UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM
CURRENT REPORT
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Indicate by check mark whether the registrant is an emerging growth company as defined in Rule 405 of the Securities Act of 1933 (17 CFR §230.405) or Rule 12b-2 of the Securities Exchange Act of 1934 (17 CFR §240.12b-2). Emerging growth company
If an emerging growth company, indicate by check mark if the registrant has elected not to use the extended transition period for complying with any new or revised financial accounting standards provided pursuant to Section 13(a) of the Exchange Act. ☐
Item 5.05 Amendments to the Registrant’s Code of Ethics, or Waiver of a Provision of the Code of Ethics.
On August 14, 2019, as part of a comprehensive review of the corporate governance policies of the Company, the Board, upon the recommendation of the Corporate Governance and Nominating Committee, approved a new Employee Code of Conduct (the “Code of Conduct”). The Code of Conduct was adopted to, among other things, (i) address recent developments in applicable law and regulatory guidance, (ii) improve its focus on the Company’s core values and take into account our previously announced Flowserve 2.0 Transformation program, (iii) reduce complexity and improve readability in order to make the Code of Conduct more accessible to a global and diverse employee base, (iv) provide additional clarity on acceptable and unacceptable behaviors and actions, including through the use of practical hypotheticals, and (v) make other technical, administrative, and non-substantive amendments to the Company’s existing Code of Business Conduct. The Code of Conduct applies to all directors, officers, and employees of the Company and its subsidiaries, establishing basic standards of business practice, as well as professional and personal conduct that are expected of all covered persons.
The adoption of the Code of Conduct did not relate to or result in any waiver, whether explicit or implicit, of any provision of the existing Code of Business Conduct. A copy of the Code of Conduct is available on the Company’s website at www.flowserve.com, under the “Corporate Governance” tab of the “Investors” menu. The contents of the Company’s website are not incorporated by reference in this report. The foregoing summary of the Code of Conduct is subject to and qualified in its entirety by reference to the full text of the Code of Conduct, attached hereto as Exhibit 14.1 and incorporated herein by reference.
| Item 9.01 | Financial Statements and Exhibits. |
| (d) | Exhibits. |
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Description | |||
| 14.1 |
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Cover Page Interactive Data File (embedded within the Inline XBRL document). | |||
SIGNATURES
Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the undersigned hereunto duly authorized.
| FLOWSERVE CORPORATION | ||||||
| Dated: August 15, 2019 |
By: |
/s/ Lanesha T. Minnix | ||||
| Lanesha T. Minnix | ||||||
| Senior Vice President, Chief Legal Officer and Corporate Secretary | ||||||
Exhibit 14.1 Flowserve Code of Conduct InternationalExhibit 14.1 Flowserve Code of Conduct International
TABLE OF CONTENTS Contents OUR VALUES ...............................................3 INTEGRITY IN INTEGRITY IN DEALING OUR COMPANY .................................... 15 WITH OTHERS ....................................... 21 A Message From Our CEO .........................................4 OUR We Maintain Accurate Business and Our Relationships With Business Partners Our Purpose, Values and Behaviors .........................5 Financial Records .....................................................16 Are Based on Integrity and Trust ............................22 VALUES Our Code of Conduct ................................................6 We Protect Flowserve’s Assets ...............................17 We Compete Fairly in the Marketplace ..................23 Our Ethical Responsibilities We Safeguard Our Intellectual Property We Prohibit Bribery and Corruption .......................24 as Employees ..............................................................7 and Confidential Information ................................... 18 We Follow Our Policies on Gifts, Our Ethical Responsibilities We Do Not Trade on Insider Information ...............19 Travel and Entertainment ........................................25 as Leaders ..................................................................8 We Speak on Behalf of Flowserve Through We Comply With International Trade Laws ............27 How to Ask for Help or Raise Concerns...................9 Designated Spokespersons ....................................20 INTEGRITY We Deal Honestly and Fairly With Governments ....29 IN OUR INTEGRITY IN We Invest in Our Communities ................................30 PEOPLE OUR PEOPLE .......................................... 10 We Respect People .................................................11 We Promote a Culture of Safety .............................12 We Avoid Conflicts of Interest .................................13 We Protect Personal Data .......................................14 INTEGRITY IN OUR COMPANY INTEGRITY IN DEALING WITH OTHERSTABLE OF CONTENTS Contents OUR VALUES ...............................................3 INTEGRITY IN INTEGRITY IN DEALING OUR COMPANY .................................... 15 WITH OTHERS ....................................... 21 A Message From Our CEO .........................................4 OUR We Maintain Accurate Business and Our Relationships With Business Partners Our Purpose, Values and Behaviors .........................5 Financial Records .....................................................16 Are Based on Integrity and Trust ............................22 VALUES Our Code of Conduct ................................................6 We Protect Flowserve’s Assets ...............................17 We Compete Fairly in the Marketplace ..................23 Our Ethical Responsibilities We Safeguard Our Intellectual Property We Prohibit Bribery and Corruption .......................24 as Employees ..............................................................7 and Confidential Information ................................... 18 We Follow Our Policies on Gifts, Our Ethical Responsibilities We Do Not Trade on Insider Information ...............19 Travel and Entertainment ........................................25 as Leaders ..................................................................8 We Speak on Behalf of Flowserve Through We Comply With International Trade Laws ............27 How to Ask for Help or Raise Concerns...................9 Designated Spokespersons ....................................20 INTEGRITY We Deal Honestly and Fairly With Governments ....29 IN OUR INTEGRITY IN We Invest in Our Communities ................................30 PEOPLE OUR PEOPLE .......................................... 10 We Respect People .................................................11 We Promote a Culture of Safety .............................12 We Avoid Conflicts of Interest .................................13 We Protect Personal Data .......................................14 INTEGRITY IN OUR COMPANY INTEGRITY IN DEALING WITH OTHERS
TABLE OF CONTENTS Our Values A Message From Our CEO Our Purpose, Values and OUR Behaviors VALUES Our Code of Conduct Our Ethical Responsibilities as Employees Our Ethical Responsibilities INTEGRITY as Leaders IN OUR How to Ask for PEOPLE Help or Raise Concerns Our Code of Conduct isn’t just about how we work. It’s about how we interact with each other and the respect we INTEGRITY show for the people and IN OUR COMPANY communities we serve. INTEGRITY IN DEALING WITH OTHERS 3TABLE OF CONTENTS Our Values A Message From Our CEO Our Purpose, Values and OUR Behaviors VALUES Our Code of Conduct Our Ethical Responsibilities as Employees Our Ethical Responsibilities INTEGRITY as Leaders IN OUR How to Ask for PEOPLE Help or Raise Concerns Our Code of Conduct isn’t just about how we work. It’s about how we interact with each other and the respect we INTEGRITY show for the people and IN OUR COMPANY communities we serve. INTEGRITY IN DEALING WITH OTHERS 3
TABLE OF A Message CONTENTS From Our CEO A Message From Our CEO Dear fellow employees, Our Purpose, Values and OUR For more than 200 years, Flowserve has been a leader in the fluid motion and control industry, delivering quality products Behaviors VALUES and industry-leading solutions. Our success is founded on our collective commitment to our core shared values – People, Our Code Safety, Integrity, Innovation, Ownership and Excellence. By upholding these values in all that we do, we build trust and of Conduct brand loyalty with our customers and business partners, and demonstrate that we are committed to conducting business Our Ethical in an honest, ethical and transparent manner. Responsibilities as Employees With more than 17,500 employees operating in 300+ locations around the world, our continued success depends on each one of us. The decisions you make and the actions you take every day impact how the world views Flowserve. Our Ethical Responsibilities By embracing our Global Integrity, Local Ownership mindset and consistently upholding our values, you contribute to INTEGRITY as Leaders Flowserve’s reputation for integrity, honesty and excellence. IN OUR How to Ask for PEOPLE Our Code of Conduct, or Code, is designed to help you understand our ethical expectations. I encourage you to carefully Help or Raise Concerns read and use it to guide your decisions and actions. While our Code cannot cover every possible situation you may face, it does define the standards and behaviors we expect from all employees. Speak up if you have a concern and seek guidance if you are unsure about the right thing to do. We are proud of the legacy we have built together at Flowserve. By putting our Code and values into practice in all that you do, we can be confident in our continued success. INTEGRITY IN OUR Thank you for your commitment to Flowserve. COMPANY Sincerely, R. Scott Rowe President and Chief Executive Officer Flowserve Corporation INTEGRITY IN DEALING WITH OTHERS 4TABLE OF A Message CONTENTS From Our CEO A Message From Our CEO Dear fellow employees, Our Purpose, Values and OUR For more than 200 years, Flowserve has been a leader in the fluid motion and control industry, delivering quality products Behaviors VALUES and industry-leading solutions. Our success is founded on our collective commitment to our core shared values – People, Our Code Safety, Integrity, Innovation, Ownership and Excellence. By upholding these values in all that we do, we build trust and of Conduct brand loyalty with our customers and business partners, and demonstrate that we are committed to conducting business Our Ethical in an honest, ethical and transparent manner. Responsibilities as Employees With more than 17,500 employees operating in 300+ locations around the world, our continued success depends on each one of us. The decisions you make and the actions you take every day impact how the world views Flowserve. Our Ethical Responsibilities By embracing our Global Integrity, Local Ownership mindset and consistently upholding our values, you contribute to INTEGRITY as Leaders Flowserve’s reputation for integrity, honesty and excellence. IN OUR How to Ask for PEOPLE Our Code of Conduct, or Code, is designed to help you understand our ethical expectations. I encourage you to carefully Help or Raise Concerns read and use it to guide your decisions and actions. While our Code cannot cover every possible situation you may face, it does define the standards and behaviors we expect from all employees. Speak up if you have a concern and seek guidance if you are unsure about the right thing to do. We are proud of the legacy we have built together at Flowserve. By putting our Code and values into practice in all that you do, we can be confident in our continued success. INTEGRITY IN OUR Thank you for your commitment to Flowserve. COMPANY Sincerely, R. Scott Rowe President and Chief Executive Officer Flowserve Corporation INTEGRITY IN DEALING WITH OTHERS 4
TABLE OF Our Purpose, Values CONTENTS and Behaviors A Message From Our CEO Our Purpose, Values and OUR OUR PURPOSE Behaviors Together, we create extraordinary flow control VALUES WHY WE ARE HERE. solutions to make the world better for everyone. Our Code of Conduct Our Ethical Responsibilities OUR VALUES OUR BEHAVIORS as Employees OUR GUIDING PRINCIPLES FOR HOW WE ACHIEVE OUR PURPOSE. THE ACTIONS WE TAKE TO LIVE BY OUR VALUES. Our Ethical Responsibilities INTEGRITY as Leaders PEOPLE SAFETY IN OUR WORK TOGETHER WITH AN ENTERPRISE MINDSET Develop each other, embrace differences, Embrace Flowserve’s safety rules and hold How to Ask for PEOPLE respect one another, and create a each other accountable. We do this for Help or Raise Concerns collaborative culture. The collective ourselves, our customers, our partners DELIVER BEYOND OUR CUSTOMER EXPECTATIONS energy of our people sets us apart and the communities we serve. from our competitors. TAKE ACTION AND LEARN FROM MISTAKES INTEGRITY INNOVATION Act ethically and transparently toward Take risks and learn from mistakes. INTEGRITY associates, customers and shareholders, Leverage and expand our knowledge to TRUST AND RESPECT EACH OTHER in accordance with the Flowserve Code bring the best products and services to IN OUR of Conduct. Be consistently open, honest market. Achieve this through creativity, COMPANY and trustworthy. modernization and ingenuity. THINK SAFE, WORK SAFE, BE SAFE OWNERSHIP EXCELLENCE EMBRACE AND DRIVE CHANGE Take the initiative to own your work, and Perform ambitiously with dedication follow through on your commitments, to and enthusiasm to deliver outstanding achieve results that are beyond what is products, services and business results. ACT WITH INTEGRITY, ALWAYS expected. INTEGRITY IN DEALING WITH OTHERS 5TABLE OF Our Purpose, Values CONTENTS and Behaviors A Message From Our CEO Our Purpose, Values and OUR OUR PURPOSE Behaviors Together, we create extraordinary flow control VALUES WHY WE ARE HERE. solutions to make the world better for everyone. Our Code of Conduct Our Ethical Responsibilities OUR VALUES OUR BEHAVIORS as Employees OUR GUIDING PRINCIPLES FOR HOW WE ACHIEVE OUR PURPOSE. THE ACTIONS WE TAKE TO LIVE BY OUR VALUES. Our Ethical Responsibilities INTEGRITY as Leaders PEOPLE SAFETY IN OUR WORK TOGETHER WITH AN ENTERPRISE MINDSET Develop each other, embrace differences, Embrace Flowserve’s safety rules and hold How to Ask for PEOPLE respect one another, and create a each other accountable. We do this for Help or Raise Concerns collaborative culture. The collective ourselves, our customers, our partners DELIVER BEYOND OUR CUSTOMER EXPECTATIONS energy of our people sets us apart and the communities we serve. from our competitors. TAKE ACTION AND LEARN FROM MISTAKES INTEGRITY INNOVATION Act ethically and transparently toward Take risks and learn from mistakes. INTEGRITY associates, customers and shareholders, Leverage and expand our knowledge to TRUST AND RESPECT EACH OTHER in accordance with the Flowserve Code bring the best products and services to IN OUR of Conduct. Be consistently open, honest market. Achieve this through creativity, COMPANY and trustworthy. modernization and ingenuity. THINK SAFE, WORK SAFE, BE SAFE OWNERSHIP EXCELLENCE EMBRACE AND DRIVE CHANGE Take the initiative to own your work, and Perform ambitiously with dedication follow through on your commitments, to and enthusiasm to deliver outstanding achieve results that are beyond what is products, services and business results. ACT WITH INTEGRITY, ALWAYS expected. INTEGRITY IN DEALING WITH OTHERS 5
