Give Us A Call:  +1-281-433-2337  

​​​​​​​Palco Materials Company

Optimizing the Energy Industry

Palco Materials Company General Business Principles


Current As Of 08/25/17

As a manufacturer’s representative company operating in a challenging world, Palco Materials Company upholds best practices regarding ethical business and corporate behavior. These ethical business and corporate behaviors support anti-corruption, anti-bribery, honest and fair business practices as well as fair and equitable treatment of all employees.  See Palco Materials Company’s Code of Ethics.

Our Ethics Hotline allows employees and stakeholders to raise concerns and report instances of potential non-compliance with our values and principles.  To report suspected corrupt business practices, oil field theft or poaching, possibly involving Palco Materials Company business interests, delivery, diversion or theft of materials or poaching, contact the Palco Materials Company Ethics Hotline at:  +01-409-939-6268.

Palco Materials Company has aligned itself from the very beginning with Local, State and Federal Law Enforcement and Regulators to combat corrupt business practices, as well as to prevent oil field theft, not engage business organizations involved with corrupt trade business practices, and to protect the environment by supporting “Operation Game Thief” operations. 

Suspected corrupt business practices may also be reported to:

Office of the Attorney General, Ken Paxton
Agency Numbers
Main Agency Switchboard: (512) 463-2100
Consumer Protection Hotline: (800) 621-0508
Mailing AddressOffice of the Attorney General
PO Box 12548
Austin, TX 78711-2548











Suspected poaching activities may also be reported to: 
Operation Game Thief
Game Warden Headquarters, Phone No. (512) 389-4845
Texas Parks and Wildlife Department    
4200 Smith School Road
Austin TX  78744-3218
Criminal Investigation Division, Austin HQ, Phone No. (512) 389-8822
If a violation is currently in progress, please call 800-792-4263 immediately.

These General Business Principles to be revised on 08/26/18.



Palco Materials Company Diversity and Inclusion Policy

Current As Of 08/25/17


Palco Materials Company is an Equal Opportunity Employer.


Building on our core values of “Heroic, Steadfastness and Compassion”, we aspire to sustain a diverse and inclusive culture where everyone feels respected and valued, from our employees to our customers and partners.  All employees are valued regardless of age, race, gender, religious preference, ethnicity, nationality, etc.: our mantra is “…every employee is important!”

Although the Palco Materials Company workforce is small, every effort is made to achieve the right balance of work and personal life.  Every effort is made to hire the right employees for the workforce and to avoid reductions in workforce due to changing economics.  We are committed to attracting, developing and retaining a diverse and talented workforce.

This Diversity and Inclusion Policy to be revised on 08/26/18.



Palco Materials Company Policy on Gifts and Hospitality

Current As Of 12/26/17

It is important to do the right thing – and to be seen to do it.  For this reason, we discourage our staff from accepting gifts and hospitality (G&H) from business partners, or offering G&H to them, especially those you would not be comfortable telling your manager, colleagues, family or the public that you had offered or accepted. In particular, you should never allow G&H, either offered or received, to influence business decisions or give other people a reason to suspect there might be an influence. We encourage you to make Palco Materials Company’s policy on G&H known to our agents and business partners, including governments and Government Officials.

YOUR RESPONSIBILITIES - You must not, either directly or indirectly, offer, give, seek or accept:

– illegal or inappropriate G&H, cash or cash equivalents (including per diems unless contractually agreed), vehicles, personal services, or loans in connection with Palco

   Materials Company business; or

– G&H where the business partner is absent, or during periods when important business decisions are being made; or

– G&H that exceed prescribed value limits, unless line manager and other required approvals have been obtained.

Reasonable value limits regarding gifts and hospitality are $20.00 USD for cash or cash equivalents per customer. 

This Gifts and Hospitality Policy to be revised on 12/27/18.



Palco Materials Company Code of Ethics

Current As Of 08/25/17

Ethics is decision making.

Always make the right decision, treat fellow employees, Clients and Vendors fairly and ethically.

If the right decision is not evident, elevate the issue up through line management for guidance or counsel.  Once advised, document and implement the right decision and advise management thereof.

In all Internal and external business activities, act with Honesty, Integrity, Respect and Fairness, and expect the same in relationships with others while maintaining a work and business climate fostering such standards; and avoid conflicts of interest.

