Everyone should enjoy a safe and healthy work environment.  We are committed to ensuring a safe working environment for all employees, clients, and everyone we interact with.  We do this by following strict safety and health rules and practices, including:

• Requiring every location to have an active, associate-led safety program that is strongly supported by its management team 
• Rigorously adhering to the established safety procedures, following safety practices and avoiding shortcuts
• Not tolerating any threats of harm - either direct or indirect - or any conduct that harasses, disrupts, or interferes with another associate's work or performance or creates an intimidating, hostile work environment
• Prohibiting the possession of weapons and other dangerous devices by our associates, contractors, vendors, and visitors at all times on the property of the Company, and by our associates while on the property of its suppliers or its customers; and
• Prohibiting substance abuse.

While compliance with all applicable laws, regulations, and record-keeping requirements is mandatory, Arcella Global seeks to surpass the legal standards. It is our intent to avoid any injuries.  

Arcella Global understands the importance of being a good corporate citizen. We encourage our associates to take advantage of spending one full week of paid time, volunteering in their community for the non-profit or government organization of their choice.  We believe that it is critical for the individual and our communities that everyone spends time giving back on a personal level.

We also believe that we should be conscientious of our responsibilities as state, national, and global citizens.  To this end, we encourage the use of our sabbatical program to travel away from home and to interact, share, learn, and teach in another location and/or culture.As a strong supporter of Liberty, Democracy, Capitalism, and Free Trade, we encourage our employees to understand the impact of our political process on our everyday lives.  We provide additional time as needed beyond our legal obligation for employees to go and vote on all election days.  

We are committed to encouraging our families, our associates and our communities, through education and leadership, to conserve our natural resources and to protect and improve the environment in our daily lives.All Arcella Global associates are expected to conduct themselves in accordance with this policy that includes not only being in compliance with all legal and regulatory requirements, but also participating in efforts to improve the environment. This includes the increasingly efficient use of resources such as raw materials, energy, and water.  

As a company, we expect that all associates treat one another with respect and dignity. Each associate has a unique role in making Arcella Global a better and more rewarding place to work. Our values are richly embedded in this commitment and are backed by our philosophy as outlined in this document.

Equal opportunity and fair treatment extend to all associates. Arcella Global specifically prohibits discrimination on the basis of age, disability, ethnicity, national origin, race, religion, gender or transgender, former military status, sexual orientation, or any other characteristic protected by law.

Decisions are to be based on the individual applicant's or associate's qualifications as they relate to their particular job.

In addition to complying with U.S. Equal Employment Opportunity (EEO) laws, Arcella Global must comply with all other civil rights, human rights, and labor laws around the world where legally applicable.

Arcella Global is committed to providing an environment that values diversity with a conscious desire to achieve understanding, respect, inclusion and continuous learning.  

In addition to covering all associates, Arcella Global's harassment-free workplace policy extends to outside vendors, clients, professionals, and other providers of goods or services to any Arcella Global location worldwide. Note that this policy applies to both work-related settings and company-organized activities outside of the workplace.  

Fraud - or the act or intent to cheat, trick, steal, deceive, lie, or withhold information – is both dishonest and, sometimes, criminal. Intentional acts of fraud are subject to strict disciplinary action, including dismissal and possible civil and/or criminal action.It is important for Arcella Global associates to understand what fraud can entail so associates can recognize it and avoid mistakes. Some examples include:

• Submitting false expense reports
• Forging or altering checks
• Misappropriating assets or misusing Company property
• Unauthorized handling or reporting of transactions
• Making any entry on Company records or financial statements that is known to be inaccurate and/or not in accordance with proper accounting standards or Company guidelines.
• The inappropriate destruction or alteration of Company records.

The legal requirements for conducting business internationally are governed by complex statutes and regulations. It is Arcella Global policy to comply with the legal requirements of each country in which we conduct business, as well as with applicable US laws.There are several areas in which acts carried out in one part of the world can result in prosecution under the laws of another country. The most important of these are:

Antiboycott

The U.S. antiboycott laws generally prohibit US companies and their subsidiaries from cooperating with international boycotts which the United States government does not sanction. US companies and their worldwide subsidiaries must report to the US Government any requests they receive to engage in boycotting activity.

 

Export Control Laws

Arcella Global must comply with all national and multinational export control laws. For example, US export control laws apply to the export and re-export of US goods and technology. Under certain circumstances, these laws prohibit subsidiaries of US companies from dealing directly or indirectly with particular countries with respect to certain transactions.

 

 

Corrupt Practices

Many countries including the EU and U.S. have enacted anti-bribery laws to prohibit payments by or on behalf of persons (including companies and their subsidiaries) to government officials to secure or retain business. In addition, the U.S. Foreign Corrupt Practices Act requires Arcella Global to use proper accounting controls and maintain accurate, reasonably detailed, books and records.

 

 

 

Customs Laws

Customs laws require Arcella Global to determine the correct classification, value and country of origin of all its imports. While specific rules may vary; virtually all countries in which we do business share these requirements.

