Code of Ethics

Summary

Telling the Truth

Public Disclosures and Code Compliance

Introduction

Loyalty

Making the Right Choices

Leadership

Ethical Relationships

Questions & Answers

Pride in Our Workplace

Competing Fairly

 
     

Introduction

Being Gateway: Our Code of Ethics

What is it that makes Gateway, Gateway? What does it mean to “be” Gateway? It’s a lot of things.

It’s the values that have guided Gateway from its beginnings:  leadership, caring, honesty.

It’s the values that will guide Gateway in the future: innovation, focus, discipline.

It’s the unique bond between Gateway and our customers. Between Gateway and the communities we live and work in. Between Gateway and our employees. And between employees, one teammate to another.

It’s a feeling, it’s a style, it’s a sense of belonging.

It’s a special blend of freedom—we like it radical—and responsibility—we keep it real.

No doubt about it—Being Gateway is a lot of things.

But the foundation of being Gateway is the simplest idea of all: ethical behavior.

We believe in doing what’s right.

 

The Gateway Code of Ethics

Ethical behavior, by employees or by a company, doesn’t just happen. It must be defined, communicated, supported and enforced.

That’s why we need a Code of Ethics.

This Code of Ethics both spells out the boundaries of ethical behavior and helps answer the inevitable questions that arise when the "rules" meet the real world. It applies to all Gateway employees, executives and board members, wherever they work, whatever they do, and it commits us to the highest standards of conduct in our relationships with each other, with customers, with shareholders, with suppliers and with the communities in which we live and work.

 

The Code isn’t just words on paper: it’s a real-life guide to what the ethical dimension of being Gateway is. It is overseen by Gateway’s Ethics Council, made up of senior executives, and is supported by a formal compliance program to ensure that all of us understand what’s expected of us and that we live up those expectations.

 

Our Code of Ethics is different from other companies’. Instead of focusing on what you shouldn’t be doing, we concentrate on what you should be doing. Just glance at the section headings and you get a pretty good idea of our approach to ethical behavior—and of being Gateway.

 

Leadership…Pride in our workplace…Telling the truth.

Ethical relationships…Competing fairly.

 

What does that add up to? To being Gateway:

- Obeying the law.

- Keeping faith with our customers, shareholders and employees.

- Never betraying Gateway’s faith in YOU by acting against the best interests of the company.

- Communicating honestly.

- Respecting rights to privacy.

- Selecting suppliers based on merit—and merit alone.

- Protecting Gateway’s assets.

- Keeping Gateway a safe and healthy place to work.

- Participating in our communities.

 

But all of that doesn’t just happen. You need a blueprint. And that’s where the Code of Ethics comes in…


Although compliance with the law and our code of ethics is each employee’s personal responsibility, there is a special degree of accountability for gateway’s leaders. A fundamental component of leadership at gateway is to live the principles of ethical behavior, to clearly communicate the ethical dimensi



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