with any reasonable demand made in a government investigation, and to refrain from any action, which could be interpreted as an attempt to obstruct or impede any government investigation or enquiry. Any employee who receives an inquiry or other demand, a subpoena, or any other legal document regarding the Company’s business from any governmental agency should notify the Company’s general counsel immediately. No employee should produce any documents without consultation with the Company’s legal counsel. If an employee is requested to submit to an interview in the context of a government investigation, the employee may be entitled to be represented by either the Company’s general counsel or independent counsel provided at the Company’s expense. Employees should contact the Company’s general counsel upon receipt of a request for an interview by government investigators. The Company’s general counsel should also be consulted if any communications are received from any government lawyers or investigators concerning the Company’s business or affairs, or an industry in which the Company or its subsidiaries and affiliates operate.
Compliance with Company Policies
Axel Johnson has established policies and procedures for the handling of various matters including matters addressed in this Code of Business Conduct and Compliance Program. All employees are responsible for identifying and complying with all Axel Johnson policies and procedures, which apply to the employee’s performance of his or her duties. Any employee who is unable to identify the relevant policies and procedures relating to a particular situation should contact his manager, human resources director, or the Company’s General Counsel for additional guidance.
Reporting Procedures
Any employee who becomes aware of any illegal activities, any breach of the Company’s Code of Business Conduct, or any breach of the ethical standards and policies contained in this compliance program is required immediately to report the conduct. This reporting is not only encouraged by the Company, it is required, and the Company pledges that no one who poses an ethical question or concern will face retaliation of any kind. In fact, anyone who does retaliate against someone who reports or questions suspected unethical or illegal behavior shall be subject to disciplinary action up to and including termination of employment.
Employees may report a policy violation to supervisory personnel, your local human resources director, or directly to the Company’s general counsel at 203.326.5225. Supervisory personnel are required to communicate reported violations of this code to the Company’s general counsel, or law department.
If you have any questions or wish to discuss anything in relation to this Code of Business Conduct and Compliance Program, please call the Company’s general counsel at 203.326.5225, or your business’s law department.
Return to TopCOPYRIGHT NOTICE
Unless otherwise noted, the graphic images, buttons, and text contained in this Web site are the exclusive property of Axel Johnson and its subsidiaries. Except for personal use, these items may not be copied, distributed, displayed, reproduced, or transmitted in any form or by any means, electronic, mechanical, photocopying, recording, or otherwise without the prior written permission of Axel Johnson. This site also features logos, trademarks, and service marks (collectively the “Marks”) that are the property of Axel Johnson and its subsidiaries. Nothing contained on this Web site should be construed as granting, by implication, estoppel, or otherwise, any license or right to use any Mark displayed on this Web site without the written permission of Axel Johnson.
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