TABLE OF Our Code CONTENTS of Conduct A Message From Our CEO Our Code of Conduct reflects who we are as company and how we do business. Our Purpose, It incorporates and reinforces our shared Flowserve values and the laws, regulations Values and OUR Behaviors and policies that apply to each of us and our business. It is intended as a guide to VALUES help you make ethical decisions and resolve challenging issues you may face in your Our Code of Conduct work at Flowserve, but it cannot cover all possible scenarios. If you have questions or Our Ethical need assistance, the Integrity & Compliance team (I&C) is always available to help. Responsibilities as Employees Our Code of Conduct and the standards it embodies apply to everyone who works for Our Ethical or represents Flowserve in any capacity, including: Responsibilities INTEGRITY as Leaders IN OUR • Employees at all levels, in any position, around the world. How to Ask for PEOPLE Help or Raise • Our board members and corporate officers. Concerns • All external companies and individuals who work with or represent Flowserve, including suppliers, agents, sales representatives, distributors, joint venture partners and other business partners. INTEGRITY IN OUR COMPANY Acting with integrity, honesty and transparency in all that we do at Flowserve is critical to our company’s INTEGRITY success and is expected from each of us. IN DEALING WITH OTHERS 6TABLE OF Our Code CONTENTS of Conduct A Message From Our CEO Our Code of Conduct reflects who we are as company and how we do business. Our Purpose, It incorporates and reinforces our shared Flowserve values and the laws, regulations Values and OUR Behaviors and policies that apply to each of us and our business. It is intended as a guide to VALUES help you make ethical decisions and resolve challenging issues you may face in your Our Code of Conduct work at Flowserve, but it cannot cover all possible scenarios. If you have questions or Our Ethical need assistance, the Integrity & Compliance team (I&C) is always available to help. Responsibilities as Employees Our Code of Conduct and the standards it embodies apply to everyone who works for Our Ethical or represents Flowserve in any capacity, including: Responsibilities INTEGRITY as Leaders IN OUR • Employees at all levels, in any position, around the world. How to Ask for PEOPLE Help or Raise • Our board members and corporate officers. Concerns • All external companies and individuals who work with or represent Flowserve, including suppliers, agents, sales representatives, distributors, joint venture partners and other business partners. INTEGRITY IN OUR COMPANY Acting with integrity, honesty and transparency in all that we do at Flowserve is critical to our company’s INTEGRITY success and is expected from each of us. IN DEALING WITH OTHERS 6
TABLE OF Our Ethical CONTENTS Responsibilities A Message From Our CEO as Employees Our Purpose, Values and OUR Behaviors We rely on every employee to act with integrity in all situations and support VALUES Flowserve’s commitment to doing business in an ethical and transparent manner. Our Code of Conduct Your actions should always be ethical and honest, reflect our values, and comply Our Ethical with applicable laws, our Code and our policies. Responsibilities as Employees YOUR RESPONSIBILITIES Our Ethical Responsibilities 9 Familiarize yourself with the Code and the Flowserve policies and procedures that apply INTEGRITY as Leaders to you, your job function or your site and follow them in your work for Flowserve. IN OUR How to Ask for PEOPLE 9 Promptly raise concerns about potential violations of law, the Code or our policies using Help or Raise any of the reporting channels available to employees (see pg. 9). Concerns 9 Cooperate fully and honestly with any investigation related to ethics or potential violations If faced with a difficult decision or of the law, our Code or our policies. ethical concern, ask yourself: 9 If you manage relationships with business partners like agents, distributors or suppliers, make them aware of our Code and let them know we expect them to comply with our • Does my planned course of action align with Flowserve’s values? INTEGRITY ethical standards. IN OUR • Does it comply with applicable laws and our policies? 9 Report circumstances where business partners are not meeting the standards set out COMPANY • Is it in the best interest of Flowserve? in our Code. • Would I be comfortable if my actions were made public? If you are not comfortable answering ‘yes’ to all of these questions, COMPLIANCE IS EXPECTED you should pause and reconsider your course of action. Remember, At Flowserve, we are committed to upholding our shared values and take violations you can always ask for help. of our Code and policies seriously. Failure to follow the standards set out in our INTEGRITY Code and polices can result in disciplinary action up to and including termination IN DEALING of employment, and in some cases, legal action. WITH OTHERS 7TABLE OF Our Ethical CONTENTS Responsibilities A Message From Our CEO as Employees Our Purpose, Values and OUR Behaviors We rely on every employee to act with integrity in all situations and support VALUES Flowserve’s commitment to doing business in an ethical and transparent manner. Our Code of Conduct Your actions should always be ethical and honest, reflect our values, and comply Our Ethical with applicable laws, our Code and our policies. Responsibilities as Employees YOUR RESPONSIBILITIES Our Ethical Responsibilities 9 Familiarize yourself with the Code and the Flowserve policies and procedures that apply INTEGRITY as Leaders to you, your job function or your site and follow them in your work for Flowserve. IN OUR How to Ask for PEOPLE 9 Promptly raise concerns about potential violations of law, the Code or our policies using Help or Raise any of the reporting channels available to employees (see pg. 9). Concerns 9 Cooperate fully and honestly with any investigation related to ethics or potential violations If faced with a difficult decision or of the law, our Code or our policies. ethical concern, ask yourself: 9 If you manage relationships with business partners like agents, distributors or suppliers, make them aware of our Code and let them know we expect them to comply with our • Does my planned course of action align with Flowserve’s values? INTEGRITY ethical standards. IN OUR • Does it comply with applicable laws and our policies? 9 Report circumstances where business partners are not meeting the standards set out COMPANY • Is it in the best interest of Flowserve? in our Code. • Would I be comfortable if my actions were made public? If you are not comfortable answering ‘yes’ to all of these questions, COMPLIANCE IS EXPECTED you should pause and reconsider your course of action. Remember, At Flowserve, we are committed to upholding our shared values and take violations you can always ask for help. of our Code and policies seriously. Failure to follow the standards set out in our INTEGRITY Code and polices can result in disciplinary action up to and including termination IN DEALING of employment, and in some cases, legal action. WITH OTHERS 7
TABLE OF Our Ethical CONTENTS Responsibilities A Message From Our CEO as Leaders Our Purpose, Values and OUR Behaviors As a Flowserve manager or supervisor, you have a higher degree of responsibility VALUES for maintaining a culture of ethics and compliance in which employees understand Our Code of Conduct our shared values and feel comfortable raising concerns without fear of retaliation. Our Ethical Reinforce with your team the importance of following our Code, and let them know Responsibilities as Employees you are a resource to help them make ethical decisions. Our Ethical Responsibilities YOUR RESPONSIBILITIES INTEGRITY as Leaders IN OUR 9 Lead by example. Set the tone for integrity with your team, not just through words, How to Ask for PEOPLE but through your daily actions. Help or Raise Concerns 9 Communicate ethical expectations. Talk frequently with your team about acting with integrity, participation in compliance initiatives, and new or updated policies or procedures. 9 Make clear that ethics come first. Reinforce with your team that at Flowserve, we do not sacrifice our integrity or shared values for the sake of business results. 9 Create the right culture. Take steps to make employees comfortable raising concerns INTEGRITY when they have them. Let employees know that we do not tolerate retaliation for raising IN OUR concerns in good faith, and we prevent retaliation by others. COMPANY 9 Ask for help. While we expect much of our leaders, we do not expect you to solve every ethical issue on your own. Raise your hand and ask for help when needed. INTEGRITY IN DEALING WITH OTHERS 8TABLE OF Our Ethical CONTENTS Responsibilities A Message From Our CEO as Leaders Our Purpose, Values and OUR Behaviors As a Flowserve manager or supervisor, you have a higher degree of responsibility VALUES for maintaining a culture of ethics and compliance in which employees understand Our Code of Conduct our shared values and feel comfortable raising concerns without fear of retaliation. Our Ethical Reinforce with your team the importance of following our Code, and let them know Responsibilities as Employees you are a resource to help them make ethical decisions. Our Ethical Responsibilities YOUR RESPONSIBILITIES INTEGRITY as Leaders IN OUR 9 Lead by example. Set the tone for integrity with your team, not just through words, How to Ask for PEOPLE but through your daily actions. Help or Raise Concerns 9 Communicate ethical expectations. Talk frequently with your team about acting with integrity, participation in compliance initiatives, and new or updated policies or procedures. 9 Make clear that ethics come first. Reinforce with your team that at Flowserve, we do not sacrifice our integrity or shared values for the sake of business results. 9 Create the right culture. Take steps to make employees comfortable raising concerns INTEGRITY when they have them. Let employees know that we do not tolerate retaliation for raising IN OUR concerns in good faith, and we prevent retaliation by others. COMPANY 9 Ask for help. While we expect much of our leaders, we do not expect you to solve every ethical issue on your own. Raise your hand and ask for help when needed. INTEGRITY IN DEALING WITH OTHERS 8
TABLE OF How to Ask for Help CONTENTS or Raise Concerns A Message From Our CEO Regardless of whom you contact, you can be assured that HOW TO RAISE AN ETHICS CONCERN your concern will be fairly and promptly investigated and Our Purpose, If you have a question or concern, there are many resources Values and addressed. We protect the confidentiality of anyone reporting OUR available to you. Your manager or supervisor usually is Behaviors concerns, and disclose information about investigations only VALUES in the best position to address your concerns. If your if required to resolve identified issues. Our Code concern relates to your manager or supervisor or you of Conduct are not comfortable reporting your concern to him or her, you can contact any of the following additional resources: Our Ethical Responsibilities Flowserve’s • Your HR contact; as Employees Ethics Hotline • Your regional I&C contact; Our Ethical Responsibilities • A member of the Legal department; Flowserve’s Ethics Hotline is available INTEGRITY as Leaders to you at any time, in any location, via • A member of senior management; IN OUR phone or online. You may submit a How to Ask for PEOPLE • A member of the Board of Directors; Help or Raise report anonymously if you choose. Concerns • A member of the Audit Committee; or Online: • Flowserve’s Ethics Hotline. www.ethicspoint.com Nothing in the Code prohibits you from reporting potential United States toll-free number: violations of law to, or participating in an investigation conducted by, the Equal Employment Opportunity 1-800-799-4597 INTEGRITY Commission, the Securities and Exchange Commission, International numbers: IN OUR or any other federal, state or local government agency. http://ethics.flowserve.com COMPANY RETALIATION IS PROHIBITED In certain countries, local laws and regulations restrict the types of reports that can be made We expect employees to report improper or unethical through the Ethics Hotline. If you are in such behavior when they see it. If you believe a violation has a country and attempting to make a report, a or is about to occur, you should promptly report it. While trained local professional will direct you to internal it is not always easy to come forward with concerns, resources where your report can be made. particularly if they involve co-workers or business partners, INTEGRITY it is important to do so. Flowserve does not permit retaliation IN DEALING against anyone who raises a concern in good faith. WITH OTHERS 9TABLE OF How to Ask for Help CONTENTS or Raise Concerns A Message From Our CEO Regardless of whom you contact, you can be assured that HOW TO RAISE AN ETHICS CONCERN your concern will be fairly and promptly investigated and Our Purpose, If you have a question or concern, there are many resources Values and addressed. We protect the confidentiality of anyone reporting OUR available to you. Your manager or supervisor usually is Behaviors concerns, and disclose information about investigations only VALUES in the best position to address your concerns. If your if required to resolve identified issues. Our Code concern relates to your manager or supervisor or you of Conduct are not comfortable reporting your concern to him or her, you can contact any of the following additional resources: Our Ethical Responsibilities Flowserve’s • Your HR contact; as Employees Ethics Hotline • Your regional I&C contact; Our Ethical Responsibilities • A member of the Legal department; Flowserve’s Ethics Hotline is available INTEGRITY as Leaders to you at any time, in any location, via • A member of senior management; IN OUR phone or online. You may submit a How to Ask for PEOPLE • A member of the Board of Directors; Help or Raise report anonymously if you choose. Concerns • A member of the Audit Committee; or Online: • Flowserve’s Ethics Hotline. www.ethicspoint.com Nothing in the Code prohibits you from reporting potential United States toll-free number: violations of law to, or participating in an investigation conducted by, the Equal Employment Opportunity 1-800-799-4597 INTEGRITY Commission, the Securities and Exchange Commission, International numbers: IN OUR or any other federal, state or local government agency. http://ethics.flowserve.com COMPANY RETALIATION IS PROHIBITED In certain countries, local laws and regulations restrict the types of reports that can be made We expect employees to report improper or unethical through the Ethics Hotline. If you are in such behavior when they see it. If you believe a violation has a country and attempting to make a report, a or is about to occur, you should promptly report it. While trained local professional will direct you to internal it is not always easy to come forward with concerns, resources where your report can be made. particularly if they involve co-workers or business partners, INTEGRITY it is important to do so. Flowserve does not permit retaliation IN DEALING against anyone who raises a concern in good faith. WITH OTHERS 9
TABLE OF CONTENTS Integrity in Our People OUR VALUES We Respect People We Promote a Culture of Safety INTEGRITY IN OUR We Avoid PEOPLE Conflicts of Interest Our Code of Conduct isn’t just about how we work. It’s about We Protect Personal Data how we interact with each other and the respect we show for the people and INTEGRITY communities we serve. IN OUR COMPANY INTEGRITY IN DEALING WITH OTHERS 10TABLE OF CONTENTS Integrity in Our People OUR VALUES We Respect People We Promote a Culture of Safety INTEGRITY IN OUR We Avoid PEOPLE Conflicts of Interest Our Code of Conduct isn’t just about how we work. It’s about We Protect Personal Data how we interact with each other and the respect we show for the people and INTEGRITY communities we serve. IN OUR COMPANY INTEGRITY IN DEALING WITH OTHERS 10