Abstain from making any decision about an issue at hand in which a conflict of interest arises or could arise and in such event, elevate through line management by disclosing in writing (via email) the relevant facts and explain the circumstances that create or could create the conflict.  Employees will be commended for being proactive and will never be disciplined for protecting the interests of the Company, their co-workers or themselves and our Clients. 

Avoid having any financial interest in works or contracts awarded by Palco Materials Company or a company associated with Palco Materials Company, or in supplies affected or services rendered to or by such a company and where this is unavoidable or where immediate family members have such a financial interest, such interest shall be disclosed in writing in the same manner as set out above. 

Not seek or accept from third parties to their own advantage any favor in whatsoever form or howsoever described in connection with the business of any Palco Materials Company or their duties (except for the acceptance of such things as gifts of nominal value and working lunches, dinners and entertainment of reasonable value, frequency and duration, appropriate under the circumstances, and subject always to the standards above).

Unless declared to management in writing, not hold positions or jobs or engage in outside businesses or other interests that might adversely impact the performance of duties owed to Palco Materials Company or the interests of the same.  Employees are encouraged to discuss potential business opportunities they may see or develop with management.  Palco Materials Company management is committed to working with employees so that they may develop to their fullest, thus increasing the value of the employee and the Company.

Avoid any relationship with a contractor or supplier that could compromise the ability to transact business on a professional, impartial and competitive basis or influence decisions to be made by Palco Materials Company or a Vendor or Client Company which Palco Materials Company may have a relationship with.

Consistent with the scope of their job responsibilities, ensure full, fair, accurate, timely, and understandable disclosure in regulatory filings and in other public communications made by Palco Materials Company.

This Code of Ethics to be revised on 08/26/17.



Palco Materials Company Code of Conduct

 

Current As Of 08/25/17

This Code applies to every employee in every Palco Services International LLC company - no exceptions.  Contract staff working for a Palco Services International LLC company must also follow the Code.  Contractors and consultants who are agents of, or working on behalf of, or in the name of a Palco Services International LLC company (through outsourcing of services, processes or any business activity), are required to act consistently with the Code when acting on our behalf.

  • Understand the risks in your role and how to manage them.
  • Seek advice when things are not clear.
  • Promptly complete the health, safety, environmental, ethics and compliance training assigned to you.
  • Make sure that any third party contractors, agents or consultants you work with are aware that we are bound by our Code and that they should act accordingly.
  • Speak up. It is your duty to report any suspected violations of the Code.


We live up to our Core Values of “Heroic, Steadfast and Compassionate” in our relationships with all people.

These Core Values and Business Principles promote trust, openness, teamwork and professionalism, as well as pride in what we do and how we conduct business.

All Palco Materials Company employees, from the President/CEO through the line management, are required to apply the General Business Principles in line with our Core Values. It provides practical advice on how to comply with laws and regulations and how to relate to customers, communities and colleagues.

Legal and regulatory requirements have never been more complex or demanding. The Palco Materials Company Code of Conduct clarifies the standards we expect our employees to follow and the behaviors we expect them to adopt.  This is our “Corporate Culture”.

The Palco Materials Company Code of Conduct covers such areas as: individual and manager responsibilities; behaviors, people and culture; information and communication; and third party and international interactions.


Palco Materials Company insists on honesty, integrity and fairness in all aspects of our business and expect the same in our relationships with all those with whom we do business. The direct or indirect offer, payment, soliciting or acceptance of bribes in any form is unacceptable. Facilitation payments are also bribes and must not be made. Employees must avoid conflicts of interest between their private activities and their part in the conduct of company business. Employees must also declare to their employing company potential conflicts of interest. All business transactions on behalf of a Palco Materials Company must be reflected accurately and fairly in the accounts of the company in accordance with established procedures and are subject to audit and disclosure.

Palco Materials Company (PMC) do not make payments to political parties, organizations or their representatives.  PMC does not take part in party politics. However, when dealing with governments, PMC has the right and the responsibility to make our position known on any matters, which affect us, our employees, our customers, our shareholders or local communities in a manner, which is in accordance with our values and the Business Principles.

If you know or suspect someone is violating the Code, you have a duty to report it: Contact the Palco Materials Company Ethics Hotline at +1-409-939-6268.

Palco Services International LLC will not tolerate any form of retaliation directed against employee who raises a concern in good faith about a possible violation of the Code. In fact, any act or threat of retaliation against an employee will be treated as a serious violation of our Code and may lead to dismissal.

