Ethics & Compliance

/Ethics & Compliance
Ethics & Compliance 2019-06-13T15:25:24+00:00

Our commitment to ethical behavior and compliance

Counterfeiting Alert and Policy

Dangers of Illegal Counterfeiting and Mislabeling Activity

We have discovered on several occasions that Dante Valve products, including the Danco Valves we manufacture, have been: (1) illegally counterfeited; and (2) obtained as used or even as scrap product, but then sold to a consumer as new.  The performance failure rates on such products are likely to be high.  More significantly, these products can pose the potential for catastrophic property damage, serious injury and loss of life.  Government and private industry consumers must be aware of and alerted to the compromised integrity and the existing dangers of procuring counterfeit products sold as authentic or a recycled product, fraudulently represented to be new.

Dante Valve product is carefully designed, manufactured, calibrated and tested to high industry standards for reliable and enduring performance.  The value and quality reflected in our products is a hallmark feature to the customer base we serve.

Consumer Awareness Efforts

Committed efforts to educate our customer base and to make information available to consumers concerning counterfeiting and mislabeling activity is an ongoing concern which we address not only as a part of this website communication, but also in our newsletter, and as other opportunities arise.

Policy Against Counterfeiting

Dante Valve does not authorize any third party to create replicas, counterfeit items, mislabeled items, or unauthorized copies to be listed or otherwise offered for sale.  No third-party person, entity, or vendor is authorized to utilize the Dante Valve or Danco Valve trademark, trade name, logo, or any other identifying mark, imprint, device or any likeness for the purpose of identifying a product as having been manufactured or sold by Dante Valve.

Dante Valve has adopted stringent policies to reduce the occurrence and threats posed to consumers caused by sales comprised of counterfeit and mislabeled valves and other products.  Dante Valve intends to investigate incidents of counterfeiting and the mislabeling associated with its product lines, to report all findings to the authorities having jurisdiction and to fully cooperate with the criminal prosecution of those implicated in such activity.

Protecting our products’ authenticity is of high importance to us.  Industry vendors bear a serious responsibility to source and sell only authentic and properly labeled products.  The sale of counterfeit or mislabeled Dante Valve product can result in legal action, involving both civil claims and criminal penalties.  Dante Valve has engaged with its customers and industry leaders to detect and preclude the sale of counterfeit and mislabeled Dante Valve product.  Please notify our management representatives with any suspicions that a counterfeit or mislabeled Dante Valve product has been sold to you or to any other person or entity.

 

Conflict Mineral Statement

Dante Valve has taken all appropriate measures to comply with the Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) concerning the S.E.C. published conflict minerals rule of August 2012. Dante Valve does not directly purchase raw materials (namely Tin, Tungsten, Tantalum and Gold) that are mined in the Democratic Republic of Congo (D.R.C.) or any of the nine African nations sharing its borders. This requirement flows down through Dante Valve’s existing supplier base.

We confirm that there is no indication that any product(s) manufactured by Dante Valve contain conflict minerals.

 

Ethics and Business Conduct Policy

Dante Valve is committed to maintaining the highest standards of ethical conduct, and to complying with all applicable federal, state and local laws, rules and regulations, including those related to Dante Valve’s business with the Federal Government.

Dante Valve’s Mission Statement establishes the guiding principles by which this Company and its employees are expected to act at all times.  Our Company Vision, “WE PROTECT THOSE WHO PROTECT US!” is driven by our shared commitments to Quality, Responsibility, and Service.

This Code of Ethics & Business Conduct Policy supplements Dante Valve’s Mission Statement and covers key aspects of relevant laws and regulations that affect the Company’s business with the Federal Government.  It reinforces Dante Valve’s commitment to comply with these obligations, conduct business ethically, and ensure all ethics and compliance issues are resolved appropriately according to our stated values, Code of Conduct, corporate policies, laws and regulations throughout our operations.