TABLE OF We Respect People CONTENTS OUR INTEGRITY COMMITMENT FREQUENTLY ASKED QUESTIONS Flowserve is a global company made up of people from QUESTION: I was recently assigned to a new group and my a wide variety of backgrounds, experiences and cultures. new supervisor frequently picks on junior team members, and We value the diversity of our workforce, embrace our often yells at employees. When I questioned a co-worker, she differences, respect one another, and work together to told me to keep my head down or I would likely be subjected OUR create a collaborative culture. to the same treatment. What should I do? VALUES ANSWER: You should promptly report this behavior to your OUR POLICIES local HR contact. This type of behavior is not aligned with our people-first values and our commitment to maintaining • We recruit, employ and develop our workforce based a safe and respectful workplace. on the qualifications and competencies necessary to We Respect People succeed at Flowserve. QUESTION: I recently observed one of our customers • We value each other’s contributions, treat one another We Promote a making insulting remarks to a co-worker. The customer Culture of Safety with dignity and respect, and work together to create INTEGRITY is important to our business and my co-worker is an open and inclusive working environment. IN OUR uncomfortable reporting the issue. Should I say something? We Avoid PEOPLE Conflicts of Interest • We do not tolerate harassment, discrimination or abusive ANSWER: Yes. Promptly report what you witnessed to conduct of any variety. your supervisor or your local HR contact. We do not tolerate harassment of any kind in our workplace, whether initiated We Protect Personal Data by or directed to an employee, customer, supplier or OUR RESPONSIBILITIES business partner. 9 Treat others as you would want to be treated. 9 Create a constructive, inclusive and productive workplace INTEGRITY by listening to others, even when their views may differ IN OUR from your own. LEARN MORE COMPANY 9 Promote a workplace free of harassment, discrimination, Global Equal Opportunity and Respect bullying and abusive conduct. in the Workplace Policy 9 Report to your supervisor or Human Resources (HR) contact if you are subjected to or you witness discrimination, harassment or abusive conduct in the workplace. INTEGRITY IN DEALING WITH OTHERS 11TABLE OF We Respect People CONTENTS OUR INTEGRITY COMMITMENT FREQUENTLY ASKED QUESTIONS Flowserve is a global company made up of people from QUESTION: I was recently assigned to a new group and my a wide variety of backgrounds, experiences and cultures. new supervisor frequently picks on junior team members, and We value the diversity of our workforce, embrace our often yells at employees. When I questioned a co-worker, she differences, respect one another, and work together to told me to keep my head down or I would likely be subjected OUR create a collaborative culture. to the same treatment. What should I do? VALUES ANSWER: You should promptly report this behavior to your OUR POLICIES local HR contact. This type of behavior is not aligned with our people-first values and our commitment to maintaining • We recruit, employ and develop our workforce based a safe and respectful workplace. on the qualifications and competencies necessary to We Respect People succeed at Flowserve. QUESTION: I recently observed one of our customers • We value each other’s contributions, treat one another We Promote a making insulting remarks to a co-worker. The customer Culture of Safety with dignity and respect, and work together to create INTEGRITY is important to our business and my co-worker is an open and inclusive working environment. IN OUR uncomfortable reporting the issue. Should I say something? We Avoid PEOPLE Conflicts of Interest • We do not tolerate harassment, discrimination or abusive ANSWER: Yes. Promptly report what you witnessed to conduct of any variety. your supervisor or your local HR contact. We do not tolerate harassment of any kind in our workplace, whether initiated We Protect Personal Data by or directed to an employee, customer, supplier or OUR RESPONSIBILITIES business partner. 9 Treat others as you would want to be treated. 9 Create a constructive, inclusive and productive workplace INTEGRITY by listening to others, even when their views may differ IN OUR from your own. LEARN MORE COMPANY 9 Promote a workplace free of harassment, discrimination, Global Equal Opportunity and Respect bullying and abusive conduct. in the Workplace Policy 9 Report to your supervisor or Human Resources (HR) contact if you are subjected to or you witness discrimination, harassment or abusive conduct in the workplace. INTEGRITY IN DEALING WITH OTHERS 11
TABLE OF We Promote CONTENTS a Culture of Safety 9 Under our Stop Work Authority (SWA) program, you are OUR INTEGRITY COMMITMENT empowered and obligated to stop work immediately if We hold each other accountable for creating and you observe unsafe behavior or conditions. OUR maintaining safe workplaces and products for our VALUES employees, customers and communities. 9 Never attempt to perform your job duties under the influence of alcohol, drugs or other substances that could impair your mental or physical abilities. OUR POLICIES • We comply with all health, safety, security and We Respect People FREQUENTLY ASKED QUESTIONS environmental laws, regulations and company policies that apply to our operations and the QUESTION: I was injured while working in the field but my We Promote a products we manufacture. supervisor is pressuring me not to report it and to perform Culture of Safety INTEGRITY light-duty work instead. What should I do? • We create and maintain safe working environments, IN OUR ANSWER: You should report your injury in accordance with empower our employees to identify and report We Avoid PEOPLE Conflicts of Interest our SHEA policy and 8 Basic Safety Rules, and report your safety concerns, and act to correct hazards. supervisor’s request to your SHEA coordinator. • We communicate our safety and security expectations We Protect to everyone who accesses our facilities. Personal Data QUESTION: My supervisor suggested changing our manufacturing process to speed up production. I know OUR RESPONSIBILITIES our goals are important, but I don’t feel the new process is safe. What should I do? 9 Comply with our Safety, Health & Environmental Affairs INTEGRITY (SHEA) policies including our 8 Basic Safety Rules, and ANSWER: You should openly discuss your concern with IN OUR site-specific safety procedures, security protocols and your supervisor. If still have concerns after discussing it, you COMPANY evacuation plans. should contact your SHEA coordinator for further support. 9 Be familiar with the location and use of emergency response equipment such as first-aid kits, safety LEARN MORE showers and eye-wash stations. Safety, Health & Environmental Affairs Policy 9 Do not undertake any activity you are not qualified Emergency Preparedness Plan Development Procedure or trained to perform or for which you do not have U.S. Drug and Alcohol Policy INTEGRITY the proper tools. Personal Security Guide IN DEALING Active Shooter Guide WITH OTHERS 12TABLE OF We Promote CONTENTS a Culture of Safety 9 Under our Stop Work Authority (SWA) program, you are OUR INTEGRITY COMMITMENT empowered and obligated to stop work immediately if We hold each other accountable for creating and you observe unsafe behavior or conditions. OUR maintaining safe workplaces and products for our VALUES employees, customers and communities. 9 Never attempt to perform your job duties under the influence of alcohol, drugs or other substances that could impair your mental or physical abilities. OUR POLICIES • We comply with all health, safety, security and We Respect People FREQUENTLY ASKED QUESTIONS environmental laws, regulations and company policies that apply to our operations and the QUESTION: I was injured while working in the field but my We Promote a products we manufacture. supervisor is pressuring me not to report it and to perform Culture of Safety INTEGRITY light-duty work instead. What should I do? • We create and maintain safe working environments, IN OUR ANSWER: You should report your injury in accordance with empower our employees to identify and report We Avoid PEOPLE Conflicts of Interest our SHEA policy and 8 Basic Safety Rules, and report your safety concerns, and act to correct hazards. supervisor’s request to your SHEA coordinator. • We communicate our safety and security expectations We Protect to everyone who accesses our facilities. Personal Data QUESTION: My supervisor suggested changing our manufacturing process to speed up production. I know OUR RESPONSIBILITIES our goals are important, but I don’t feel the new process is safe. What should I do? 9 Comply with our Safety, Health & Environmental Affairs INTEGRITY (SHEA) policies including our 8 Basic Safety Rules, and ANSWER: You should openly discuss your concern with IN OUR site-specific safety procedures, security protocols and your supervisor. If still have concerns after discussing it, you COMPANY evacuation plans. should contact your SHEA coordinator for further support. 9 Be familiar with the location and use of emergency response equipment such as first-aid kits, safety LEARN MORE showers and eye-wash stations. Safety, Health & Environmental Affairs Policy 9 Do not undertake any activity you are not qualified Emergency Preparedness Plan Development Procedure or trained to perform or for which you do not have U.S. Drug and Alcohol Policy INTEGRITY the proper tools. Personal Security Guide IN DEALING Active Shooter Guide WITH OTHERS 12
TABLE OF We Avoid CONTENTS Conflicts of Interest OUR INTEGRITY COMMITMENT Conflicts of interest arise when your personal We make decisions based on what is best for Flowserve OUR interests interfere or are inconsistent with the without considering our own personal interests. VALUES decisions you make or work you do for Flowserve. OUR POLICIES • We do not allow our personal interests, relationships, FREQUENTLY ASKED QUESTIONS investments or other factors to interfere with business QUESTION: I have been asked to serve as a trustee on the We Respect People decisions we make on behalf of Flowserve. board of a newly formed company that could compete with Flowserve in the future. This is not a salaried position, and • We avoid situations or activities that can give rise to We Promote a I do not expect my commitment to this other company will Culture of Safety conflicts of interest. INTEGRITY take a lot of time. Do I need to disclose this? IN OUR We Avoid ANSWER: Yes. Serving on another company’s board could OUR RESPONSIBILITIES PEOPLE Conflicts of Interest create a conflict, depending on the nature of the company, 9 Act in the best interest of Flowserve when making its services and products, the markets it competes in, decisions at work. We Protect and whether the position will impact your responsibilities Personal Data 9 Avoid conflicts of interest and situations that could give at Flowserve. rise to the appearance of a conflict of interest, including: − Investing in a Flowserve customer, supplier, business QUESTION: My neighbor asked if I could ‘pull some strings’ partner or competitor. to get a position for his brother at Flowserve. How should INTEGRITY I respond? − Owning or working for a company that competes with IN OUR Flowserve, does business with Flowserve or is seeking ANSWER: You should tell your neighbor that Flowserve to do business with Flowserve. COMPANY job openings are posted on the company website, and − Choosing suppliers, vendors or other business partners that he can apply for positions through the HR department. that employ, or are owned by, a family member or a You should not attempt to influence the company’s decision close friend. whether to hire your neighbor’s relative, as this could be a − Hiring, promoting or supervising someone you have a conflict of interest. close personal relationship with. 9 Promptly disclose to your supervisor, HR or regional I&C LEARN MORE contact any potential conflict of interest. INTEGRITY Conflicts of Interest Policy IN DEALING Related Party Transactions Policy and Procedures WITH OTHERS 13TABLE OF We Avoid CONTENTS Conflicts of Interest OUR INTEGRITY COMMITMENT Conflicts of interest arise when your personal We make decisions based on what is best for Flowserve OUR interests interfere or are inconsistent with the without considering our own personal interests. VALUES decisions you make or work you do for Flowserve. OUR POLICIES • We do not allow our personal interests, relationships, FREQUENTLY ASKED QUESTIONS investments or other factors to interfere with business QUESTION: I have been asked to serve as a trustee on the We Respect People decisions we make on behalf of Flowserve. board of a newly formed company that could compete with Flowserve in the future. This is not a salaried position, and • We avoid situations or activities that can give rise to We Promote a I do not expect my commitment to this other company will Culture of Safety conflicts of interest. INTEGRITY take a lot of time. Do I need to disclose this? IN OUR We Avoid ANSWER: Yes. Serving on another company’s board could OUR RESPONSIBILITIES PEOPLE Conflicts of Interest create a conflict, depending on the nature of the company, 9 Act in the best interest of Flowserve when making its services and products, the markets it competes in, decisions at work. We Protect and whether the position will impact your responsibilities Personal Data 9 Avoid conflicts of interest and situations that could give at Flowserve. rise to the appearance of a conflict of interest, including: − Investing in a Flowserve customer, supplier, business QUESTION: My neighbor asked if I could ‘pull some strings’ partner or competitor. to get a position for his brother at Flowserve. How should INTEGRITY I respond? − Owning or working for a company that competes with IN OUR Flowserve, does business with Flowserve or is seeking ANSWER: You should tell your neighbor that Flowserve to do business with Flowserve. COMPANY job openings are posted on the company website, and − Choosing suppliers, vendors or other business partners that he can apply for positions through the HR department. that employ, or are owned by, a family member or a You should not attempt to influence the company’s decision close friend. whether to hire your neighbor’s relative, as this could be a − Hiring, promoting or supervising someone you have a conflict of interest. close personal relationship with. 9 Promptly disclose to your supervisor, HR or regional I&C LEARN MORE contact any potential conflict of interest. INTEGRITY Conflicts of Interest Policy IN DEALING Related Party Transactions Policy and Procedures WITH OTHERS 13
