Corporate Social Responsibility Policy

The Linkswalker Brand is a proud line of products owned and sold by our parent company, MPDirect, Inc.

MPDirect, Inc. seeks to be a good corporate citizen in all aspects of its operations and activities. To this end we have brought together a series of operating principles under the broad heading of Corporate Social Responsibility (CSR) to serve as a guide to employees in all aspects of their work for the company. The principles cover all areas of the company operations and have been developed with reference to the relevant codes of corporate governance and best practice, including the Fair Labor Association Workplace Code of Conduct, the Federal Human Rights Commission statements and guidelines as well as those of the state of Florida Commission on Human Rights. This policy reflects guidelines set in our Policy Handbook. The policy can be divided into five main areas:

1. Ethical Business Conduct
2. Policies Specific to Employees
3. Fair Employment Practices
4. Workplace Health and Safety
5. Environmental Policy

Ethical Business Conduct

A. Our Principles

The success and reputation of MPDirect is built upon the principles of fair dealing and ethical conduct of our employees. Our reputation for integrity and excellence requires careful observance of the spirit and letter of all applicable laws and regulations, as well as a scrupulous regard for the highest standards of conduct and personal integrity.

Our policy is to conduct our business in a manner which ensures:

Fair treatment of all employees and clients
Transparency of our business policies and practices
High standards in all matters relating to health, safety and the environment
Ethical business practices throughout our operations

We recognize that the involvement of our employees is key to the future success of the business and we have, for all of our years of operation, adopted a policy of keeping employees fully informed on all matters affecting them. We have consistently operated a compensation philosophy that recognizes individual performance. We are also committed to best practice in employment matters, recognizing the role this plays in attracting and retaining staff.

Customers are among our organization’s most valuable assets and every employee is expected to adhere to our core values and to uphold them in the workplace. Employees are expected to exercise the highest ethical judgment and comply with policies applicable to their duties.

Policies Specific to Employees

A. Compliance with Codes and Regulations

Our reputation for integrity and excellence requires careful observance of the spirit and letter of all applicable laws and regulations, as well as a scrupulous regard for the highest standards of conduct and personal integrity. Employees are expected to comply with all codes and regulations related to the business expectations as stated in the Policy Handbook as well as with regulations specific to their duties.

B. Outside Employment

Employees may hold outside jobs as long as they inform management of the nature of the outside job and meet the performance standards of their position with MPDirect. All employees will be evaluated by the same performance standards and will be subject to MPDirect’s scheduling requirements.

If MPDirect determines that an employee’s outside work interferes with performance or the ability to meet the requirements of MPDirect as modified from time to time, the employee may be asked to terminate the outside employment if he/she wishes to remain employed with MPDirect.

Outside employment that constitutes a conflict of interest is prohibited.

C. Dealing with Customers and External Parties

MPDirect is committed to the provision of accurate information and fairness in all its dealings with customers and any other external party having direct business with MPDirect.

D. Confidentiality

All employees of MPDirect are required to maintain strict confidentiality of records, correspondence, customer information, trade secrets, or other proprietary materials. Employees who breach confidentiality will be subject to disciplinary action, up to and including termination of employment and possible legal action. All employees are required to sign a Confidentiality/Non-Disclosure Agreement.

E. Data Protection

MPDirect is committed to compliance with all state and federal laws regarding internet usage. All employees have a responsibility to use MPDirect’s computer resources and the Internet in a professional, lawful and ethical manner, consistent with business purposes.

F. Use of Company Information/Assets

Employees shall use the company’s computer systems, internet and intranet, and email systems for business use. All computers remain under the control, custody and supervision of MPDirect. Employees have no expectation of privacy in their use of MPDirect computers and MPDirect reserves the right to monitor all computers and Internet activity and any files created by employees. Employees who violate policies governing this use are subject to disciplinary action, up to and including termination of employment. In addition, they may be subject to civil or criminal liability.

G. Disciplinary Procedure

To ensure effective operation of MPDirect and provide the best possible work environment, MPDirect provides a Policy Handbook outlining policies and work rules to protect the interests and safety of all employees and the company. While discipline will generally be progressive, MPDirect retains sole discretion to deviate from progressive discipline based on the nature and circumstances of an employee’s behavior and misconduct. Some types of employee misconduct are so serious that they may result in immediate termination of employment.

Policies Specific to MPDirect

A. Political Contributions

It is MPDirect’s policy not to make contributions for political purposes. However, employees are not hindered from being politically active in their own time using their own resources.