Set Tone at the Top

All Dante Valve employees share responsibility for implementing this Code of Ethics and Business Conduct Policy.  Management has the added responsibility of demonstrating, through its actions, the importance of this commitment and how to model ethical and compliant practices.  In any business, ethical behavior and fair treatment does not simply happen; it is the product of clear and direct communication of expectations, modeled from the top and demonstrated by example.  Our actions are what matter.

To make this Code of Ethics & Business Conduct effective, managers must be responsible for promptly addressing any concerns regarding ethical behavior or fair treatment raised by employees, and for taking the appropriate steps to deal with those concerns, including escalating any concerns of misconduct to the President of Dante Valve.  Managers should not consider employees’ concerns as threats or challenges to authority, but rather as an encouraged form of business communication.  At Dante Valve, dialogue regarding ethical behavior and fair treatment should be a natural part of daily work.

General Policy and Commitment to Safe and Productive Work Environment

To maintain a safe and productive work environment, all Dante Valve employees are expected to comply with certain guidelines pertaining to conduct and employee relationships. Any behavior that is inconsistent with this Code or that could interfere with job performance or Dante Valve’s operations will not be tolerated and should be reported.

Violations of these standards will be taken seriously and may subject employees to any of the following forms of disciplinary action including verbal warning, written warning, paid or unpaid suspension or termination.  Dante Valve does not guarantee that one form of discipline will necessarily preclude another.  Supervisors have authority to enforce standards of conduct and other Dante Valve policies or procedures. To protect our employees and Dante Valve, employees witnessing a violation are required to immediately report such an incident to a supervisor.

This list is intended to be representative of the types of behaviors and activities that may result in disciplinary action, up to and including termination.  It is not intended to be comprehensive and, therefore, Dante Valve may impose discipline up to and including termination for any other violation or inappropriate conduct not listed below. This policy does not alter the employment-at-will relationship between you and Dante Valve.  This list is not intended to and does not prohibit any conduct that is protected by law.

  • Violation of any of the Company’s policies included in the Company Handbook.
  • Engaging in acts of dishonesty, fraud, theft, or sabotage.
  • Unauthorized possession of property belonging to the Company, a customer or another employee.
  • Fighting, horseplay, practical jokes or other conduct that may endanger or disrupt anyone on our premises or in the course of your job duties.
  • Drinking alcohol and/or the use of controlled substances on the job or during a meal/break period or reporting to work under the influence of alcohol and/or controlled substances or with alcohol and/or with controlled substances in your system.
  • Failing or refusing to cooperate with Company investigations, or providing false information or otherwise interfering with or obstructing a Company investigation.
  • Violating criminal laws on Company premises or while performing Company business.
  • Being convicted of a felony or crime that reflects negatively on your trustworthiness or dedication to personal safety or reasonably may be expected to damage the Company’s reputation in the community.
  • Threatening, intimidating, coercing, harming or otherwise interfering with the performance of employees, applicants, customers, vendors or the general public.
  • Falsifying employment applications, resumes, time records, personnel documents, customer documents, or any other records belonging or relating to the Company, or intentionally giving false information to anyone who makes such records.
  • Insubordination, including refusal to work on an assigned job, refusal to comply with instructions, refusal to comply with Company policies and refusal to work overtime.
  • Displaying rude or indifferent treatment toward or inability to establish sound relationships with customers, third parties, supervisors or other Dante Valve staff, as determined by management.
  • Unauthorized use, including willful or careless waste, damage, removal and destruction, of Company time, materials, property, equipment or supplies.
  • Wasting time, loitering or leaving your place of work without permission during working time.
  • Conduct that reflects adversely on the Company.
  • Disclosing to any person, including television, radio and print media representatives, any confidential information relating to the Company business, customers, finances or trade secrets. (Please see the Confidentiality Policy)
  • Carelessness or neglect of job duties that results in the loss, damage or destruction of the Company, employee or customer property.
  • Performance that does not meet Company requirements or expectations.
  • Violation of safety and health rules.
  • Failing to immediately report any accident, incident, work-related injury, fire or other emergency to your supervisor, and if appropriate, the proper authorities.

