Our Code Responsibilities
Using Our Code
Our Code applies to all employees, contingent workers and contractors at ATC. It exists to help guide us when making business decisions. It will not address every applicable law, nor will it give examples of every type of potential misconduct. But it will provide a high-level outline of important compliance obligations, and it will explain where to go for help if questions or concerns arise.
Expectations Around the Code
An understanding of this Code and what it conveys is a critical component of working for ATC.
We expect our employees and contractors to comply with our Code of Conduct, raise questions and concerns, and cooperate during audits and investigations. Failure to comply with this Code, or falsely certifying to it or any other policy, procedure or compliance obligation, will result in disciplinary action, up to and including termination.
This Code of Conduct does not create any contract of employment and may be amended at any time. ATC will properly enforce the Code regardless of the seniority, role or location of those involved in misconduct.
The Code is not intended by ATC, and will not be interpreted or applied by ATC, to prohibit or dissuade employees from engaging in legally protected activities such as discussing wages, benefits or terms and conditions of employment.
The Importance of Speaking Up
Complying with this Code requires all of us to speak up in the event of ethical misconduct or the potential for ethical misconduct. This includes not only speaking up about violations and suspected violations of the Code by others, but also about our own violations or potential violations, even if they were not intentional.
Speaking up is rarely easy. But having the courage to raise our voice when we have concerns about something we or others might have done can have a very positive impact on our company.
And by sharing potential concerns with the appropriate company resources at ATC, we are empowered to deal with any potential issues before more damage is done. Failing to report, or delaying the reporting of, a concern is a violation of this Code.
Callout
There are many resources available to raise a concern. Our Compliance Resources include:
- Your supervisor
- Human Resources
- Policy & Ethics Committee Member
- Ethics & Compliance Helpline (report through atcllc.ethicspoint.com or 866-384-4277)
The Ethics & Compliance Helpline is operated by a third party that routes the information to the appropriate ATC contacts, up to the Audit Committee Chair, based on any named individuals. Employees who make a report to the Helpline can remain anonymous and be given a reference code to follow up on their report.