Nordson Corporation

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NASDAQ $123.22   +0.00

Ethics and Compliance

Our ethical practices stem from our founders’ unyielding commitment to treat all constituencies the right way.  Ethics and compliance are part of our overall Corporate Responsibility & Sustainability strategy.

Ethics and Compliance


Overview 

Ethical and responsible business conduct is fundamental to our success. The essence of our Code of Ethics and Business Conduct is captured in Nordson Corporation’s Corporate Purpose:

Nordson Corporation strives to be a vital, self-renewing, worldwide organization which, within the framework of ethical behavior and enlightened citizenship, grows and produces wealth for our customers, employees, shareholders and communities.

Our ethical practices stem from our founders’ unyielding commitment to treat all constituencies—shareholders, customers, suppliers, communities and, most importantly, employees—the right way. Our Corporate Values of Integrity, Excellence, Passion for Our Customers, Energy and Respect for People grow out of this commitment and reflect the behaviors we strive to include in every aspect of the way Nordson conducts business.  

Ensuring Ethical Behavior

As a global corporation, Nordson operates in over 35 countries with diverse and ever-changing laws, cultures and practices. We conduct ourselves with integrity at all times and operate in full compliance with the laws and regulations that govern our global business activities. Our unwavering commitment to ethical behavior reflects high standards—those that go beyond what is legally required or even commonly practiced in certain geographies.

Our Code of Ethics and Business Conduct provides the basic guidelines needed to understand our responsibilities in conducting business on behalf of Nordson and making the right decision. 
The Audit Committee of our Board of Directors is responsible for monitoring and evaluating the effectiveness of our Code of Ethics and Business Conduct. Our Vice President, General Counsel & Secretary serves as our Ethics and Compliance Officer. Our practices are implemented and monitored by our Ethics and Compliance Officer, our Global Trade Compliance, Product Compliance and Safety Groups, and other departments, including Legal, Human Resources and Communications.  

Our Code of Ethics and Business Conduct applies to all Nordson directors, officers and employees. Wherever we are located throughout the world, each of us has a duty to meet the standards set out in the Code. We also expect Nordson’s representatives, agents, suppliers and consultants to uphold similar standards whenever operating on our behalf. Our Code clearly outlines expected behavior and is a global policy—available in 12 languages—that all employees, executive management and our Board of Directors agree to follow.  

Our Code of Ethics and Business Conduct aligns with our corporate purpose and includes our expectations on a full range of ethical considerations.  

On an annual basis, all employees are required to attend training on Nordson’s Code of Ethics and Business Conduct and sign an acknowledgement form that they have read and understand the Code. We integrate our Code into all newly acquired companies. For further information, visit our Ethics & Responsibility page. 

Compliance & Training

We comply with national and international laws, including U.S. Export Administration Regulations; the European Union Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) initiative; International Traffic in Arms Regulations (ITAR); Restriction of Hazardous Substances Directive (RoHS); California Transparency in Supply Chains Act of 2010; and the UK Modern Slavery Act. Our facilities also comply with the Automated Export Systems (AES), which is used by U.S. exporters to electronically declare their international exports. These export declarations are known as Electronic Export Information (EEI), and are reported to the Census Bureau to help compile U.S. export and trade statistics. This information is also shared with the Bureau of Industry and Security Directorate of Defense Trade Controls, and other federal agencies involved in monitoring and validating U.S. exports. 

Nordson’s Global Trade Compliance Policy, Conflict Minerals Policy and Supplier Code of Conduct supplement our adherence to the aforementioned regulations. To ensure our employees understand the implications of these laws and policies, we hold training sessions for all employees globally in multiple languages using live training sessions and online software.  

Performance 

Nordson closely incorporates the Department of Justice Checklist for a Company FCPA (Foreign Corrupt Practices Act of 1977, as amended) Compliance Policy. For comparison, we outline the elements of an effective compliance program and Nordson’s program components below.
 

Department of Justice
Elements of An Effective Compliance Program

Nordson Program Components

Element #1

Adopt a formal company compliance policy and conduct regular audits of it to ensure up-to-date compliance procedures.

  • Our Code of Ethics and Business Conduct outlines Nordson’s Compliance Policy, including provisions on worldwide anti-corruption laws and the FCPA.
  • Our Gifts and Entertainment of Government Officials Policy mirrors and enforces the requirements outlined by the FCPA.
  • Both of the above policies are available to employees worldwide in 12 languages on Nordson’s intranet.
  • We provide online and live training sessions on these policies in multiple languages, including hearing- and seeing-impaired facilitation, at our locations around the world.
  • We conduct audits of our compliance policies on a regular basis to ensure up-to-date compliance procedures.
  • We invest significant resources to ensure compliance with our programs.

Element #2

Train employees in FCPA compliance and cultivate a culture of compliance among the company employees and executive officers.

  • We partner with Navex Global® to provide interactive online training to employees worldwide on FCPA compliance through role-playing scenarios and question-and-answer sessions. Training occurs multiple times throughout the year and targets portions of Nordson’s workforce for whom FCPA training is most applicable. For example, finance and sales employees receive specialized training on recognizing violations of the FCPA and ensuring compliance with the FCPA. Additionally, our Law department conducts live training around the world on both a periodic and as-needed basis in jurisdictions of heightened risk.
  • We periodically publish FCPA compliance information on our intranet and in targeted security bulletins delivered via intercompany email.
  • Senior and middle management demonstrate their shared commitment to the Company’s compliance program.
  • Our Ethics and Compliance Officer has significant years of experience in corporate compliance and is well-qualified for her responsibilities. She annually reports on our compliance programs to our Board of Directors.

Element #3

Provide methods to address possible FCPA violations.

  • Our anonymous, toll-free external helpline enables employees to report any suspected violation of the FCPA or any other provision of the Code of Conduct. It is accessible 24/7 online or by phone.
  • We conduct a complete analysis when misconduct occurs or is detected to identify root causes and systemic issues.
  • We quickly remediate any misconduct to ensure that there is no reoccurrence.

Element #4

When entering a business relationship in a foreign country, engage local counsel.

  • We engage local counsel as needed when entering into business relationships abroad, including when Nordson enters into Merger & Acquisition transactions.

Element #5

Review all intermediaries.

  • We utilize a third-party process to conduct background checks on firms or individuals before engaging new sales representatives, distributors or agents.
  • We communicate expectations for our intermediaries to comply with the Code of Conduct and require periodic online ethics and FCPA training via Navex Global®.

Element #6

Keep accurate books and records.

  • We maintain records of all employee training sessions, due diligence efforts and FCPA internal investigations and compliance reviews, as well as accurate books and records that fairly reflect our transactions.
  • Our Audit department maintains a thorough system of internal accounting controls.

Nordson conducts multiple global online training modules for employees each year. Examples of recent modules are listed below, and our overall completion percentage has increased for four consecutive years.

Ethical Choices: Thinking Things Through
International Trade Compliance
Workplace Health & Safety
Sexual Harassment: What Leaders Need to Know

Online Training Module Completion Percentage

online training

Highlights

In May of 2014, Nordson’s Swainsboro, Georgia facility received the Presidential Award for Exports (“E” award). The “E” award is the highest recognition for any U.S. entity for making a significant contribution to the expansion of U.S. exports. U.S. Secretary of Commerce, Penny Pritzker presented the award to our Swainsboro team.

Three of our locations—Amherst, Ohio, Duluth, Georgia, and Swainsboro, Georgia, have been Level 2 certified for imports only in the Customs-Trade Partnership Against Terrorism (C-TPAT) since September 2003.

AES Completion Rate