 

 

Economic Embargoes and Trade Sanctions

Arcella Global must comply with all economic embargoes and trade sanctions imposed by the countries in which we do business. U.S. laws generally prohibit all U.S. persons from conducting business with embargoed countries (e.g., Cuba, Iran) or specifically identified individuals known as Specially Designated Nationals and Blocked Persons (supporters of terrorist activities, etc.) 

 

 

Arcella Global's business information is very valuable and must be protected. Arcella Global associates are expected to respect the Company's proprietary and confidential business and financial information by:

• Maintaining strict confidentiality of sensitive information.
• Not sharing that information with anyone - even another associate - who does not need to know about it or who has not been authorized to receive it other than as required by law.
• Examples of confidential and proprietary information include:
  • Written and oral agreements between the Company and the Company's associates, agents, strategic partners, and/or other third parties.
  •  Intellectual property - such as trademarks, patents, and copyrights.
  • Company financial information.
  • Proprietary software or company-owned coursework, modules, workbooks, software modifications, templates, worksheets, or other programs.
  • Financial and other information about potential acquisitions.
  • Customer lists and agreements, market share data, supplier agreements, and other files.

Information provided to Arcella Global by its customers, suppliers, and other third parties is also very valuable and must be protected. Arcella Global associates are expected to respect such proprietary and confidential information of third parties by treating it with the same degree of confidentiality that would be employed in connection with Arcella Global's confidential and proprietary information.

Note that appropriate permission must be received before using copyrighted works of others, such as music or artwork downloaded from the Internet.

NO ASSOCIATE SHOULD SIGN ANY CONFIDENTIALITY AGREEMENT THAT IS BINDING ON ARCELLA GLOBAL WITHOUT LEGAL DEPARTMENT APPROVAL.

Ownership of Intellectual Property

Any technical innovations, discoveries, system designs, or technical enhancements that an associate designs or conceives while at Arcella Global are the sole property of Arcella Global.

The associate must disclose such discoveries and innovations to Arcella Global.Obligations to confidentiality extend beyond an associate's tenure at Arcella Global. Even after leaving Arcella Global, confidential information may not be disclosed in any way. At the same time, confidential information that may have been obtained at a previous employer, including, but not limited to, trade secrets may not be disclosed to Arcella Global.

Should you have any questions, seek guidance from Arcella Global management or Arcella Global's Law Department.  

Information obtained from public sources is considered to be neither confidential nor proprietary.These public sources include the press, patents, property records, the Internet, and other governmental filings. However, the misappropriation of the "trade secrets" of other companies is a criminal act and can be punishable by fines, imprisonment, or both.When seeking information regarding other companies as an associate or agent of Arcella Global & Company, the following guidelines must be strictly followed:

• Do not enter private property illegally
• Do not employ covert listening or viewing devices or methods
• Do not misrepresent yourself, your intent or your affiliation for the purpose of securing information
• Always respect proper requests for confidentiality
• Do not offer bribes in any form in exchange for information
• The job interview process must never be used for the purpose of seeking company information. Job candidates must be advised against volunteering information that might be considered proprietary by their current or former employer
• Whether by direct contact or through an agent, avoid discussions with associates of competitor companies that might lead to or imply an interest in restraint of trade-pricing, bidding, market allocation, or bribery

As a condition of employment, any outside agent whose job may include the solicitation of information regarding other companies must, within each consulting agreement, commit in writing to abide by the above guidelines.  

To help maintain the integrity of the record-keeping and reporting systems, associates must know the area's record retention procedures, including how data is stored and retrieved. It is the associate’s responsibility to know how to document and report any entries, information or records for which they are responsible.You are expected to comply fully and accurately with all audits, including responding in a timely fashion to requests from or on behalf of Arcella Global's auditors, the Human Resources Department, the Legal Department or senior management for:

• Documents or other sources of information
• Special record-keeping or retention of documents
• Error Reconciliation

It is Arcella Global's policy to advise customers and suppliers of any clerical or accounting errors - and to promptly correct such errors through credits, refunds, or other mutually acceptable means.   

All associates are required to sign a statement annually that they have read and understand Our Commitments. This statement also requires them to state that they are in full compliance with the Commitments. This statement must be returned to the Human Resources Department. 

I have carefully read Our Commitments and understand the importance to the Company of compliance with its provisions. 

I fully realize the importance to the Company of: protecting our Company's reputation; safeguarding proprietary and confidential information; properly handling Company funds, property and records; guarding against sabotage; and of all Company associates adhering to the commitments in this booklet.

I am not and have not been aware of any circumstances of a personal or family nature that would conflict or appear to conflict with the interests of Arcella Global. I have no knowledge of any exceptions to these commitments. I will report promptly any such developments in the future. I fully realize that it is the policy of Arcella Global to observe all laws that govern the conduct of our business, including laws that prohibit unauthorized duplication of copyrighted material, including computer software.I further realize that factual reporting and accounting in all phases of the Company's operations are required both by law and Company practices. 

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