We comply with laws and regulations wherever we operate, and we exceed those legal structures by practicing a high standard of business and personal ethics.
Our Corporate Conduct and Ethics Code (Ethics Code) reaffirms our continuing commitment to act with integrity. It outlines our responsibilities to all our stakeholders, guides our decision-making, and outlines the minimum business standards we apply across our value chain. We work to instill the concepts of our Ethics Code in every employee. All employees acknowledge their review of the Ethics Code at the time of their onboarding. Additionally, certain employees, including management, supervisors, and procurement leads, are required to complete an annual review of the Ethics Code, including an attestation of their compliance. We also expect our suppliers and contractors to uphold the same legal and ethical standards and have established these requirements in our Supplier Code of Conduct.
ANTI-CORRUPTION AND ANTI-BRIBERY: All employees are prohibited from accepting favors of other than nominal or token value from suppliers, contractors, customers, competitors, or others in a position to attempt to influence Company decisions. This prohibition applies to money, gifts, loans, unusual hospitality, or any other personal gain. We prohibit the use of Company assets for bribes, kickbacks, or other improper payments.
CONFLICTS OF INTEREST: PotlatchDeltic recognizes that Company transactions must be in the best interest of the Company and its shareholders. Directors and employees must avoid activities involving unauthorized use of Company time, equipment, or information that in any way conflict with the Company’s interests or compromise its integrity or reputation.
SECURITIES LAW COMPLIANCE / INSIDER TRADING: Directors, officers, and employees, including related persons, are expected to adhere to strict requirements surrounding insider trading. Transactions based on material non-public information are prohibited. From time-to-time, trading blackouts are imposed on insiders with specific information. Directors, officers, and certain employees in a position to have access to material non-public information must obtain clearance from the General Counsel before trading in Company stock and may only conduct such transactions during open trading windows.
ANTITRUST: PotlatchDeltic is committed to strict adherence to the letter and spirit of the antitrust laws. At a minimum, each employee who has a sales, purchasing, or planning responsibility must have read and be familiar with our pamphlet entitled Antitrust Compliance Rules and Guidelines, which sets forth our Antitrust Compliance Policy. PotlatchDeltic also conducts antitrust compliance training for sales, purchasing and other groups.
AUDIT AND ACCOUNTING / WHISTLEBLOWER: Full, fair, accurate, timely, and understandable disclosures in our public communications, including the periodic reports filed with the Securities and Exchange Commission and other governmental authorities, are legally required and are essential to our success. Each employee shares responsibility with management and the Board of Directors to maintain the integrity of the Company’s financial records and reporting processes. Whistleblower procedures have been established for the receipt, investigation, and reporting to the Audit Committee of any complaints regarding audit, accounting, or internal accounting controls.
REPORTING: PotlatchDeltic provides a Hotline, maintained by an independent third-party, for stakeholders to anonymously report any suspected violation of the law or breach of established policies and procedures. After a report is made, a written report is sent to the Law Department. Reports in which an allegation of fraud is made are also sent directly to the Chair of the Audit Committee of the Company’s Board of Directors.