TABLE OF We Protect CONTENTS Personal Data 9 Create, retain and dispose of personal data in compliance OUR INTEGRITY COMMITMENT with applicable laws and our Records Retention policy. We respect and value the privacy rights of our employees, Personal data is broadly defined and OUR customers and business partners around the world. 9 Report any event or incident that may have resulted in the includes any information that can be used VALUES unauthorized access, disclosure, misuse, alteration or loss to identify someone, including name, of personal data to Flowserve’s Data Privacy Office at OUR POLICIES [email protected]. email address, phone number or credit • We handle personal data in our possession (both electronic and hard-copy) with care and safeguard its use. card number. We Respect People FREQUENTLY ASKED QUESTIONS • We comply with the data privacy and security laws and QUESTION: I found an HR report on a copier that contains regulations where we operate. We Promote a confidential payroll information. I don’t want to get anyone in Culture of Safety INTEGRITY • We take appropriate measures to protect Flowserve’s IT trouble. What should I do? IN OUR systems from cybersecurity threats. ANSWER: You should immediately return it to your HR We Avoid PEOPLE Conflicts of Interest contact without reviewing or sharing it. All of us have a responsibility to protect the privacy of personal and OUR RESPONSIBILITIES business data. We Protect 9 Use personal data only for legitimate business needs and Personal Data consistent with our privacy policies and applicable laws and regulations. QUESTION: A friend started a new business and asked me to send contact details for my team to add to her 9 Follow our IT policies and procedures regarding use, mailing list. I would like to help her out. Can I send her access and security of personal data. INTEGRITY the contact information? LEARN MORE IN OUR 9 Protect against accidental or unlawful destruction, Social Media Guidelines ANSWER: No. Personal data such as your colleagues’ misuse, alteration, unauthorized disclosure or access COMPANY names, email addresses or phone numbers cannot be Data Privacy Policy to personal data: shared with unauthorized third parties. Records Management Policy − Secure electronic and hard-copy data and storage areas. Information Logging Policy − Use strong passwords and other appropriate security Information Exchange Policy measures for electronic access. Security Database Credentials Policy − Use only IT department-approved systems and tools for Security Remote Administration Policy storage, transmission and back-up of data. INTEGRITY IN DEALING WITH OTHERS 14TABLE OF We Protect CONTENTS Personal Data 9 Create, retain and dispose of personal data in compliance OUR INTEGRITY COMMITMENT with applicable laws and our Records Retention policy. We respect and value the privacy rights of our employees, Personal data is broadly defined and OUR customers and business partners around the world. 9 Report any event or incident that may have resulted in the includes any information that can be used VALUES unauthorized access, disclosure, misuse, alteration or loss to identify someone, including name, of personal data to Flowserve’s Data Privacy Office at OUR POLICIES [email protected]. email address, phone number or credit • We handle personal data in our possession (both electronic and hard-copy) with care and safeguard its use. card number. We Respect People FREQUENTLY ASKED QUESTIONS • We comply with the data privacy and security laws and QUESTION: I found an HR report on a copier that contains regulations where we operate. We Promote a confidential payroll information. I don’t want to get anyone in Culture of Safety INTEGRITY • We take appropriate measures to protect Flowserve’s IT trouble. What should I do? IN OUR systems from cybersecurity threats. ANSWER: You should immediately return it to your HR We Avoid PEOPLE Conflicts of Interest contact without reviewing or sharing it. All of us have a responsibility to protect the privacy of personal and OUR RESPONSIBILITIES business data. We Protect 9 Use personal data only for legitimate business needs and Personal Data consistent with our privacy policies and applicable laws and regulations. QUESTION: A friend started a new business and asked me to send contact details for my team to add to her 9 Follow our IT policies and procedures regarding use, mailing list. I would like to help her out. Can I send her access and security of personal data. INTEGRITY the contact information? LEARN MORE IN OUR 9 Protect against accidental or unlawful destruction, Social Media Guidelines ANSWER: No. Personal data such as your colleagues’ misuse, alteration, unauthorized disclosure or access COMPANY names, email addresses or phone numbers cannot be Data Privacy Policy to personal data: shared with unauthorized third parties. Records Management Policy − Secure electronic and hard-copy data and storage areas. Information Logging Policy − Use strong passwords and other appropriate security Information Exchange Policy measures for electronic access. Security Database Credentials Policy − Use only IT department-approved systems and tools for Security Remote Administration Policy storage, transmission and back-up of data. INTEGRITY IN DEALING WITH OTHERS 14
TABLE OF CONTENTS Integrity in OUR Our Company VALUES We Maintain Accurate Business and Financial Records INTEGRITY IN OUR We Protect PEOPLE Our Code of Conduct isn’t just Flowserve’s Assets about how we work. It’s about We Safeguard Our Intellectual Property how we interact with each and Confidential Information other and the respect we show for the people and We Do Not Trade on INTEGRITY Insider Information communities we serve. IN OUR COMPANY We Speak on Behalf of Flowserve Through Designated Spokespersons INTEGRITY IN DEALING WITH OTHERS 15TABLE OF CONTENTS Integrity in OUR Our Company VALUES We Maintain Accurate Business and Financial Records INTEGRITY IN OUR We Protect PEOPLE Our Code of Conduct isn’t just Flowserve’s Assets about how we work. It’s about We Safeguard Our Intellectual Property how we interact with each and Confidential Information other and the respect we show for the people and We Do Not Trade on INTEGRITY Insider Information communities we serve. IN OUR COMPANY We Speak on Behalf of Flowserve Through Designated Spokespersons INTEGRITY IN DEALING WITH OTHERS 15
TABLE OF We Maintain CONTENTS Accurate Business and Financial Records OUR 9 Do not create false, misleading or incomplete records or OUR INTEGRITY COMMITMENT VALUES maintain undisclosed or unrecorded transactions, liabilities, Maintaining complete and accurate business records is accounts or other financial or transactional information. an important legal obligation that also builds trust with our customers, business partners, investors and government 9 Promptly report any situation where you believe false regulators. Our internal policies and controls are designed to or misleading records or documents have been created ensure the accuracy and integrity of our recordkeeping and We Maintain or company records have been altered or manipulated. reporting of Flowserve’s business and financial results. Accurate Business and Financial 9 Follow our records retention policies and any litigation Records INTEGRITY OUR POLICIES or record holds issued by the Legal department. IN OUR • All business records we create are accurate, objective and We Protect PEOPLE Flowserve’s Assets fairly reflect the business transactions or results recorded. FREQUENTLY ASKED QUESTIONS QUESTION: A supplier asked me to accept an invoice • We comply with all applicable laws, regulations and our We Safeguard Our with a lower than accurate value for the supplier’s product. policies related to the creation, preservation, disclosure Intellectual Property He said he does this all the time to help with ‘tax issues.’ and Confidential and destruction of business and financial records. Information What should I do? ANSWER: The supplier is asking you to accept inaccurate OUR RESPONSIBILITIES We Do Not Trade on financial records. You should inform him you can only accept INTEGRITY Insider Information 9 Create records that are factual, accurate, complete and accurate invoices, and report the issue to your supervisor. IN OUR comply with the law and Flowserve policies, including any: COMPANY We Speak on − Records related to your job responsibilities, such Behalf of Flowserve QUESTION: I just saw a co-worker sign a product as time and attendance records, expense reports, Through inspection report, but I know he did not actually complete production reports and quality assurance records; and Designated the inspection. What should I do? Spokespersons − Financial or transactional records, such as quotes, ANSWER: You should report the issue to your supervisor. purchase orders, contracts, shipping documents, By falsely certifying that an inspection has been completed, invoices, revenue accounting, forecasts and inventory. your co-worker has created a false record that violates our LEARN MORE 9 Accurately code transactions to the proper accounts and INTEGRITY Code and policies. Accounting Policies timely record transactions in the appropriate reporting period. IN DEALING Records Management Policy WITH OTHERS 16TABLE OF We Maintain CONTENTS Accurate Business and Financial Records OUR 9 Do not create false, misleading or incomplete records or OUR INTEGRITY COMMITMENT VALUES maintain undisclosed or unrecorded transactions, liabilities, Maintaining complete and accurate business records is accounts or other financial or transactional information. an important legal obligation that also builds trust with our customers, business partners, investors and government 9 Promptly report any situation where you believe false regulators. Our internal policies and controls are designed to or misleading records or documents have been created ensure the accuracy and integrity of our recordkeeping and We Maintain or company records have been altered or manipulated. reporting of Flowserve’s business and financial results. Accurate Business and Financial 9 Follow our records retention policies and any litigation Records INTEGRITY OUR POLICIES or record holds issued by the Legal department. IN OUR • All business records we create are accurate, objective and We Protect PEOPLE Flowserve’s Assets fairly reflect the business transactions or results recorded. FREQUENTLY ASKED QUESTIONS QUESTION: A supplier asked me to accept an invoice • We comply with all applicable laws, regulations and our We Safeguard Our with a lower than accurate value for the supplier’s product. policies related to the creation, preservation, disclosure Intellectual Property He said he does this all the time to help with ‘tax issues.’ and Confidential and destruction of business and financial records. Information What should I do? ANSWER: The supplier is asking you to accept inaccurate OUR RESPONSIBILITIES We Do Not Trade on financial records. You should inform him you can only accept INTEGRITY Insider Information 9 Create records that are factual, accurate, complete and accurate invoices, and report the issue to your supervisor. IN OUR comply with the law and Flowserve policies, including any: COMPANY We Speak on − Records related to your job responsibilities, such Behalf of Flowserve QUESTION: I just saw a co-worker sign a product as time and attendance records, expense reports, Through inspection report, but I know he did not actually complete production reports and quality assurance records; and Designated the inspection. What should I do? Spokespersons − Financial or transactional records, such as quotes, ANSWER: You should report the issue to your supervisor. purchase orders, contracts, shipping documents, By falsely certifying that an inspection has been completed, invoices, revenue accounting, forecasts and inventory. your co-worker has created a false record that violates our LEARN MORE 9 Accurately code transactions to the proper accounts and INTEGRITY Code and policies. Accounting Policies timely record transactions in the appropriate reporting period. IN DEALING Records Management Policy WITH OTHERS 16
TABLE OF We Protect CONTENTS Flowserve’s Assets OUR INTEGRITY COMMITMENT FREQUENTLY ASKED QUESTIONS We are all entrusted with the protection, care and responsible QUESTION: Can I use tools owned by Flowserve for OUR use of the assets of the company. my home improvements during the weekend? VALUES ANSWER: No. Flowserve tools may only be used for OUR POLICIES Flowserve business activities and not for personal use. • We protect the company’s physical, IT and information assets (defined at right) from loss, damage, theft or misuse. QUESTION: Is it OK to use my Flowserve email account to register for an external website? • We use the company’s assets responsibly and for We Maintain ANSWER: Yes, for work-related services such as trade Accurate Business authorized business purposes only. and Financial associations or subscriptions. You should not use your Records INTEGRITY Flowserve email account for non-work related websites OUR RESPONSIBILITIES IN OUR or correspondence. We Protect 9 Ensure that assets are kept in good working order in PEOPLE Flowserve’s Assets accordance with applicable laws and our policies. 9 Physically secure assets when not in use, and protect We Safeguard Our Intellectual Property the security of our IT and information assets by keeping and Confidential passwords secure. Information LEARN MORE Physical assets include things like furniture, 9 Access Flowserve’s network only through IT-authorized office supplies, equipment, machinery, tools, applications and devices. We Do Not Trade on Acceptable Use Policy INTEGRITY Insider Information materials and vehicles. Acceptable Encryption Use Policy IN OUR 9 Promptly report any unauthorized access, use, loss or Remote Networking Policy theft of IT assets like computers, cell phones or other COMPANY IT assets include things like electronically stored We Speak on Web Application Policy electronic equipment to the IT Help Desk. Behalf of Flowserve data, software and applications, computer Through Information Exchange Policy equipment, printers, servers, electronic storage Designated 9 Limited personal use of IT assets like cell phones or Bluetooth Policy devices and telecommunications equipment. Spokespersons computers is permitted if it does not interfere with your job Email Policy responsibilities and complies with our policies and the law. Information assets include things such as Password Policy product performance data, product designs or Wireless Communication Policy Anything you create, access, download, send or receive drawings, R&D plans, business plans or strategies, Data Retention, Back-up and Recovery Policy INTEGRITY on company IT assets is subject to review, monitoring and manufacturing processes and know-how. Electronic Equipment Disposal Policy IN DEALING and confiscation by Flowserve. You should have no WITH OTHERS expectation of privacy when using Flowserve IT assets. 17TABLE OF We Protect CONTENTS Flowserve’s Assets OUR INTEGRITY COMMITMENT FREQUENTLY ASKED QUESTIONS We are all entrusted with the protection, care and responsible QUESTION: Can I use tools owned by Flowserve for OUR use of the assets of the company. my home improvements during the weekend? VALUES ANSWER: No. Flowserve tools may only be used for OUR POLICIES Flowserve business activities and not for personal use. • We protect the company’s physical, IT and information assets (defined at right) from loss, damage, theft or misuse. QUESTION: Is it OK to use my Flowserve email account to register for an external website? • We use the company’s assets responsibly and for We Maintain ANSWER: Yes, for work-related services such as trade Accurate Business authorized business purposes only. and Financial associations or subscriptions. You should not use your Records INTEGRITY Flowserve email account for non-work related websites OUR RESPONSIBILITIES IN OUR or correspondence. We Protect 9 Ensure that assets are kept in good working order in PEOPLE Flowserve’s Assets accordance with applicable laws and our policies. 9 Physically secure assets when not in use, and protect We Safeguard Our Intellectual Property the security of our IT and information assets by keeping and Confidential passwords secure. Information LEARN MORE Physical assets include things like furniture, 9 Access Flowserve’s network only through IT-authorized office supplies, equipment, machinery, tools, applications and devices. We Do Not Trade on Acceptable Use Policy INTEGRITY Insider Information materials and vehicles. Acceptable Encryption Use Policy IN OUR 9 Promptly report any unauthorized access, use, loss or Remote Networking Policy theft of IT assets like computers, cell phones or other COMPANY IT assets include things like electronically stored We Speak on Web Application Policy electronic equipment to the IT Help Desk. Behalf of Flowserve data, software and applications, computer Through Information Exchange Policy equipment, printers, servers, electronic storage Designated 9 Limited personal use of IT assets like cell phones or Bluetooth Policy devices and telecommunications equipment. Spokespersons computers is permitted if it does not interfere with your job Email Policy responsibilities and complies with our policies and the law. Information assets include things such as Password Policy product performance data, product designs or Wireless Communication Policy Anything you create, access, download, send or receive drawings, R&D plans, business plans or strategies, Data Retention, Back-up and Recovery Policy INTEGRITY on company IT assets is subject to review, monitoring and manufacturing processes and know-how. Electronic Equipment Disposal Policy IN DEALING and confiscation by Flowserve. You should have no WITH OTHERS expectation of privacy when using Flowserve IT assets. 17
