Open and Honest Communication

Open and direct communication helps bring alive our value of respect for individuals. First and foremost, it means we listen. We listen to each other, we listen to our suppliers, and we listen to our customers. We listen because communication—and the possibilities it presents—is as much about listening as it is about talking.

 

We also are open to questions and, in turn, we feel comfortable in raising questions. It is important that we understand the needs of both our internal and external customers. Asking questions is paramount to obtaining that understanding.

 

We value differences in opinion, because out of diversity comes better ideas, improved products and a collective sense of accomplishment. Although we may disagree with one another, we acknowledge that healthy debate is important and always keeps the communication channels open.

 

When communication takes the form of a concern or complaint, we know that we can take that concern or complaint to our manager. And, if the concern or complaint is about the manager, or if the manager can't solve the problem, we can take it to higher management, to the Human Resources department without fear of retaliation.

 

Open communication and respect operate on another level, as well. It means we take responsibility for what we say and do. If we make commitments—whether they're to each other, to customers, or to others—we keep them. If we're going to be absent from work, we promptly tell a manager so arrangements can be made. We're also honest with our work time, because we know that others count on us to do our share in achieving Gateway's mission.

 

Respect for All

Gateway is dedicated to providing a work environment free from discrimination, intimidation, harassment and violence. What this means is that Gateway has policies in place to achieve this purpose and we also comply with applicable state and federal fair employment laws. Gateway does not discriminate in any aspect of employment and will act in good faith, in accordance with the law, to provide reasonable accommodations to the known physical and mental limitations of otherwise qualified individuals with disabilities.

It also means that we won't tolerate conduct by anyone that creates an unsafe, hostile, intimidating or offensive work environment. Such conduct includes, but isn't limited to, racist, sexist or derogatory comments or jokes; derogatory comments or gestures based on age, sexual orientation or disability; unwelcome sexual advances or requests for sexual favors in conjunction with employment decisions; pictures, jokes or statements, whether in person, on the phone or electronically. We understand that such conduct is outside the scope of our duties to Gateway and constitutes a serious violation of this Code of Ethics.

 

If you believe you are the victim of discriminatory or harassing conduct, discuss the situation with your manager. In addition, any manager who receives such complaints must contact the Human Resources department. All complaints will be investigated promptly and without retaliation.

 

Assuring a Safe and Healthy Workplace

Occupational Health and Safety (OH&S) is an important concern to all of us. OH&S, however, is not reactive, it's proactive. It requires commitment, thought, planning, caring, common sense, teamwork and smart execution on behalf of every employee.

 

Our concern for safety at Gateway is proactive. We're committed to making Gateway work environments healthy and safe—and that means specific actions:

1. We will comply with all applicable laws and regulations relating to health and safety in the workplace.

2. We will design operations to provide a workplace free from recognized hazards and ensure employees are properly trained on safety requirements and are held accountable for their safety performance.

3. We will instill an OH&S culture throughout all our work environments that promotes continuous improvement and eliminates work-related injuries, illnesses and associated expenses.

 

A safe and healthy work environment goes beyond work conditions — it also means working together to prevent violence against employees.

 

Two areas of dangerous conduct are forbidden under any circumstances:

• Possession of firearms, explosives, toxic or dangerous chemicals, ammunition or other weapons anywhere on Gateway property or while conducting Gateway business.

• Threatening or violent conduct, or even the suggestion of such conduct toward others.

 

Gateway believes in a drug-free workplace. This means, among other things, that Gateway specifically prohibits the use, possession, distribution or sale of illegal drugs or alcohol. Exceptions to this policy—and only in the case of alcohol for a business-related event, never drugs—can be made only by a Gateway senior vice president or above.

 

In addition, such conduct outside of work is prohibited if it:

• Affects an employee’s safety on the job;

• Interferes with job performance;

• Compromises the safety of others; or

• Would affect the reputation of Gateway with the general public or threaten Gateway’s integrity.

 

Reporting Violations of the Code of Ethics

Responsibility for creating the workplace we all want is shared by everyone who works at Gateway—and that means taking action if you see someone breaking faith with what it means to be Gateway.

 

So, if you observe or learn of unethical business conduct or the commission of any dishonest, destructive or illegal act at Gateway, contact your manager, Human Resources, the Ethics Help Line, or the Gateway Law Department. You may make your report anonymously. All reports will be investigated.

 

No retaliation against individuals who report suspected violations in good faith will be tolerated, and the identity of those making such reports will be protected to the extent consistent with the law and Gateway policy. Because Gateway believes so strongly in ethical behavior and the highest standards of integrity, violations of this Code, the compliance program or other Gateway policies will result in discipline, up to and including possible dismissal or even criminal and/or civil penalties.

 

We don’t just take ethical behavior seriously at Gateway—it is a fundamental part of being Gateway.