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