Rayonier is committed to conducting all operations consistent with our core values and the highest ethical considerations. We are guided by our Standard of Ethics and Code of Corporate Conduct (Code of Conduct) that applies to all directors, officers and employees of the company, and our Supplier Code of Conduct that applies to contractors (i.e. vendors, consultants, brokers, etc). All employees are trained on our ethics program when they join the company, receive regular training on our Code of Conduct periodically thereafter, and must certify annual compliance with our Code of Conduct.
Managerial responsibility for our compliance, anti-corruption and business ethics programs resides with our Chief Compliance Officer, who is the company’s Director, Audit & Compliance, in consultation with our General Counsel. The Board provides additional and regular oversight through the Audit Committee. Annually, we undertake a compliance and ethical risk assessment to identify key risks, which is reviewed by our Board.
Our Code of Conduct and supplementary Foreign Corrupt Practices Act (FCPA) Policy set forth our policies and procedures for compliance with anti-corruption laws. We maintain clear operating guidelines to ensure proper record keeping and compliance, including maintaining a list of state owned enterprises (SOEs), customer due diligence, contract review and approval procedures. All employees receive training on bribery and corruption at least every three years, with risk-exposed employees, such as those in sales, finance, and other customer-facing roles, receiving training annually. All relevant employees must certify annually that they comply with our FCPA policy.
To help ensure compliance, we maintain a whistleblower program, which offers anonymous, 24/7 reporting of information regarding any ethical concern. Information on the program and contact details are communicated and provided through our Code of Conduct, company intranet and posters at our offices, among other places. All reported incidents are logged and tracked via a web-based system, and investigated until resolved.
Company funds may not be used for political contributions without the approval of the company’s VP of Public Affairs. Furthermore, these contributions are reviewed by a third-party organization to ensure compliance.