TABLE OF We Safeguard CONTENTS Our Intellectual Property and Confidential Information OUR 9 Do not solicit, obtain or use the IP or confidential OUR INTEGRITY COMMITMENT VALUES information of other parties like customers or competitors. Through our more than 200-year history, Flowserve has Intellectual property includes patents, developed a vast body of intellectual property (IP), unique 9 If you obtain confidential information about another entity trade secrets, trademarks and copyrights knowledge, technical know-how and proprietary business through any source, do not use or share it and contact the which embody and protect Flowserve’s information (confidential information) related to flow control Legal department or your regional I&C contact. inventions, product designs, processes, products and services and the applications where they brands, business plans, marketing materials, We Maintain are used. We safeguard our intellectual property and Accurate Business Inventions and IP created, improved or software and computer code, and other confidential information and prevent its misuse or and Financial enhanced in the normal course of your information, knowledge and processes. Records unauthorized disclosure. INTEGRITY work for Flowserve belong exclusively to IN OUR Confidential or proprietary information Flowserve. You agree to assist Flowserve We Protect PEOPLE is information related to our business that is OUR POLICIES in securing its rights to such inventions Flowserve’s Assets not publicly known or generally available and and IP, including assignment of your • We diligently protect our IP and confidential information is held in confidence by the company. interest or rights, if necessary. Disclose and enforce our rights against others who take or use it We Safeguard Our Examples include manufacturing or detail all inventions or IP creations, improvements Intellectual Property without authorization. drawings, manufacturing and engineering and Confidential or enhancements to Flowserve’s IP counsel Information processes, bills of materials, customer and • We do not take or use the IP or confidential information in the Legal Department. supplier lists, price lists and market strategies. that belongs to others without proper authorization. We Do Not Trade on INTEGRITY Insider Information FREQUENTLY ASKED QUESTION IN OUR OUR RESPONSIBILITIES QUESTION: A friend who recently left a competitor COMPANY We Speak on 9 Do not disclose Flowserve’s IP or confidential company gave me coding for the company’s new Behalf of Flowserve information to a third party without approval of an LEARN MORE Through diagnostic software. I think the coding solutions could appropriate director-level business leader or above and Designated Confidential and Proprietary Information Policy help upgrade Flowserve’s diagnostic software. Can Spokespersons IP counsel. Disclosure for valid business reasons can I use the code to revise Flowserve’s software? Policy on Gathering Competitor Information be authorized through confidentiality or non-disclosure Anti-Trust and Anti-Competitive Behaviors Policy ANSWER: No. You cannot use IP or confidential information agreements that are approved by the Legal department. Intellectual Property Policy from any other company. Report the matter to the Legal 9 Do not disclose or use Flowserve’s IP or confidential Invention Disclosure and Assignment Form Department or your regional I&C contact. INTEGRITY information for your own personal gain. IN DEALING WITH OTHERS 18TABLE OF We Safeguard CONTENTS Our Intellectual Property and Confidential Information OUR 9 Do not solicit, obtain or use the IP or confidential OUR INTEGRITY COMMITMENT VALUES information of other parties like customers or competitors. Through our more than 200-year history, Flowserve has Intellectual property includes patents, developed a vast body of intellectual property (IP), unique 9 If you obtain confidential information about another entity trade secrets, trademarks and copyrights knowledge, technical know-how and proprietary business through any source, do not use or share it and contact the which embody and protect Flowserve’s information (confidential information) related to flow control Legal department or your regional I&C contact. inventions, product designs, processes, products and services and the applications where they brands, business plans, marketing materials, We Maintain are used. We safeguard our intellectual property and Accurate Business Inventions and IP created, improved or software and computer code, and other confidential information and prevent its misuse or and Financial enhanced in the normal course of your information, knowledge and processes. Records unauthorized disclosure. INTEGRITY work for Flowserve belong exclusively to IN OUR Confidential or proprietary information Flowserve. You agree to assist Flowserve We Protect PEOPLE is information related to our business that is OUR POLICIES in securing its rights to such inventions Flowserve’s Assets not publicly known or generally available and and IP, including assignment of your • We diligently protect our IP and confidential information is held in confidence by the company. interest or rights, if necessary. Disclose and enforce our rights against others who take or use it We Safeguard Our Examples include manufacturing or detail all inventions or IP creations, improvements Intellectual Property without authorization. drawings, manufacturing and engineering and Confidential or enhancements to Flowserve’s IP counsel Information processes, bills of materials, customer and • We do not take or use the IP or confidential information in the Legal Department. supplier lists, price lists and market strategies. that belongs to others without proper authorization. We Do Not Trade on INTEGRITY Insider Information FREQUENTLY ASKED QUESTION IN OUR OUR RESPONSIBILITIES QUESTION: A friend who recently left a competitor COMPANY We Speak on 9 Do not disclose Flowserve’s IP or confidential company gave me coding for the company’s new Behalf of Flowserve information to a third party without approval of an LEARN MORE Through diagnostic software. I think the coding solutions could appropriate director-level business leader or above and Designated Confidential and Proprietary Information Policy help upgrade Flowserve’s diagnostic software. Can Spokespersons IP counsel. Disclosure for valid business reasons can I use the code to revise Flowserve’s software? Policy on Gathering Competitor Information be authorized through confidentiality or non-disclosure Anti-Trust and Anti-Competitive Behaviors Policy ANSWER: No. You cannot use IP or confidential information agreements that are approved by the Legal department. Intellectual Property Policy from any other company. Report the matter to the Legal 9 Do not disclose or use Flowserve’s IP or confidential Invention Disclosure and Assignment Form Department or your regional I&C contact. INTEGRITY information for your own personal gain. IN DEALING WITH OTHERS 18
TABLE OF We Do Not Trade CONTENTS on Insider Information 9 Be aware of the types of information that can be OUR INTEGRITY COMMITMENT considered insider information, including non-public As employees, we may receive confidential information information about mergers or acquisitions, sales or OUR about the company or our business partners that if made earnings, financial forecasts, changes to the executive VALUES public, could influence peoples’ decisions about whether to management, or pending lawsuits or regulatory buy, sell or hold the company’s securities (such as stocks or investigations. bonds), or could impact the value of the company’s shares. Information like this is called “insider information”. We 9 If you are aware of insider information or are advised that do not use or disclose such information except where you are subject to a defined trading window or blackout approved for legitimate business purposes. period, do not trade in Flowserve securities until the We Maintain restriction has been lifted and you have received prior Accurate Business and Financial written approval from the Legal department. OUR POLICIES Records INTEGRITY • We comply with all insider trading laws and regulations. IN OUR FREQUENTLY ASKED QUESTION We Protect PEOPLE • We do not use or share insider information for our own Flowserve’s Assets QUESTION: I overheard a senior manager talking about personal benefit or for the benefit of any other person a company we are thinking about buying. A close friend or entity. We Safeguard Our of mine works at the company. Can I let him know that this Intellectual Property is a possibility? • We safeguard confidential, non-public information about and Confidential Information Flowserve and our business partners. ANSWER: No. This information could be considered insider information and you may not disclose it to your friend or We Do Not Trade on INTEGRITY OUR RESPONSIBILITIES anyone else, whether inside or outside Flowserve. If you Insider Information IN OUR aren’t sure whether information is considered insider 9 Do not buy or sell securities of Flowserve or any other information, you should contact the Legal department. COMPANY company, either directly or through a third party like a We Speak on Behalf of Flowserve family member or friend, while aware of insider information. Through Designated 9 Closely safeguard and avoid disclosing to any third- Spokespersons party insider information about Flowserve and our business partners. LEARN MORE 9 Do not encourage or attempt to influence others, Insider Trading Policy including employees, family members, friends and INTEGRITY Confidential and Proprietary Information Policy business associates, to buy, sell or hold securities IN DEALING based on insider information. WITH OTHERS 19TABLE OF We Do Not Trade CONTENTS on Insider Information 9 Be aware of the types of information that can be OUR INTEGRITY COMMITMENT considered insider information, including non-public As employees, we may receive confidential information information about mergers or acquisitions, sales or OUR about the company or our business partners that if made earnings, financial forecasts, changes to the executive VALUES public, could influence peoples’ decisions about whether to management, or pending lawsuits or regulatory buy, sell or hold the company’s securities (such as stocks or investigations. bonds), or could impact the value of the company’s shares. Information like this is called “insider information”. We 9 If you are aware of insider information or are advised that do not use or disclose such information except where you are subject to a defined trading window or blackout approved for legitimate business purposes. period, do not trade in Flowserve securities until the We Maintain restriction has been lifted and you have received prior Accurate Business and Financial written approval from the Legal department. OUR POLICIES Records INTEGRITY • We comply with all insider trading laws and regulations. IN OUR FREQUENTLY ASKED QUESTION We Protect PEOPLE • We do not use or share insider information for our own Flowserve’s Assets QUESTION: I overheard a senior manager talking about personal benefit or for the benefit of any other person a company we are thinking about buying. A close friend or entity. We Safeguard Our of mine works at the company. Can I let him know that this Intellectual Property is a possibility? • We safeguard confidential, non-public information about and Confidential Information Flowserve and our business partners. ANSWER: No. This information could be considered insider information and you may not disclose it to your friend or We Do Not Trade on INTEGRITY OUR RESPONSIBILITIES anyone else, whether inside or outside Flowserve. If you Insider Information IN OUR aren’t sure whether information is considered insider 9 Do not buy or sell securities of Flowserve or any other information, you should contact the Legal department. COMPANY company, either directly or through a third party like a We Speak on Behalf of Flowserve family member or friend, while aware of insider information. Through Designated 9 Closely safeguard and avoid disclosing to any third- Spokespersons party insider information about Flowserve and our business partners. LEARN MORE 9 Do not encourage or attempt to influence others, Insider Trading Policy including employees, family members, friends and INTEGRITY Confidential and Proprietary Information Policy business associates, to buy, sell or hold securities IN DEALING based on insider information. WITH OTHERS 19
TABLE OF We Speak on Behalf CONTENTS of Flowserve Through Designated Spokespersons OUR 9 When using social media, make clear that any views you OUR INTEGRITY COMMITMENT VALUES express about Flowserve are your own and not those of Today, our words can be shared instantly through the company. countless online platforms and can greatly influence how our customers, shareholders, business partners and the public view Flowserve. We are committed to FREQUENTLY ASKED QUESTIONS providing clear, complete and accurate information QUESTION: A competitor posted on social media that We Maintain when we communicate about Flowserve. Accurate Business his company’s pump outperforms Flowserve’s comparable and Financial pump. He cited a recent study comparing the products, but Records INTEGRITY OUR POLICIES misrepresented its conclusions. I want to post a response IN OUR correcting his false representation. Is this OK? • We rely on designated company spokespersons We Protect PEOPLE Flowserve’s Assets to communicate about Flowserve externally. ANSWER: No. While we appreciate the desire to correct misrepresentations in the market, only authorized • As individuals, we do not communicate on behalf We Safeguard Our spokespersons may speak for Flowserve. Contact of Flowserve or give the impression that our views Intellectual Property Corporate Communications so the company can address and Confidential represent the views of the company. Information the situation. OUR RESPONSIBILITIES We Do Not Trade on INTEGRITY Insider Information 9 Do not make public statements on Flowserve’s behalf IN OUR LEARN MORE unless you are authorized to do so. This includes COMPANY We Speak on posting commentary or content about Flowserve on Media and Investor Relations and Disclosure Policy Behalf of Flowserve social media platforms. Financial Information Disclosure Policy Through Designated Social Media Guidelines 9 Know where to send external requests for information Spokespersons Public Advocacy Policy about Flowserve: − Refer media inquiries to Corporate Communications; − Refer requests for financial information to Investor INTEGRITY Relations; and IN DEALING − Refer requests for information from governments or WITH OTHERS regulatory agencies to the Legal department. 20TABLE OF We Speak on Behalf CONTENTS of Flowserve Through Designated Spokespersons OUR 9 When using social media, make clear that any views you OUR INTEGRITY COMMITMENT VALUES express about Flowserve are your own and not those of Today, our words can be shared instantly through the company. countless online platforms and can greatly influence how our customers, shareholders, business partners and the public view Flowserve. We are committed to FREQUENTLY ASKED QUESTIONS providing clear, complete and accurate information QUESTION: A competitor posted on social media that We Maintain when we communicate about Flowserve. Accurate Business his company’s pump outperforms Flowserve’s comparable and Financial pump. He cited a recent study comparing the products, but Records INTEGRITY OUR POLICIES misrepresented its conclusions. I want to post a response IN OUR correcting his false representation. Is this OK? • We rely on designated company spokespersons We Protect PEOPLE Flowserve’s Assets to communicate about Flowserve externally. ANSWER: No. While we appreciate the desire to correct misrepresentations in the market, only authorized • As individuals, we do not communicate on behalf We Safeguard Our spokespersons may speak for Flowserve. Contact of Flowserve or give the impression that our views Intellectual Property Corporate Communications so the company can address and Confidential represent the views of the company. Information the situation. OUR RESPONSIBILITIES We Do Not Trade on INTEGRITY Insider Information 9 Do not make public statements on Flowserve’s behalf IN OUR LEARN MORE unless you are authorized to do so. This includes COMPANY We Speak on posting commentary or content about Flowserve on Media and Investor Relations and Disclosure Policy Behalf of Flowserve social media platforms. Financial Information Disclosure Policy Through Designated Social Media Guidelines 9 Know where to send external requests for information Spokespersons Public Advocacy Policy about Flowserve: − Refer media inquiries to Corporate Communications; − Refer requests for financial information to Investor INTEGRITY Relations; and IN DEALING − Refer requests for information from governments or WITH OTHERS regulatory agencies to the Legal department. 20
