Steel Plus Network, LLC, is an international association (“SPN”), organized to serve its structural steel fabricator and supplier members. Its purpose is to provide, through its activities, events, and meetings, common ground where fabricators and suppliers can become informed of current developments in the steel fabrication industry and otherwise advance that industry’s contribution.

SPN is not intended to, and may not, play any role in competitive decisions of its members or suppliers, nor in any way restrict competition among participants in the steel fabrication industry.

It shall be the responsibility of every member of SPN to be guided by SPN’s policy of strict compliance with the antitrust laws in all SPN activities, events, and meetings. It shall be the special responsibility of SPN officers and staff to assure that this policy is known and adhered to in the course of activities pursued under their leadership.

To assist SPN staff and all of its officers in recognizing situations which may raise the appearance of an antitrust problem, the Board of Managers will, as a matter of policy, furnish to each such person this Antitrust Policy Statement. Should questions arise as to the manner in which the antitrust laws may apply to the activities of SPN, such questions shall be directed to SPN’s headquarters and/or its counsel, as appropriate.

Antitrust compliance is the responsibility of every SPN member. Any knowing violation of the SPN general rules of antitrust compliance or with this general policy by an SPN member will result in that person’s immediate suspension from the membership in SPN, and immediate removal from any office held.

General Rules of Antitrust Compliance

The following rules are applicable to all SPN activities and must be observed in all situations and under all circumstances without exception or qualification:

1. Neither Steel Plus Network, LLC, nor any activity or event held by SPN, shall be used for the purpose of bringing about or attempting to bring about any understanding or agreement, written or oral, formal or informal, express or implied, among competitors with regard to prices, terms or conditions of sale, distribution, volume of production, territories or customers.
2. No SPN activity, event, or communication shall include discussion for any purpose or in any fashion of pricing methods, production quotas, or other limitations on the timing, costs, volume, production, terms of sale, or allocation of territories or customers.
3. No SPN activity, event, or communication shall include any discussion which might be construed as an attempt to prevent any person or business entity from gaining access to any market or customer for goods or services, or to prevent any business entity from obtaining a supply of goods, or otherwise purchasing goods or services freely in the market.
4. No SPN activity, event, or communication shall include any discussion which might be construed as an agreement or an understanding to refrain from purchasing any raw materials, equipment, services or other supplies from any supplier.
5. In conducting meetings, the Chair and the President shall prepare and follow a formal agenda. Minutes of the meeting shall be distributed to all members. Approval of the minutes shall be obtained from the Board or Executive Committee at its next meeting.
6. Speakers at SPN meetings or events shall be informed of the need to comply with SPN’s antitrust policy in their presentation.
7. In informal discussions at the site of an SPN meeting, event, or activity, but beyond the control of its President, all members are expected to observe the same standards of personal conduct as are required of the SPN in its compliance with these antitrust guidelines.

INTENT

The SPN employee Code of Ethics and Conduct outlines expectations regarding the behavior of employees towards members, customers, stakeholders, and society. SPN stands for the core values of respect, collaboration, and integrity. As such, SPN expects all organization members to be directed by the same values in their judgment and behavior. Open communication and expression should be guided by the desire for a respectful, safe, and collaborative working environment.

We believe SPN should maintain a positive and inclusive experience for everyone. SPN is committed to providing a friendly, safe, and welcoming environment for all participants and expects everyone to treat each other with respect and courtesy. The following Code of Ethics and Conduct outlines our expectations for participant behavior as well as the consequences for unacceptable behavior. We require that all participants abide by this Code within the Network and any Network-related events.

CODE OF ETHICS

Scope

This policy applies to all organizational members regardless of rank or employment type.

Compliance with law

Employees must work to protect the company and its legal interests by complying with all environmental, trading, safety, and privacy laws.

Safety in the working environment

All employees should respect their colleagues, supervisors, and customers. Any discriminatory behavior or harassment will not be tolerated.

Professionalism

Employees must show integrity and professionalism in every aspect of conduct. Personal appearance should project the company’s commitment to professionalism.

Integrity

All employees should fulfill their work with integrity and respect toward our stakeholders. We are all expected to avoid any personal, financial or other interests that may interfere with the quality of work.

Care for the physical environment

Employees should treat company property and their physical environment with respect and care.

Disciplinary Actions

Employees who repeatedly or deliberately fail to follow our code of conduct will meet an appropriate disciplinary action. Following a clear warning, employees who persistently show indecorous behavior may face demotion, reprimand, detraction of benefits, suspension, or termination. Legal actions may be taken in cases of theft, embezzlement, corruption, and other unlawful actions.

CODE OF CONDUCT

Expected behaviour

• Treat others with dignity and respect.
• Refrain from demeaning or discriminatory behavior and speech.
• Be mindful of your surroundings and of your fellow participants.
• Alert SPN Management or staff if you notice a dangerous situation or someone in distress.

Unacceptable behaviour

Unacceptable behavior includes, intimidating, harassing, abusive, discriminatory, derogatory, or demeaning conduct by any attendees of SPN meetings.

Unacceptable behavior will not be tolerated. If someone is deemed to be acting in an unacceptable manner, staff may take any action they deem appropriate, including removing any person from the meetings or related events without warning, as warranted.

If you are subject to unacceptable behavior, notice that someone else is being subject to unacceptable behavior, or have any other concerns, please notify SPN Management or staff as soon as possible.