2018 CORPORATE RESPONSIBILITY REPORT
prosperity

Compliance and Ethical Behavior

102-16
Values, principles, standards, and norms of behavior

GRI
102-16

Ethics unite Covia in our vision for sustainability. Our commitment to Do Good. Do Well. Act Responsibly. forms the foundation of our compliance and ethics program. We empower and expect our employees to make ethical decisions throughout their work, which helps us Deliver on Promise to meet or exceed local, state, and federal regulations.

Governance

Covia’s commitment to ethics begins with our executive management team. They lead by demonstrating principle-centered leadership and inspire adherence to all applicable rules and regulations. We strive to do things right and to do the right things. Our executive management team advances our compliance and ethics program, which includes comprehensive policies, procedures and controls, training and communication, observation and analysis, and evaluation and improvement. Our legal department develops and administers the compliance and ethics program, and in conjunction with other functional areas, assists management with compliance, risk management, and internal control evaluations.

Our Corporate Code of Business Conduct and Ethics is the foundation of our compliance and ethics program. The Code drives our business conduct so that we Do Good. Do Well. Act Responsibly. in all decisions. The Code covers topics such as:

  • Avoiding potential conflicts of interest
  • Ensuring fair business and trade practices
  • Protecting confidential information
  • Properly using Company assets
  • Guarding against workplace sexual harassment

We expect all employees to take ownership of compliance and ethics, and perform all job-related tasks with honesty and integrity. Employees are required to show the utmost respect for Covia, their peers, the environment, and the communities in which we operate. Further, our governance policies clearly define what we expect of our people and our business partners. They set forth written standards for behavior, including:

  • Anti-Corruption Policy
  • Corporate Code of Business Conduct and Ethics
  • Corporate Governance Guidelines
  • Delegation of Authority
  • Financial Code of Ethics
  • Insider Trading Policy
  • Policy for Employee Concern Procedures for Accounting and Compliance Matters
  • Public Disclosure Policy
  • Related Party Transactions Policy
  • Social Media Policy

Covia strictly prohibits and adopts a zero-tolerance policy for all forms of harassment based upon a person’s race, color, gender, religion, age, national origin, citizenship status, military service or reserve or veteran status, sexual orientation, gender identity, gender expression, or disability.

Covia provides access to a confidential, anonymous hotline for reporting questionable accounting and compliance matters through http://www.openboard.info/CVIA/ or 855-216-2954. The whistleblower hotline can be reached 24 hours a day, seven days a week. The hotline accepts messages in two ways: voicemail and web interface, and an employee only need to leave one message as both methods deliver your message anonymously and confidentially. Further, the hotline is available to all stakeholders, or others, who might have concerns regarding Covia’s business practices.

As Covia strengthens our foundation for future growth, we hold ourselves accountable for maintaining high ethical standards. We continuously make enhancements to our corporate compliance program. For example, we recently approved and implemented an updated Delegation of Authority policy shortly after the combination. This policy establishes the appropriate internal control procedures for reviewing and obtaining the necessary approval of transactions, agreements, and commitments that bind Covia and the decisions that expose our Company to risk. The primary objectives of this Delegation of Authority are to provide the appropriate level of responsibility and accountability, and establish review levels and dollar amount thresholds that make sense given Covia’s current organizational structure and business processes.

Performance

In 2018, we updated our Code of Business Conduct and our Anti-Corruption policies. We have assembled a cross-functional internal team to assess all policies and procedures from our legacy companies, with a plan to complete this review and updates in 2019.

Opportunity

In 2019, we plan to continue providing ethics and compliance training to employees and will look for ways to expand this training for employees without regular access to technology. This reflects Covia’s continued commitment to Do Good. Do Well. Act Responsibly.