TABLE OF CONTENTS Integrity in Dealing OUR With Others VALUES Our Relationships With Business Partners Are Based on Integrity and Trust INTEGRITY We Compete Fairly IN OUR in the Marketplace PEOPLE We Prohibit Bribery and Corruption Our Code of Conduct isn’t just about how we work. It’s about how We Follow Our Policies on Gifts, we interact with each other and Travel and INTEGRITY Entertainment the respect we show for the IN OUR COMPANY people and communities We Comply With International we serve. Trade Laws We Deal Honestly and Fairly With Governments INTEGRITY IN DEALING We Invest in Our Communities WITH OTHERS 21TABLE OF CONTENTS Integrity in Dealing OUR With Others VALUES Our Relationships With Business Partners Are Based on Integrity and Trust INTEGRITY We Compete Fairly IN OUR in the Marketplace PEOPLE We Prohibit Bribery and Corruption Our Code of Conduct isn’t just about how we work. It’s about how We Follow Our Policies on Gifts, we interact with each other and Travel and INTEGRITY Entertainment the respect we show for the IN OUR COMPANY people and communities We Comply With International we serve. Trade Laws We Deal Honestly and Fairly With Governments INTEGRITY IN DEALING We Invest in Our Communities WITH OTHERS 21
TABLE OF Our Relationships With CONTENTS Business Partners Are Based on Integrity and Trust OUR 9 Follow our procurement, sourcing and due diligence OUR INTEGRITY COMMITMENT VALUES screening processes before engaging any business Our suppliers and other third parties like agents, sales partner. representatives and distributors (collectively “business partners”) are an important part of our business and are Our Relationships 9 Safeguard our proprietary and confidential information With Business vital to the success of our company. We only work with and personal data. Use confidentiality agreements Partners Are Based business partners who uphold our values and standards where appropriate. on Integrity and who conduct business in an ethical, legal and and Trust 9 Make sure suppliers comply with the expectations in responsible manner. our Supplier Code of Business Conduct. INTEGRITY We Compete Fairly in IN OUR OUR POLICIES the Marketplace PEOPLE FREQUENTLY ASKED QUESTION • We treat our business partners fairly and with respect. QUESTION: I recently read in the paper that one of our We Prohibit • We only do business with business partners who act Bribery and long-time suppliers was fined by the government for paying ethically and comply with applicable laws. Corruption bribes to get work on a big public construction project. It didn’t have anything to do with Flowserve and I’d hate to • We expect our suppliers to comply with Flowserve’s lose this supplier. What should I do? We Follow Our Poli- Supplier Code of Conduct and all business partners cies on Gifts, Travel to comply with the standards embodied in this Code ANSWER: You should report the information to your and INTEGRITY of Conduct. Entertainment regional I&C contact for review. Failing to raise potential IN OUR concerns about suppliers, even good ones, can put COMPANY Flowserve at compliance risk. OUR RESPONSIBILITIES We Comply With International 9 Select business partners objectively based on criteria Trade Laws such as quality, skill, reputation, price and performance LEARN MORE – never based on favoritism or our own personal interests. Travel and Expense Reporting, Entertainment We Deal Honestly and Business Gift Policy and Fairly With 9 Avoid conflicts of interest. Never accept gifts, offers of Supplier Code of Business Conduct Governments entertainment or other items of value from a business INTEGRITY Supplier Selection Policy partner unless it complies with our policies related to IN DEALING Third Party Due Diligence Policy We Invest in Our gifts, travel and entertainment. Communities WITH OTHERS 22TABLE OF Our Relationships With CONTENTS Business Partners Are Based on Integrity and Trust OUR 9 Follow our procurement, sourcing and due diligence OUR INTEGRITY COMMITMENT VALUES screening processes before engaging any business Our suppliers and other third parties like agents, sales partner. representatives and distributors (collectively “business partners”) are an important part of our business and are Our Relationships 9 Safeguard our proprietary and confidential information With Business vital to the success of our company. We only work with and personal data. Use confidentiality agreements Partners Are Based business partners who uphold our values and standards where appropriate. on Integrity and who conduct business in an ethical, legal and and Trust 9 Make sure suppliers comply with the expectations in responsible manner. our Supplier Code of Business Conduct. INTEGRITY We Compete Fairly in IN OUR OUR POLICIES the Marketplace PEOPLE FREQUENTLY ASKED QUESTION • We treat our business partners fairly and with respect. QUESTION: I recently read in the paper that one of our We Prohibit • We only do business with business partners who act Bribery and long-time suppliers was fined by the government for paying ethically and comply with applicable laws. Corruption bribes to get work on a big public construction project. It didn’t have anything to do with Flowserve and I’d hate to • We expect our suppliers to comply with Flowserve’s lose this supplier. What should I do? We Follow Our Poli- Supplier Code of Conduct and all business partners cies on Gifts, Travel to comply with the standards embodied in this Code ANSWER: You should report the information to your and INTEGRITY of Conduct. Entertainment regional I&C contact for review. Failing to raise potential IN OUR concerns about suppliers, even good ones, can put COMPANY Flowserve at compliance risk. OUR RESPONSIBILITIES We Comply With International 9 Select business partners objectively based on criteria Trade Laws such as quality, skill, reputation, price and performance LEARN MORE – never based on favoritism or our own personal interests. Travel and Expense Reporting, Entertainment We Deal Honestly and Business Gift Policy and Fairly With 9 Avoid conflicts of interest. Never accept gifts, offers of Supplier Code of Business Conduct Governments entertainment or other items of value from a business INTEGRITY Supplier Selection Policy partner unless it complies with our policies related to IN DEALING Third Party Due Diligence Policy We Invest in Our gifts, travel and entertainment. Communities WITH OTHERS 22
TABLE OF We Compete Fairly CONTENTS in the Marketplace OUR INTEGRITY COMMITMENT OUR RESPONSIBILITIES If you receive confidential or proprietary We compete fairly in the markets we serve, we deal honestly 9 Do not propose or agree with any competitor, customer information about a competitor or business OUR with our customers and business partners, and we do not or supplier to: opportunity, do not use or share it. Report VALUES use unfair or deceptive practices to gain an advantage over − Raise, set or hold steady (“fix”) prices; it to your regional I&C contact, who will advise our competitors. − Prevent another company from entering a market; you on appropriate measures to return or − Refuse to deal with a certain customer or supplier; destroy the information. Our Relationships OUR POLICIES With Business − Allocate or assign territories, markets or customers; Partners Are Based • We comply with fair competition and antitrust laws and − Interfere with a competitive bidding process; FREQUENTLY ASKED QUESTIONS on Integrity regulations everywhere we do business. − Restrict or suspend production, sales or output; and Trust QUESTION: I ran into a former colleague at an industry • We do not disclose pricing or other contract terms to third − Require customers to buy something they do not event and learned that he now works for a competitor. INTEGRITY want by linking it to something they do. parties or make agreements with competitors to allocate We Compete Fairly He asked how business has been this quarter. How should IN OUR in the Marketplace market segments or territories. I respond? 9 Do not request or share competitive information with any PEOPLE competitor, including information about pricing, contract • We do not manipulate bidding processes, or seek or use ANSWER: You should keep your response high-level and We Prohibit terms, business strategies, production capacity, wages or confidential or proprietary competitor information. non-specific. Avoid any discussions involving details of Bribery and other non-public competitive information. Flowserve’s or a competitor’s business results or strategies. Corruption 9 Do not propose or agree with another company not to QUESTION: One of our external sales agents emailed me a We Follow Our solicit or hire each other’s employees or business partners Policies on Gifts, competitor’s draft bid on a project we are also bidding. There like suppliers. Travel and INTEGRITY is no pricing information, but it does have other contract Entertainment 9 Avoid situations that could create the appearance of IN OUR terms filled in. I did not request this, but it could be useful improper dealings with competitors. Be careful at industry in preparing our bid. Is it OK to use the information? COMPANY events to avoid discussing Flowserve or competitor busi- We Comply ANSWER: No. We do not use competitors’ confidential With International ness, including at informal meetings, meals or social events. information like bids, even if pricing information is not Trade Laws 9 Use only appropriate sources, such as public filings, news included. Many contract terms can be considered confi- articles and industry publications when gathering informa- dential competitive information. While you did not ask for We Deal Honestly LEARN MORE tion on a competitor. the information, simply having access to it creates risk for and Fairly With you and the company. Do not use or share the information, Governments Anti-Trust and Anti-Competitive Behaviors Policy 9 If you receive confidential or proprietary information about INTEGRITY and contact your regional I&C contact for guidance on how Policy on Gathering Competitor Information a competitor or business opportunity, do not use or share to return or destroy it. IN DEALING Anti-bribery Gift, Meal, Entertainment We Invest in Our it. Report it to your regional I&C contact, who will advise and Travel Policy for Government Officials Communities WITH OTHERS you on appropriate measures to return or destroy the 23 information.TABLE OF We Compete Fairly CONTENTS in the Marketplace OUR INTEGRITY COMMITMENT OUR RESPONSIBILITIES If you receive confidential or proprietary We compete fairly in the markets we serve, we deal honestly 9 Do not propose or agree with any competitor, customer information about a competitor or business OUR with our customers and business partners, and we do not or supplier to: opportunity, do not use or share it. Report VALUES use unfair or deceptive practices to gain an advantage over − Raise, set or hold steady (“fix”) prices; it to your regional I&C contact, who will advise our competitors. − Prevent another company from entering a market; you on appropriate measures to return or − Refuse to deal with a certain customer or supplier; destroy the information. Our Relationships OUR POLICIES With Business − Allocate or assign territories, markets or customers; Partners Are Based • We comply with fair competition and antitrust laws and − Interfere with a competitive bidding process; FREQUENTLY ASKED QUESTIONS on Integrity regulations everywhere we do business. − Restrict or suspend production, sales or output; and Trust QUESTION: I ran into a former colleague at an industry • We do not disclose pricing or other contract terms to third − Require customers to buy something they do not event and learned that he now works for a competitor. INTEGRITY want by linking it to something they do. parties or make agreements with competitors to allocate We Compete Fairly He asked how business has been this quarter. How should IN OUR in the Marketplace market segments or territories. I respond? 9 Do not request or share competitive information with any PEOPLE competitor, including information about pricing, contract • We do not manipulate bidding processes, or seek or use ANSWER: You should keep your response high-level and We Prohibit terms, business strategies, production capacity, wages or confidential or proprietary competitor information. non-specific. Avoid any discussions involving details of Bribery and other non-public competitive information. Flowserve’s or a competitor’s business results or strategies. Corruption 9 Do not propose or agree with another company not to QUESTION: One of our external sales agents emailed me a We Follow Our solicit or hire each other’s employees or business partners Policies on Gifts, competitor’s draft bid on a project we are also bidding. There like suppliers. Travel and INTEGRITY is no pricing information, but it does have other contract Entertainment 9 Avoid situations that could create the appearance of IN OUR terms filled in. I did not request this, but it could be useful improper dealings with competitors. Be careful at industry in preparing our bid. Is it OK to use the information? COMPANY events to avoid discussing Flowserve or competitor busi- We Comply ANSWER: No. We do not use competitors’ confidential With International ness, including at informal meetings, meals or social events. information like bids, even if pricing information is not Trade Laws 9 Use only appropriate sources, such as public filings, news included. Many contract terms can be considered confi- articles and industry publications when gathering informa- dential competitive information. While you did not ask for We Deal Honestly LEARN MORE tion on a competitor. the information, simply having access to it creates risk for and Fairly With you and the company. Do not use or share the information, Governments Anti-Trust and Anti-Competitive Behaviors Policy 9 If you receive confidential or proprietary information about INTEGRITY and contact your regional I&C contact for guidance on how Policy on Gathering Competitor Information a competitor or business opportunity, do not use or share to return or destroy it. IN DEALING Anti-bribery Gift, Meal, Entertainment We Invest in Our it. Report it to your regional I&C contact, who will advise and Travel Policy for Government Officials Communities WITH OTHERS you on appropriate measures to return or destroy the 23 information.