Additional Restrictions Related to Dante Valve’s Federal Business

In addition to Dante Valve’s overall commitment to a safe and productive work environment, employees must also comply with various Federal laws and regulations that apply to the work we do for the Federal government.  These include:

  • Prohibition on illegal gifts, gratuities, bribes or subcontractor kickbacks.  In order to comply with unique Government rules on providing items of value to government employees, prime contractors, or subcontractors in connection with any government contract, it is Dante Valve’s policy that neither the Company nor its employees may offer, promise, solicit, or accept improper payments or gifts.
  • Representations and certifications to the Government.  All employees must be certain that all statements, communications, and representations to all Government customers are accurate and truthful.  Dante Valve personnel involved in the performance or administration of any Government contract must ensure that all work is performed in compliance with the relevant contract specifications, requirements and clauses, and that all statements, communications, and representations to Government customers are accurate and truthful.
  • Competition-sensitive information.  The Company and its employees must comply with the Procurement Integrity Act, which prohibits the improper receipt or disclosure of competition-sensitive information before the award of a contract to which the information relates.  This includes any competitor bid or proposal information, information marked with a competitor’s proprietary/confidential restrictive legend, or any government source selection information.  If an employee inadvertently or improperly receives such sensitive information, the information should be immediately quarantined without further dissemination, and immediately reported to management for guidance.

Employees should be aware that there may be other Government restrictions involving Dante Valve’s Federal business, including limits on hiring certain former government employees; personal and organizational conflict of interest; engaging in certain lobbying activity in connection with any Government contract; conducting business with suspended or debarred individuals or entities; paying contingency fees to secure a Government contract; and engaging in anti-competitive or unfair business practices. Any employee who becomes aware of any violation involving these Government restrictions has an obligation to report it.

Questions about Compliance and Issue Reporting

Any employee who has questions about the obligations imposed in this Code of Ethics & Business Conduct, or who suspects or becomes aware of any misconduct or failure by anyone in the Company to comply with the Code or any other applicable law or regulation, should contact one of the following:

  • Employee’s supervisor/manager
  • Any Human Resources representative
  • Outside Legal representative at Wiley Rein LLP
    • Jon W. Burd, Attorney at Law
      • Telephone: 202-719-7172
      • Email: jburd@wileyrein.com
  • Any compliance representative in the areas of Ethics & Compliance
  • President of Dante Valve, Lisa Papini
  • Ethics Hotline
    • Via telephone or email at:
      • Telephone: US 866-432-6837
      • Email: Report@DanteValve.com

Retaliation

Dante Valve will not tolerate retaliation against any stakeholder who reports potential ethics and compliance concerns in good faith (a genuine attempt to provide honest, complete and accurate information, even if it later proves to be mistaken or unsubstantiated). Retaliation includes but is not limited to improper denial of benefits, termination, demotion, suspension, threats, improper poor performance evaluation, intimidation, harassment or discrimination. Retaliation violates both the Code of Conduct and corporate policy, therefore all known or suspected retaliation cases should be reported for investigation and resolution through any of the reporting channels listed above.

Issue Handling

All ethics & compliance issues, regardless of the severity or nature (i.e., simple inquiry), shall be confidentially escalated to the management team to ensure proper oversight of individual reports. This management team includes, at a minimum, the President of the Company who has the overall responsibility for ensuring compliance with this Code of Ethics and Business Conduct.  The management team shall ensure that the resolution of all cases is complete and documented, and that appropriate corrective actions are identified and instituted. Such action can include making a disclosure to the U.S. Government, including a mandatory disclosure.

 

Compliance

Dante Valve, in compliance with California’s Prop 65, has added warnings to its Danco products acknowledging that those products can expose you to chemicals including chromium, which is known to the State of California to cause cancer or birth defects or other reproductive harm. For more information go to www.P65/Warnings.ca.gov.

 

 WARNING: Danco Pressure Relief Valve products can expose you to chemicals including chromium, which is known to
the State of California to cause cancer or birth defects or other reproductive harm. For more information go
to www.P65Warnings.ca.gov.