Fair Employment Practices

In developing employment policy, MPDirect has been guided by federal and state guidelines and is the responsibility of Carole Byers, PHR Human Resources Manager and is overseen by Carole Byers, Corporate HR. The policies are periodically reviewed and updated when appropriate.

A. Equal Opportunities Employer

MPDirect will not discriminate against any employee or applicant because of gender, race, color, religion, age, national origin, veteran status, sexual orientation, physical or mental disability or any other discriminatory characteristic defined by law. The company will also take all reasonably practical steps to ensure that disabled applicants or workers are able to participate in its business activities on an equal basis with people who are not disabled.

All employees are responsible for complying with this policy and for ensuring that the standards of behavior required by the company are observed by:

Treating others on their merits and disassociating themselves from any form of direct or indirect discrimination, victimization or harassment;
Bringing to the attention of their manager any suspected working practice in breach of this policy;
Working together to promote a harmonious working environment free from discrimination, harassment and bullying.

MPDirect regards direct or indirect discrimination, victimization, and harassment as a serious matter. Employees who fail to comply with this policy will be subject to the company’s disciplinary procedure. All breaches of this policy will be regarded as serious disciplinary matters and will, if there has been victimization, intentional discrimination or deliberate harassment, be regarded as potential gross misconduct leading to possible termination.

MPDirect recognizes that misunderstandings can arise where people of a different sex, interests and cultures work together. We strive to maintain a work environment that encourages productivity, teamwork, respect, open and honest communication and participation by all employees. We believe that most workplace issues can be resolved by direct communication among the people involved.

Employees are encouraged to let their Manager/Supervisor know of any operational concerns the employee cannot resolve him/herself so that they can be addressed in an appropriate manner. If an employee is uncomfortable speaking directly to his/her Manager/Supervisor, or if the issue is personal or confidential in nature, he/she may contact Carole Byers, PHR, Human Resources Manager for counsel or advice.

The Human Resources Manager, Carole Byers, carries out periodic reviews of the company’s equal opportunity policy and monitors the effects and the application of this policy across the company.

Environmental Policy

A. MPDirect supports environmental awareness by encouraging recycling and waste management in its business practices and operating procedures. This support includes a commitment to the purchase, use, and disposal of products and materials in a manner that will best utilize natural resources and minimize any negative impact on the Earth’s environment.

B. Communicating the Policy

All employees receive and acknowledge receipt of the Employee Handbook that describes our policy. In addition, employees are encouraged to suggest other ways that the company can minimize any negative impact on the environment.

C. Environmental Policy

MPDirect aims to:

Minimize the environmental impacts of our existing operations and ensure that the environmental impacts of new operations are fully assessed and minimized prior to their introduction
Reduce consumption of materials in all operations, where practicable, to re-use rather than dispose of materials where possible, and promote recycling and use recycled materials
Seek to improve the energy efficiency of buildings and to manage energy wisely in all operations
Reduce, wherever practicable, the level of harmful emissions from our workplace
Introduce measures that aim to minimize waste
Dispose of waste and effluents in a responsible manner
Promote the ownership and control of environmental issues at management level
Provide the necessary training and support in order to ensure that staff fulfill their requirements
Work with our suppliers to minimize the impact of their operations on the environment through a quality purchasing policy
Monitor progress and evaluate performance regularly.

Energy

MPDirect aims to reduce the consumption of energy and will also strive to ensure that that energy is used as efficiently as possible. Energy is used for office lighting, heating and cooling systems and for the operation of office equipment and any appliances.

a) MPDirect will encourage the use of low energy lighting and where practicable, the use of segmented areas which will allow lights to be switched off when not required.

b) To make more efficient use of heating systems we will ensure that the temperature is set for a comfortable working environment and not more than 70 degrees on days that are colder than 60 degrees.

c) Central air conditioning will be used to keep the temperature at not less than 70 degrees.

d) We will aim to ensure that the refrigerator and microwave are energy efficient and that they release the minimum amount of waste product.

Water

MPDirect seeks to reduce the amount of water used.

Paper

MPDirect seeks to reduce the amount of paper used and to increase the amount of paper that is recycled. Recycle bins are located in offices and throughout the building. We will strive to reduce the amount of paper purchased and will re-purpose used paper as we can. Management is encouraged to make use of electronic reporting and communication with OLCC and email as well as scanning documents into electronic records for storage.

