Good corporate governance is critical to our operating principles of winning with accountability, integrity, and responsibility. A diverse Board of Directors and a foundation of ethical business practices is critical to Turning Point Brands having a winning culture and strategy.

Our Commitment

Turning Point Brands is committed to a diverse Board that reflects the diverse world in which we live. We are committed to business conduct that is based on sound business ethics. Acting with accountability, integrity, and responsibility is at the core of our business conduct. We perform all of our internal business activities to ensure we are conducting our business in an ethical manner while meeting the legal requirements in the countries in which we operate. We commit to only working with those business partners who share these principles.

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Our Approach

Turning Point Brands believes that responsible and ethical business practices are a core foundation for our business and our culture.

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Our Code of Business Conduct and Ethics

Our Code of Business Conduct and Ethics recognizes the importance to the Company of conducting its business subject to high ethical standards and in full compliance with all applicable laws, and even where not required by law, with integrity and honesty, dealing fairly with suppliers, customers, business partners and others. Our Code applies to Turning Point Brands, Inc., and all subsidiaries and entities controlled by it, and the Company’s employees, officers and directors.

We train all employees on our business conduct policies. Our goal is to have all of our employees and suppliers act in accordance with the principles in our policy.

Fair competition

We seek to outperform our competition fairly and honestly. We believe every employee and director should deal fairly with the Company's customers, suppliers, and competitors. No employee or director should take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any other unfair business practice. The purpose of business entertainment and gifts in a commercial setting is to create goodwill and sound working relationships, not to gain unfair advantage with customers, and we believe gift or entertainment should not be given or received as an inducement for unfair business dealings.

Raising concerns and the whistleblower function

We actively engage with stakeholders for input into our business conduct. Turning Point Brands encourages all employees, directors, and other stakeholders to report any potential breach of our Code of Business Conduct and Ethics. Employees are encouraged to talk to supervisors, managers, or other appropriate personnel about observed illegal or unethical behavior or when in doubt about the best course of action in a particular situation. Turning Point Brands also has a whistleblower phone number that provides the opportunity to anonymously report suspicion of non-compliance with the Code of Business Conduct and Ethics. Any employee, director, or other stakeholder who in good faith brings information regarding a violation (or potential violation) will not be disadvantaged or discriminated against in any way. We also will protect against any discrimination or retaliation against any person who in good faith takes appropriate action in response to any concerns or complaints received by them. All reports are taken seriously and will be investigated fully, and appropriate action will be taken if breaches are substantiated.

All violations of the Code of Business Conduct and Ethics raised, along with any actions taken in response, are reported to the Audit Committee. External auditors are also present at the time of these reports. During 2020, we had no breaches of our Code of Business Conduct and Ethics.

Our Suppliers’ Conduct

Although Turning Point Brands does not have a written Suppliers’ Code of Business Conduct and Ethics, we expect and hold our suppliers to the same standards and principles as prescribed in our Code of Business Conduct and Ethics. We seek suppliers who are not only financially sound but ethically sound. We anticipate formalizing a policy regarding our specific expectations of our suppliers’ business conduct and ethics in 2021.

2020 Highlights

In 2020, women represented 29 percent of the Turning Point Brands Board of Directors. In addition, underrepresented minorities represented 43 percent of the Turning Point Brands Board of Directors.

Training on our Code of Business Conduct and Ethics achieved 100 percent in 2020.

There were zero reported breaches of our Code of Business Conduct and Ethics in 2020.

GOVERNANCE 2020 2019
Business Ethics 100% adherence to our Code of Business Conduct and Ethics (CBCE) % of employees who completed CBCE formal sign-offs and training 100% 100%
Number of CBCE allegations 0 0
Number of confirmed CBCE breaches 0 0
Board Diversity % of women representation: Board of Directors 29% 29%
% underrepresented minorities: Board of Directors 43% 43%

In 2019 and 2020, all new hires received training on CBCE during orientation. For 2021, policy will be updated and all training will continue for new hires and refresher training will be given to current employees.

Moving Forward

  • Continue our focus on training and monitoring our Code of Business Conduct and Ethics.
  • Develop and implement a Suppliers’ Code of Business Conduct and Ethics.
  • Continue to review suppliers for the business behavior and practices and take action on potential concerns.