LUXON HOLDINGS, INC.
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| A. | Compliance with all Laws that Affect Business and Financial Conduct. It is the policy of Luxon Holdings, Inc. to comply with all laws affecting our business, including (but not limited to) laws governing the manner in which we record, describe and account for the financial results of our business operations, as well as all laws governing other aspects of our business, including but not limited to competition, health, safety, non-discrimination and the environment. | ||||||||||||||||||||||||||||||||
| B. | General Complaint Process for Violations or Suspected Violations of Law. We recognize that an employee or other person may become aware of something involving possible financial or business misconduct that he or she believes to be important enough to bring directly to management’s attention. Depending upon the issue, the complaint may be directed to a supervisor, manager or head of a department at the plant level; general manager of a plant or facility; the Chief Executive Officer or the Chief Financial Officer of the Company at the Company’s corporate offices; or the Audit Committee of the Company’s Board of Directors.
Complaints involving non-financial matters such as workplace conditions, health and safety issues, claims of harassment or discrimination, work assignment issues or promotion or operational issues should be directed to the plant level supervisor, manager or department with authority to consider and resolve the matter, or, if the matter remains unresolved, to the general manager of the plant or facility. If a matter continues to be unresolved, the complaint should be directed to the Company’s Chief Executive Officer at the Company’s corporate offices in City of Industry, California. Complaints involving accounting, internal accounting controls, or auditing matters (”Accounting Matters”) should be directed to the Audit Committee of the Board of Directors or the Company’s Chief Executive Officer with a copy to the Audit Committee of the Board of Directors. Such Accounting Matters include, without limitation, the following: fraud or deliberate error in the preparation, evaluation, review or audit of any financial statement of the Company; fraud or deliberate error in the recording and maintaining of financial records of the Company; deficiencies in or non-compliance with the Company’s internal accounting policies; misrepresentation or false statements to or by a senior officer or accountant regarding a matter contained in the financial records, financial reports or audit reports of the Company; deviation from full and fair reporting of the Company’s financial condition; or violation of the Company’s Code of Ethics for Principal Executive Officers and Senior Financial Officers. Complaints other than those submitted anonymously under the procedures described in Section C may be submitted in writing. If an employee would like to discuss any matter, the employee should indicate this in the submission and include a telephone number of another place of contact at which he or she might be contacted if it is deemed appropriate. Complaints involving possible violations of the Company’s general Code of Ethics may be submitted directly to the Company’s Chief Executive Officer or, if the complaining party wishes to avail himself or herself of the confidential and anonymous complaint process described in Section C, may lodge such a complaint with the Audit Committee as outlined therein. Contact information for the Company’s Chief Executive Officer, Chief Financial Officer, and the Company’s Audit Committee is set forth in Section C. |
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| C. | Confidential (Anonymous) Complaint Process. We have established a process by which confidential complaints involving any Accounting Matters or matters involving a possible violation of the Company’s general Code of Ethics may be raised anonymously. Complaints submitted through this confidential process will be presented directly to the Audit Committee of the Company’s Board of Directors under a process that is designed to ensure maximum practical confidentiality. An employee may utilize this confidential process either to raise new complaints or to lodge a previously filed complaint if he or she feels that a complaint previously raised on a non-confidential basis has not been appropriately handled or resolved.
Our process for the confidential, anonymous submission by employees of concerns regarding Accounting Matters or Code of Ethics violations operates as follows: |
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| D. | Non-Discrimination and Non-Retaliation Regarding Complaints. Luxon Holdings, Inc. has a policy to protect our employees and others against unlawful discrimination or retaliation by the Company as a result of their lawful reporting of information regarding, or their participation in investigations involving possible violations of any Accounting Matter, by us, our employees, our agents or our product or service providers of any possible violations of our general Code of Ethics, or of any other possible business or financial misconduct, or of any federal, state, local or foreign law, including (but not limited to) possible fraud. Specifically, this policy prohibits any employee, agent or other person from being subjected to disciplinary or retaliatory action by the Company or any of its employees or agents as a result of that person in good faith: | ||||||||||||||||||||||||||||||||
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| regardless of whether such information or assistance is provided to or the investigation is being conducted by a federal or state regulatory agency, a member of the executive or legislative branches of government, or a Company employee or agent with authority to conduct such investigation.
However, employees or others who file reports or provide evidence which they know to be false, or without a reasonable belief in the truth and accuracy of such information, will not be protected by the above policy and may be subject to disciplinary action, including termination of their employment or loss of some other advantage. If any employee or other person believes that he or she has been subjected to any action that violates this Policy, that person may file a complaint directly with the Company’s Audit Committee. If it is determined that an employee or other person has experienced any improper employment or retaliatory action in violation of this Policy, such person will be entitled to appropriate corrective action. |
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