Waste

General office waste is collected and removed each day by cleaners and taken to a compactor for removal by a waste contractor, or is collected weekly by the local authorities.

Toner cartridges are collected after use and mailed to recycler.

Redundant computers and IT equipment is recycled or donated to a local charity organization.

Hazardous Materials

MPDirect accepts responsibility for monitoring hazardous waste materials including paint and cleaning products that are disposed of per MSDS Relevance.

Transportation

MPDirect acknowledges that transportation is a major source of CO2 emissions. We encourage employees to car pool or use public transportation wherever possible.

Conference calls and video-conferencing is used wherever possible to reduce the need for extensive travel.

Supply Chain Management

MPDirect encourages sustainability and environmentally sound sourcing and production methods in our suppliers’ manufacturing and delivery processes. To this end we will inform our suppliers of our Environmental Policy and inform them that we favor companies with established environmental policies and practices in allocating contracts. We also aim to use local suppliers and local goods and services, where practicable.

Community Involvement

MPDirect has been fostering good relations within the local community by implementing food drives, clothing and toy drives, donations and gifts to help various charitable organizations. We also work with the local high school shadow program. We are listed with the Better Business Bureau and support its initiatives to foster good business practices for our customers.

B. Human Rights

MPDirect enforces all federal and state regulations in support of human rights. We endorse the Fair Labor Association Workplace Code of Conduct for our company and have committed to encouraging and monitoring FLA participation by facilities that we source product from. We also believe in the Universal Declaration of Human Rights in all of its spheres of influence.

C. Forced/Child Labor

There shall not be any use of forced labor, whether in the form of prison labor, indentured labor, bonded labor or otherwise. No person shall be employed at an age younger than 15 (or 14 where the law of the country of manufacture allows) or younger than the age for completing compulsory education in the country of manufacture where such age is higher than 15.

D. Discrimination, Sexual Harassment and Other Forms of Harassment and/or Bullying

MPDirect expects all employees to conduct themselves with dignity and with respect for fellow employees, customers, vendors, and others. Employees shall not verbally, physically, or psychologically harass another individual based on their sex, race, color, religion, age, national origin, veteran status, sexual orientation or physical or mental disability. Harassment is disruptive, interferes with MPDirect’s business, and creates an intimidating, hostile, or offensive work environment. MPDirect provides periodic harassment training for all employees. Any form of harassment will not be tolerated by MPDirect.

E. Employee Benefits

MPDirect recognizes the value of its employees and has identified and assessed their long term retention as key to the short and long term value of the company. To this end, the company aims to attract and retain skilled employees and enhance the life/work balance of each individual. The company offers full time employees (30 + hours week) a range of benefits including, Medical Insurance, Dental Insurance, Life Insurance, Supplemental Cancer Insurance, Short Term/Long Term Disability Insurance, Accident Insurance, Critical Illness Insurance, Hospital Confinement Insurance, Paid Sick/Personal, Paid Vacation and Paid Holidays. Also available to employees are opportunities for personal development and training programs designed to enhance the employee’s skill base. All programs are related directly to the specific role of the individual within the company and are linked to performance expectations.

F. Grievances

MPDirect has adopted an Employee Complaint Procedure to provide employees who consider that they have a problem or complaint about their work to be able to seek resolution fairly and speedily.

Workplace Health & Safety

MPDirect has established a Safety Committee and workplace safety program to provide a safe and healthy environment for employees and guests. The success of the safety program depends upon the commitment of every employee. Periodic safety training is provided for employees including Forklift certifications for warehouse personnel, (Florida Industrial Training, Inc.) and OSHA training for compliance.

Each employee is required to observe safety rules and procedures, and to exercise caution in work activities. Employees who violate safety rules and procedures, who cause hazardous and dangerous situations, or who fail to report unsafe conditions, will be subject to disciplinary action, up to and including termination of employment.

Employees are a great source of safety improvements and suggestions. Employees are encouraged to use the suggestion box or discuss suggestions with the Manager/Supervisor or members of the Safety Committee.

MPDirect abides by all safety regulations including inspections by NFPA (National Fire Protection Association – MSDS compliance), Florida Department of Agriculture and Consumer Services Division of Food Safety (annual food permit), OSHA (Occupational Safety and Health Act) and UCC (Uniform Commercial Code) requirements.

B. Health and Safety Records

All MPDirect health and safety events are reported and investigated to determine if preventative action is required to prevent further accidents.