Confidential Reporting Alleged Code Violations
This Confidential Reporting of Potential or Actual Code Violations Procedure (this “Reporting Procedure”) is a component of the Code of Business Conduct and Ethics Procedures (the “Code”).
This Reporting Procedure sets forth specific policies governing the disclosure and reporting of actual or potential violations of the Code for Alamo Group Inc., and our subsidiaries and affiliates (the “Company” or “we”), directors, officers and employees (collectively, “covered parties” and each a “covered party”).
I. Policy
You may report actual or potential violations of the Code or seek guidance with respect to actual or potential violations of the Code or the law to management through (i) your supervisor through our "open door" policy under which you may arrange to meet with management personnel, (ii) our Compliance Committee, (iii) our Legal Department, or (iv) if you wish to remain anonymous, you may make a report or seek guidance by calling or emailing MySafeWorkplace® as noted below. Any report of potential or actual violations of the Code made through MySafeWorkplace® will be delivered to the Chairman of the Compliance Committee and the Chairman of the Audit Committee of the Board of Directors.
Investigations of alleged violations of this Policy, disciplinary measures for violations of this Policy and any agreement by the Company to deviate from this Policy shall be governed by applicable law and the Code.
MySafeWorkplace® is an independent third-party service that is not affiliated with the Company, is answered by trained professionals and is available every day, 24 hours a day. If you use MySafeWorkplace®:
-You may refrain from identifying yourself (although, in the absence of such identification, we may have insufficient information to investigate the allegations);
-If your identity is made available, no retribution will be imposed on you for making the report unless you are one of the violators or intentionally provide false information; and
-Your confidentiality will be maintained unless it is made available and disclosure is required or advisable in connection with any governmental investigation or report or our legal defense of the matter.
MySafeWorkplace® is not intended to be used for personal grievances. All matters that do not appear to constitute violations of the Code will be referred to the appropriate department. For example, reports concerning personnel grievances will be sent to the Human Resources Department.
The mailing address, phone numbers and email address for reporting Code violations are:
To MySafeWorkplace®:
MySafeWorkplace® Staff
15000 West Sixth Avenue, Suite 150
Golden, CO 80401
800-461-9330
www.MySafeWorkplace.com
With respect to violations regarding accounting, finance, internal accounting controls and audit matters (collectively, “Financial Matters”), or involving Chief Executive Officers, Chief Financial Officers, Principal Accounting Officer, Controllers and others performing similar functions:
Audit Committee Chairman
Alamo Group Inc.
1627 E. Walnut St.
Seguin, TX 78155
Audit Committee Contact:
Sharon Rice 830-372-9615
srice@alamo-group.com
With respect to non-Financial Matters:
Compliance Committee Chairman
Alamo Group Inc.
1627 E. Walnut St.
Seguin, TX 78155
830-372-9600
dduncan@alamo-group.com
Compliance Committee:
Donald Duncan, Chairman
VP & General Counsel 830-372-9600
dduncan@alamo-group.com
Bob George
VP 830-372-9621
bgeorge@alamo-group.com
Dan Malone
EVP & CFO 830-372-9581
dmalone@alamo-group.com
Richard Wehrle
VP & Controller 830-372-9620
rwehrle@alamo-group.com
Gabriela Garcia
VP of HR 830-372-9559
ggarcia@alamo-group.com
Jeffrey Leonard
EVP Industrial Division
jleonard@alamo-group.com
Richard Pummell
EVP Agricultural Division 830-372-9580
830-372-9601
330-339-8394
rpummell@alamo-group.com
Geoff Davies
Managing Director, Alamo Europe 011-44 1789 773383 ext. 266
gdavies@alamoeur.com
Rev 2/14/2013
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