TABLE OF We Prohibit CONTENTS Bribery and Corruption OUR OUR INTEGRITY COMMITMENT VALUES We do not permit or engage in bribery or corruption of any kind, for any reason, in any country where we do business. Our Relationships With Business OUR POLICIES Partners Are Based on Integrity • We prohibit improper payments and corruption of any kind in our business dealings, and Trust in every country in the world, whether dealing with governments or the private sector. INTEGRITY • We comply with applicable anti-corruption laws, this Code and our policies. We Compete Fairly in IN OUR the Marketplace • We keep accurate books, records and accounts that reflect the true nature of all PEOPLE our transactions. We Prohibit Bribery and OUR RESPONSIBILITIES Corruption 9 Do not offer, promise or authorize any payment or thing of value to government officials or to any other person to obtain any improper business advantage or to We Follow Our influence decisions in our favor. Policies on Gifts, Travel and INTEGRITY 9 Comply with Flowserve’s policies and seek approval before offering or giving a gift Entertainment IN OUR or providing entertainment, travel or other items of value to any government official, COMPANY customer or supplier. We Comply With International Trade Laws We Deal Honestly and Fairly With Governments INTEGRITY IN DEALING We Invest in Our Communities WITH OTHERS 24TABLE OF We Prohibit CONTENTS Bribery and Corruption OUR OUR INTEGRITY COMMITMENT VALUES We do not permit or engage in bribery or corruption of any kind, for any reason, in any country where we do business. Our Relationships With Business OUR POLICIES Partners Are Based on Integrity • We prohibit improper payments and corruption of any kind in our business dealings, and Trust in every country in the world, whether dealing with governments or the private sector. INTEGRITY • We comply with applicable anti-corruption laws, this Code and our policies. We Compete Fairly in IN OUR the Marketplace • We keep accurate books, records and accounts that reflect the true nature of all PEOPLE our transactions. We Prohibit Bribery and OUR RESPONSIBILITIES Corruption 9 Do not offer, promise or authorize any payment or thing of value to government officials or to any other person to obtain any improper business advantage or to We Follow Our influence decisions in our favor. Policies on Gifts, Travel and INTEGRITY 9 Comply with Flowserve’s policies and seek approval before offering or giving a gift Entertainment IN OUR or providing entertainment, travel or other items of value to any government official, COMPANY customer or supplier. We Comply With International Trade Laws We Deal Honestly and Fairly With Governments INTEGRITY IN DEALING We Invest in Our Communities WITH OTHERS 24
We Prohibit Bribery and Corruption (continued) TABLE OF CONTENTS 9 Flowserve can be responsible if anyone acting on its behalf makes improper payments, including business It is important to monitor the conduct of Rules to partners like sales agents, consultants or Customs business partners working on our behalf. brokers. Watch for red flags like requests for additional Remember compensation, advance payments, payments − Follow our processes for pre-screening and • Bribery is not limited to cash payments OUR to unrelated parties, requests for payment engagement of third parties and consistently monitor the conduct of third parties you engage. in cash, or requests to use unknown or kickbacks and can include anything VALUES subcontractors or agents. − Report conduct that suggests a third party may be offered to gain a business advantage or violating our anti-corruption policy. to reward someone for taking an action Our Relationships in our favor such as expensive gifts or 9 Contact your regional I&C contact if you have With Business entertainment or offers of employment. Protect Your Personal Safety questions about local laws, customs or practices Partners Are Based on Integrity that may conflict with Flowserve policies or this Code. In the rare situation where refusing to make a • Facilitation payments are small and Trust payments made at the request of payment will result in an immediate threat to your INTEGRITY FREQUENTLY ASKED QUESTIONS: government officials to speed up routine We Compete Fairly in IN OUR or your family’s health or safety, a payment may clerical or administrative actions, such QUESTION: I do not work at a U.S. site and I am not a U.S. the Marketplace PEOPLE citizen. Does the U.S. anti-bribery law, the Foreign Corrupt as processing visas or clearing Customs. be made without prior approval. This applies only Practices Act (FCPA), apply to me and my business unit? Flowserve policy prohibits making We Prohibit to physical threats, not commercial or financial Bribery and facilitation payments, even where local ANSWER: Yes. Any person employed by or acting on behalf Corruption laws may permit them. of a company subject to the FCPA — such as Flowserve — concerns. As soon as you are safe, report the can be liable for actions that violate the FCPA. This can also • Government officials include persons We Follow Our be true for the anti-corruption laws of other countries. incident to your regional I&C contact. Policies on Gifts, at any level of seniority employed by or Travel and INTEGRITY representing: (i) a local, state, provincial QUESTION: I have been asked by a local Customs agent to Entertainment IN OUR or national government; or (ii) any pay a small fee to move a shipment of our products through COMPANY LEARN MORE company that is owned, operated or Customs more quickly. Is this allowed? We Comply controlled by a government, such as a Anti-Bribery Policy With International ANSWER: No. This kind of payment would likely be national oil company or state-owned Travel and Expense Reporting, Trade Laws considered a facilitation payment, which is prohibited utility; and (iii) any non-U.S. political party, Entertainment and Business Gift Policy by Flowserve policy. If you are asked to make this kind party official or candidate for office. Antifraud Program Policy We Deal Honestly of payment, please contact your regional I&C leader and Fairly With Third Party Due Diligence Policy for assistance. Governments INTEGRITY IN DEALING We Invest in Our Communities WITH OTHERS 25We Prohibit Bribery and Corruption (continued) TABLE OF CONTENTS 9 Flowserve can be responsible if anyone acting on its behalf makes improper payments, including business It is important to monitor the conduct of Rules to partners like sales agents, consultants or Customs business partners working on our behalf. brokers. Watch for red flags like requests for additional Remember compensation, advance payments, payments − Follow our processes for pre-screening and • Bribery is not limited to cash payments OUR to unrelated parties, requests for payment engagement of third parties and consistently monitor the conduct of third parties you engage. in cash, or requests to use unknown or kickbacks and can include anything VALUES subcontractors or agents. − Report conduct that suggests a third party may be offered to gain a business advantage or violating our anti-corruption policy. to reward someone for taking an action Our Relationships in our favor such as expensive gifts or 9 Contact your regional I&C contact if you have With Business entertainment or offers of employment. Protect Your Personal Safety questions about local laws, customs or practices Partners Are Based on Integrity that may conflict with Flowserve policies or this Code. In the rare situation where refusing to make a • Facilitation payments are small and Trust payments made at the request of payment will result in an immediate threat to your INTEGRITY FREQUENTLY ASKED QUESTIONS: government officials to speed up routine We Compete Fairly in IN OUR or your family’s health or safety, a payment may clerical or administrative actions, such QUESTION: I do not work at a U.S. site and I am not a U.S. the Marketplace PEOPLE citizen. Does the U.S. anti-bribery law, the Foreign Corrupt as processing visas or clearing Customs. be made without prior approval. This applies only Practices Act (FCPA), apply to me and my business unit? Flowserve policy prohibits making We Prohibit to physical threats, not commercial or financial Bribery and facilitation payments, even where local ANSWER: Yes. Any person employed by or acting on behalf Corruption laws may permit them. of a company subject to the FCPA — such as Flowserve — concerns. As soon as you are safe, report the can be liable for actions that violate the FCPA. This can also • Government officials include persons We Follow Our be true for the anti-corruption laws of other countries. incident to your regional I&C contact. Policies on Gifts, at any level of seniority employed by or Travel and INTEGRITY representing: (i) a local, state, provincial QUESTION: I have been asked by a local Customs agent to Entertainment IN OUR or national government; or (ii) any pay a small fee to move a shipment of our products through COMPANY LEARN MORE company that is owned, operated or Customs more quickly. Is this allowed? We Comply controlled by a government, such as a Anti-Bribery Policy With International ANSWER: No. This kind of payment would likely be national oil company or state-owned Travel and Expense Reporting, Trade Laws considered a facilitation payment, which is prohibited utility; and (iii) any non-U.S. political party, Entertainment and Business Gift Policy by Flowserve policy. If you are asked to make this kind party official or candidate for office. Antifraud Program Policy We Deal Honestly of payment, please contact your regional I&C leader and Fairly With Third Party Due Diligence Policy for assistance. Governments INTEGRITY IN DEALING We Invest in Our Communities WITH OTHERS 25
TABLE OF We Follow Our Policies CONTENTS on Gifts, Travel and Entertainment OUR INTEGRITY COMMITMENT OUR RESPONSIBILITIES FREQUENTLY ASKED QUESTIONS We believe our relationships with customers and business 9 Make certain that any gift or entertainment offered or QUESTION: A National Oil Company (NOC) customer OUR partners should be built on trust and mutual values. Offering received is: asked Flowserve to sponsor a golf team for a charity VALUES or accepting gifts or entertainment can be appropriate in event. Two employees of the NOC and two employees − Of nominal value and within Flowserve’s policy limits. some circumstances, but we do not offer, solicit or accept of Flowserve will play on the team. Is this ok? − Not cash or cash equivalents such as gift cards. anything that could give rise to an actual or perceived ANSWER: Maybe. Participating alongside customers in Our Relationships conflict of interest or be viewed as an attempt to improperly − Infrequent. events such as golf tournaments can serve to build valuable With Business influence business decisions. Partners Are Based business relationships and promote Flowserve’s capabilities. − Related to a legitimate business purpose. on Integrity However, because the customer is an NOC, its employees and Trust OUR POLICIES − Consistent with business and industry standards. are considered government officials. Paying for their entry fee is a thing of value which could implicate anti-corruption • We comply with all applicable laws, including INTEGRITY − Not of a nature that would reflect poorly on Flowserve. We Compete Fairly laws. Carefully review our Anti-Bribery Policy and contact government procurement regulations, concerning IN OUR in the Marketplace − Complies with local laws and the policies of both giver your regional I&C contact for approval before agreeing to gifts and entertainment. PEOPLE and receiver. pay for the tournament entry fee. • We do not offer, solicit or accept gifts or entertainment We Prohibit − Accurately recorded. if it would improperly influence a business decision or Bribery and could create the appearance of impropriety, even if the QUESTION: A supplier offered me two tickets to a sold-out Corruption 9 If you are offered a gift or entertainment that violates value is within Flowserve’s policy limits. concert that he can’t attend. Can I accept? Flowserve’s policies, would influence your business We Follow Our • We do not solicit gifts or things of value from customers, ANSWER: No. You may not accept tickets to concerts, decision, or otherwise seems inappropriate, decline Policies on Gifts, suppliers or business partners in return for favorable sporting events or other entertainment if the customer or the offer. Travel and INTEGRITY treatment or make them provide something of value to supplier will not attend the event with you. Such situations Entertainment IN OUR do business with us. 9 Obtain pre-approval from your regional I&C contact do not enhance our business relationships or otherwise COMPANY before offering anything of value to a government present legitimate business purposes. We Comply employee or official. With International Trade Laws 9 Certain Flowserve sites may adopt additional procedures LEARN MORE related to gifts or entertainment, including monetary limits Anti-Bribery Policy that comply with local laws. We Deal Honestly Travel and Expense Reporting, and Fairly With Entertainment and Business Gift Policy Governments INTEGRITY Supplier Code of Conduct IN DEALING Third Party Due Diligence Policy We Invest in Our Communities WITH OTHERS 26TABLE OF We Follow Our Policies CONTENTS on Gifts, Travel and Entertainment OUR INTEGRITY COMMITMENT OUR RESPONSIBILITIES FREQUENTLY ASKED QUESTIONS We believe our relationships with customers and business 9 Make certain that any gift or entertainment offered or QUESTION: A National Oil Company (NOC) customer OUR partners should be built on trust and mutual values. Offering received is: asked Flowserve to sponsor a golf team for a charity VALUES or accepting gifts or entertainment can be appropriate in event. Two employees of the NOC and two employees − Of nominal value and within Flowserve’s policy limits. some circumstances, but we do not offer, solicit or accept of Flowserve will play on the team. Is this ok? − Not cash or cash equivalents such as gift cards. anything that could give rise to an actual or perceived ANSWER: Maybe. Participating alongside customers in Our Relationships conflict of interest or be viewed as an attempt to improperly − Infrequent. events such as golf tournaments can serve to build valuable With Business influence business decisions. Partners Are Based business relationships and promote Flowserve’s capabilities. − Related to a legitimate business purpose. on Integrity However, because the customer is an NOC, its employees and Trust OUR POLICIES − Consistent with business and industry standards. are considered government officials. Paying for their entry fee is a thing of value which could implicate anti-corruption • We comply with all applicable laws, including INTEGRITY − Not of a nature that would reflect poorly on Flowserve. We Compete Fairly laws. Carefully review our Anti-Bribery Policy and contact government procurement regulations, concerning IN OUR in the Marketplace − Complies with local laws and the policies of both giver your regional I&C contact for approval before agreeing to gifts and entertainment. PEOPLE and receiver. pay for the tournament entry fee. • We do not offer, solicit or accept gifts or entertainment We Prohibit − Accurately recorded. if it would improperly influence a business decision or Bribery and could create the appearance of impropriety, even if the QUESTION: A supplier offered me two tickets to a sold-out Corruption 9 If you are offered a gift or entertainment that violates value is within Flowserve’s policy limits. concert that he can’t attend. Can I accept? Flowserve’s policies, would influence your business We Follow Our • We do not solicit gifts or things of value from customers, ANSWER: No. You may not accept tickets to concerts, decision, or otherwise seems inappropriate, decline Policies on Gifts, suppliers or business partners in return for favorable sporting events or other entertainment if the customer or the offer. Travel and INTEGRITY treatment or make them provide something of value to supplier will not attend the event with you. Such situations Entertainment IN OUR do business with us. 9 Obtain pre-approval from your regional I&C contact do not enhance our business relationships or otherwise COMPANY before offering anything of value to a government present legitimate business purposes. We Comply employee or official. With International Trade Laws 9 Certain Flowserve sites may adopt additional procedures LEARN MORE related to gifts or entertainment, including monetary limits Anti-Bribery Policy that comply with local laws. We Deal Honestly Travel and Expense Reporting, and Fairly With Entertainment and Business Gift Policy Governments INTEGRITY Supplier Code of Conduct IN DEALING Third Party Due Diligence Policy We Invest in Our Communities WITH OTHERS 26
TABLE OF We Comply CONTENTS With International Trade Laws OUR OUR INTEGRITY COMMITMENT VALUES We comply with all import and export controls, economic sanctions and customs laws that regulate the movement of our goods, services, information and technology around the world. Our Relationships With Business OUR POLICIES Partners Are Based on Integrity • We comply with the trade laws of the countries where we do business. and Trustt • We provide accurate classification data and documentation for the products, services, INTEGRITY information and technology we sell. We Compete Fairly IN OUR • We carefully evaluate business opportunities in countries subject to trade embargoes or in the Marketplace PEOPLE economic sanctions to ensure we operate within the requirements of such regulations. We Prohibit • We do not participate in or promote boycotts that the U.S. does not support. Bribery and • We screen transactions to ensure we do not conduct business with terrorists, those Corruption involved in illegal weapons proliferation or other prohibited parties. We Follow Our Policies on Gifts, Travel and INTEGRITY Entertainment IN OUR COMPANY We Comply With International Trade Laws We Deal Honestly and Fairly With Governments INTEGRITY IN DEALING We Invest in Our Communities WITH OTHERS 27TABLE OF We Comply CONTENTS With International Trade Laws OUR OUR INTEGRITY COMMITMENT VALUES We comply with all import and export controls, economic sanctions and customs laws that regulate the movement of our goods, services, information and technology around the world. Our Relationships With Business OUR POLICIES Partners Are Based on Integrity • We comply with the trade laws of the countries where we do business. and Trustt • We provide accurate classification data and documentation for the products, services, INTEGRITY information and technology we sell. We Compete Fairly IN OUR • We carefully evaluate business opportunities in countries subject to trade embargoes or in the Marketplace PEOPLE economic sanctions to ensure we operate within the requirements of such regulations. We Prohibit • We do not participate in or promote boycotts that the U.S. does not support. Bribery and • We screen transactions to ensure we do not conduct business with terrorists, those Corruption involved in illegal weapons proliferation or other prohibited parties. We Follow Our Policies on Gifts, Travel and INTEGRITY Entertainment IN OUR COMPANY We Comply With International Trade Laws We Deal Honestly and Fairly With Governments INTEGRITY IN DEALING We Invest in Our Communities WITH OTHERS 27
We Comply With International Trade Laws (continued) TABLE OF CONTENTS OUR RESPONSIBILITIES FREQUENTLY ASKED QUESTIONS 9 Ensure that anything intended for import or export: QUESTION: I am based in Singapore and recently received Export control laws regulate cross-border an order from a customer in China. To fill the order, product − Is classified correctly, based on the country of origin, transfers of goods, software and know-how would need to ship from one of our U.S. plants. I am not a destination, end use and end user. that can be used for military or proliferation U.S. citizen. Do I still need to follow U.S. export laws? purposes; some countries also regulate the OUR − Includes all required documentation, labeling, licensing, ANSWER: Yes. Since the product will ship from the U.S., permits and approvals. release of technical data to foreign nationals. VALUES you must follow U.S. export laws. In addition, because − Identifies any restricted software. Sanctions laws include embargoes and Flowserve is a U.S. company, even our non-U.S. facilities boycotts and serve to restrict trade of certain can be required to comply with U.S. trade laws in certain Our Relationships 9 Use only approved customs brokers, freight forwarders goods and services in specified countries circumstances. Please check with your site Trade With Business or other third party logistics agents. and with specified companies and people. Partners Are Based Coordinator or regional I&C contact with questions. on Integrity 9 Follow the company’s Export and Denied Party and Trust Screening procedures to ensure we do not do QUESTION: I am negotiating a contract and have been business with sanctioned persons or companies. INTEGRITY asked to provide information about Flowserve’s business We Compete Fairly IN OUR with Israel. Can I comply with this request? 9 U.S. anti-boycott laws prohibit participating in boycotts in the Marketplace PEOPLE not sanctioned by the U.S. and providing information ANSWER: No, this may be prohibited by U.S. anti-boycott about a company’s business in countries subject to laws. You should check with your regional I&C contact We Prohibit LEARN MORE a boycott. before responding. Bribery and Corruption Trade Compliance Policy − If asked to participate in a boycott or about Flowserve’s Third Party Due Diligence Policy position on a boycott, or if you believe a business partner is participating in a boycott, report it to your Global External Communication Policy We Follow Our (regarding trade compliance matters) regional I&C contact. Policies on Gifts, Travel and Export Compliance Policies INTEGRITY 9 Obtain proper documentation and required licenses Entertainment Import Compliance Policies IN OUR before carrying any commercial product across a border, COMPANY and ensure correct customs declarations are made. We Comply With International Trade Laws We Deal Honestly and Fairly With Governments INTEGRITY IN DEALING We Invest in Our Communities WITH OTHERS 28We Comply With International Trade Laws (continued) TABLE OF CONTENTS OUR RESPONSIBILITIES FREQUENTLY ASKED QUESTIONS 9 Ensure that anything intended for import or export: QUESTION: I am based in Singapore and recently received Export control laws regulate cross-border an order from a customer in China. To fill the order, product − Is classified correctly, based on the country of origin, transfers of goods, software and know-how would need to ship from one of our U.S. plants. I am not a destination, end use and end user. that can be used for military or proliferation U.S. citizen. Do I still need to follow U.S. export laws? purposes; some countries also regulate the OUR − Includes all required documentation, labeling, licensing, ANSWER: Yes. Since the product will ship from the U.S., permits and approvals. release of technical data to foreign nationals. VALUES you must follow U.S. export laws. In addition, because − Identifies any restricted software. Sanctions laws include embargoes and Flowserve is a U.S. company, even our non-U.S. facilities boycotts and serve to restrict trade of certain can be required to comply with U.S. trade laws in certain Our Relationships 9 Use only approved customs brokers, freight forwarders goods and services in specified countries circumstances. Please check with your site Trade With Business or other third party logistics agents. and with specified companies and people. Partners Are Based Coordinator or regional I&C contact with questions. on Integrity 9 Follow the company’s Export and Denied Party and Trust Screening procedures to ensure we do not do QUESTION: I am negotiating a contract and have been business with sanctioned persons or companies. INTEGRITY asked to provide information about Flowserve’s business We Compete Fairly IN OUR with Israel. Can I comply with this request? 9 U.S. anti-boycott laws prohibit participating in boycotts in the Marketplace PEOPLE not sanctioned by the U.S. and providing information ANSWER: No, this may be prohibited by U.S. anti-boycott about a company’s business in countries subject to laws. You should check with your regional I&C contact We Prohibit LEARN MORE a boycott. before responding. Bribery and Corruption Trade Compliance Policy − If asked to participate in a boycott or about Flowserve’s Third Party Due Diligence Policy position on a boycott, or if you believe a business partner is participating in a boycott, report it to your Global External Communication Policy We Follow Our (regarding trade compliance matters) regional I&C contact. Policies on Gifts, Travel and Export Compliance Policies INTEGRITY 9 Obtain proper documentation and required licenses Entertainment Import Compliance Policies IN OUR before carrying any commercial product across a border, COMPANY and ensure correct customs declarations are made. We Comply With International Trade Laws We Deal Honestly and Fairly With Governments INTEGRITY IN DEALING We Invest in Our Communities WITH OTHERS 28
TABLE OF We Deal Honestly and CONTENTS Fairly With Governments 9 Avoid situations that could create a conflict of interest OUR INTEGRITY COMMITMENT with a government employee. For example, do not We follow the highest ethical standards in conducting discuss future employment or business opportunities OUR business with governments around the world. with government officials. VALUES 9 If awarded government business, perform in accordance OUR POLICIES with the contract terms and regulatory obligations. • We comply with all contract terms and conditions, Our Relationships 9 Because political contributions can be viewed as a way to With Business applicable laws, regulations and Flowserve policies Partners Are Based influence government officials, you may not use Flowserve when working with governments. on Integrity assets in connection with any political activity. You may and Trust • We maintain appropriate controls and procedures specific contribute your own time and resources, but must make to our government business activities. clear that you are not acting or speaking for Flowserve. INTEGRITY We Compete Fairly IN OUR 9 If you are contacted by a government representative in the Marketplace OUR RESPONSIBILITIES regarding an investigation, audit or request for information PEOPLE or documents, direct them to the Legal department for 9 Government procurement rules can be complicated, so We Prohibit assistance. you must be familiar with applicable rules and regulations Bribery and before pursuing such business. Supply Chain can assist Corruption you if you have questions. FREQUENTLY ASKED QUESTION We Follow Our 9 Never submit inaccurate or incomplete information in QUESTION: My friend is running for local political office Policies on Gifts, response to a government bid. and I would like to volunteer to help with her campaign. Travel and INTEGRITY Is this allowed? Entertainment 9 Do not solicit or accept confidential information about IN OUR a government’s selection process or a competitor’s ANSWER: Yes. You may use your own time and resources COMPANY We Comply proposal. If you receive such information, contact your to support political activity. Do not use Flowserve funds, With International regional I&C contact. property or equipment for personal political activities, and Trade Laws always make clear that your views and actions are your 9 Do not authorize, promise or provide anything of value, own, and not Flowserve’s. including gifts, meals or entertainment to a government We Deal Honestly employee unless you have obtained pre-approval and Fairly With Governments from I&C. INTEGRITY IN DEALING We Invest in Our Communities WITH OTHERS 29TABLE OF We Deal Honestly and CONTENTS Fairly With Governments 9 Avoid situations that could create a conflict of interest OUR INTEGRITY COMMITMENT with a government employee. For example, do not We follow the highest ethical standards in conducting discuss future employment or business opportunities OUR business with governments around the world. with government officials. VALUES 9 If awarded government business, perform in accordance OUR POLICIES with the contract terms and regulatory obligations. • We comply with all contract terms and conditions, Our Relationships 9 Because political contributions can be viewed as a way to With Business applicable laws, regulations and Flowserve policies Partners Are Based influence government officials, you may not use Flowserve when working with governments. on Integrity assets in connection with any political activity. You may and Trust • We maintain appropriate controls and procedures specific contribute your own time and resources, but must make to our government business activities. clear that you are not acting or speaking for Flowserve. INTEGRITY We Compete Fairly IN OUR 9 If you are contacted by a government representative in the Marketplace OUR RESPONSIBILITIES regarding an investigation, audit or request for information PEOPLE or documents, direct them to the Legal department for 9 Government procurement rules can be complicated, so We Prohibit assistance. you must be familiar with applicable rules and regulations Bribery and before pursuing such business. Supply Chain can assist Corruption you if you have questions. FREQUENTLY ASKED QUESTION We Follow Our 9 Never submit inaccurate or incomplete information in QUESTION: My friend is running for local political office Policies on Gifts, response to a government bid. and I would like to volunteer to help with her campaign. Travel and INTEGRITY Is this allowed? Entertainment 9 Do not solicit or accept confidential information about IN OUR a government’s selection process or a competitor’s ANSWER: Yes. You may use your own time and resources COMPANY We Comply proposal. If you receive such information, contact your to support political activity. Do not use Flowserve funds, With International regional I&C contact. property or equipment for personal political activities, and Trade Laws always make clear that your views and actions are your 9 Do not authorize, promise or provide anything of value, own, and not Flowserve’s. including gifts, meals or entertainment to a government We Deal Honestly employee unless you have obtained pre-approval and Fairly With Governments from I&C. INTEGRITY IN DEALING We Invest in Our Communities WITH OTHERS 29
TABLE OF We Invest CONTENTS in Our Communities OUR INTEGRITY COMMITMENT OUR RESPONSIBILITIES Through community impact programs like our Flowserve 9 Obtain approval through our Flowserve Cares program OUR Cares program, Flowserve proudly supports civic and before making any charitable donation or promise of VALUES charitable activities and encourages employee involvement in-kind support on behalf of Flowserve. and engagement in the communities where our employees 9 Refer questions about donations to your Flowserve Cares and customers live and work. regional program representative. Our Relationships With Business 9 Utilize the online application on Passport to submit OUR POLICIES Partners Are Based contributions, in-kind donation or volunteer requests. on Integrity • We support charities and good causes whose objectives and Trust align with our shared values through charitable donations, 9 Participation in group volunteer opportunities organized in-kind contributions and volunteer opportunities. INTEGRITY by Flowserve is encouraged and should be coordinated We Compete Fairly with your supervisor, taking into account your job IN OUR in the Marketplace • Local sites are encouraged to select organizations to responsibilities. PEOPLE support that maximize our impact and employee involvement in our core areas of support: At-risk Youth, We Prohibit FREQUENTLY ASKED QUESTION Bribery and STEM Programs and Education, Disaster Recovery and Corruption Community-related Activities. QUESTION: A local teacher asked if Flowserve would sponsor an event at an elementary school near our facility. • We encourage our employees to give back to their We Follow Our I know the company supports charities that support communities and charitable organizations of their Policies on Gifts, children. Can I say yes? choice by contributing their time, energy and resources. Travel and INTEGRITY Entertainment ANSWER: You should contact your Flowserve Cares IN OUR representative before making a commitment to determine COMPANY LEARN MORE We Comply if the request meets Flowserve’s contribution criteria. Global Philanthropy and Donations Policy With International Trade Laws We Deal Honestly and Fairly With Governments INTEGRITY IN DEALING We Invest in Our Communities WITH OTHERS 30TABLE OF We Invest CONTENTS in Our Communities OUR INTEGRITY COMMITMENT OUR RESPONSIBILITIES Through community impact programs like our Flowserve 9 Obtain approval through our Flowserve Cares program OUR Cares program, Flowserve proudly supports civic and before making any charitable donation or promise of VALUES charitable activities and encourages employee involvement in-kind support on behalf of Flowserve. and engagement in the communities where our employees 9 Refer questions about donations to your Flowserve Cares and customers live and work. regional program representative. Our Relationships With Business 9 Utilize the online application on Passport to submit OUR POLICIES Partners Are Based contributions, in-kind donation or volunteer requests. on Integrity • We support charities and good causes whose objectives and Trust align with our shared values through charitable donations, 9 Participation in group volunteer opportunities organized in-kind contributions and volunteer opportunities. INTEGRITY by Flowserve is encouraged and should be coordinated We Compete Fairly with your supervisor, taking into account your job IN OUR in the Marketplace • Local sites are encouraged to select organizations to responsibilities. PEOPLE support that maximize our impact and employee involvement in our core areas of support: At-risk Youth, We Prohibit FREQUENTLY ASKED QUESTION Bribery and STEM Programs and Education, Disaster Recovery and Corruption Community-related Activities. QUESTION: A local teacher asked if Flowserve would sponsor an event at an elementary school near our facility. • We encourage our employees to give back to their We Follow Our I know the company supports charities that support communities and charitable organizations of their Policies on Gifts, children. Can I say yes? choice by contributing their time, energy and resources. Travel and INTEGRITY Entertainment ANSWER: You should contact your Flowserve Cares IN OUR representative before making a commitment to determine COMPANY LEARN MORE We Comply if the request meets Flowserve’s contribution criteria. Global Philanthropy and Donations Policy With International Trade Laws We Deal Honestly and Fairly With Governments INTEGRITY IN DEALING We Invest in Our Communities WITH OTHERS 30
Conduct Flowserve Code of International Flowserve Corporation 5215 North O’Connor Blvd. Suite 2300 Irving, Texas 75039-5421 USA Telephone: +1 (972) 443-6500 ©2019 Flowserve Corporation. All rights reserved. This document contains registered and unregistered trademarks of Flowserve Corporation. Other company, product, or service names may be trademarks or service FLS-COBCENINT August 2019 marks of their respective companies.Conduct Flowserve Code of International Flowserve Corporation 5215 North O’Connor Blvd. Suite 2300 Irving, Texas 75039-5421 USA Telephone: +1 (972) 443-6500 ©2019 Flowserve Corporation. All rights reserved. This document contains registered and unregistered trademarks of Flowserve Corporation. Other company, product, or service names may be trademarks or service FLS-COBCENINT August 2019 marks of their respective companies.