Our aim is “Safety First – Safety Last” in all our business activities!  We are committed to the goal of doing no harm to people and protecting the environment, while providing materials and resources, products and services in a way that is consistent with these objectives in order to optimize the Energy Industry.

You must follow the three Golden Rules:
(i)   Comply with the law, standards and procedures
(ii)  Intervene in unsafe or non-compliant situations
(iii) Respect our neighbors.


  • You must ensure that your work complies with the HSE Commitment and Policy in our Safety Manual.
  • You must follow the 12 Life-Saving Rules.
  • You must report and act on a Health, Safety and Environmental or Security incident, potential incident or near-miss as soon as you become aware of it.


HARASSMENT OF EMPLOYEES

Employee harassment is not tolerated in the Palco Services International LLC family of companies.

  • You must treat others with respect at all times.
  • You must not physically or verbally intimidate or humiliate others.
  • Lying is not tolerated.
  • You must not make inappropriate jokes or comments.
  • You must not display offensive or disrespectful material.
  • Challenge someone if you find their behavior hostile, intimidating, humiliating or disrespectful.
  • You may always contact your line manager, the Palco Materials Company Ethics & Compliance Office, Human Resources, Palco Materials Company Hotline.


THE 12 LIFE SAVING RULES

  1. Work with a valid Work Permit when or where required.
  2. Conduct Gas Tests when required.
  3. Verify isolation before work begins and use the specified life protecting equipment.
  4. Obtain authorization before entering a confined space.
  5. Obtain authorization before overriding or disabling safety critical equipment.
  6. Protect Yourself against a fall when working at height.
  7. Do not walk under a suspended load.
  8. Do not smoke outside of designated smoking areas.
  9. No alcohol or drugs while working or driving.
  10. While driving, do not use your phone and do not exceed speed limits.
  11. Wear your seat belt.
  12. Follow prescribed Journey Management Plan.


 
The 12 Life Saving Rules Explained

1.     Work with a valid Work Permit when required.

This rule is associated with the OSHA Work Authorization Permits and the Permit to Work system. It doesn’t apply to permits obtained through oversight agencies, such as encroachment permits, drilling permits, grading permits, building permits, etc. Those permits need to be obtained where required, and not having those permits can result in fines imposed by the oversight agencies, but this Life Saving Rule is specific to OSHA Work Authorization Permits and the Permit to Work System.  A Work Permit describes what you must do to stay safe.

You should:
·        Understand the Work Permit and follow it.
·        Confirm that the Work permit is valid.
·        Confirm with the Supervisor or the Person in Charge of the work that it is safe to start work.

If you are the Supervisor or the Person in Charge of the work you should:
·        Confirm if a Work Permit is required for this work.
·        Confirm that the workplace has been inspected before work starts.
·        Explain how the Work Permit is signed.
·        Confirm the Work Permit is signed.
·        Confirm that it is safe to start work.
·        Get a new Work Permit when the work or the situation changes.
·        Confirm that the work is completed.


2.     Conduct Gas Tests when required.

The air should be tested to prevent explosions and/or make sure the workers and people on-site can breathe the air safely.

You should:
·        Confirm with the Supervisor or the Person in Charge of the work that the air is tested.
·        Confirm with the Supervisor or the Person in Charge of the work that it is safe to start work.
·        Stop work if you smell gas.

If you are a Gas Tester you should:
·        Understand which tests the Work Permit requires and how often.
·        Use certified equipment for the tests.

If you are the Supervisor or the Person in Charge of the work you should:
·        Confirm that gas testing is carried out as per Work Permit.
·        Request more gas tests if necessary to keep the workers safe.
·        Confirm that it is safe to start work.


3.     Verify isolation before work begins and use the specified life protecting equipment.

Isolation separates the worker and keeps them safe from the many dangers that can exist at any given job site. There is always a risk around any electricity, pressure, toxic materials, poisonous gas, chemicals, hot liquids, or radiation. Specified life-protecting equipment, such as breathing apparatus, electrical arc flash protection, or chemical resistant suits help to protect from danger.

You should:
·        Understand the isolations that protect you from danger.
·        Confirm with the Supervisor or the Person in Charge of the work that isolations are in place.
·        Confirm with the Supervisor or the Person in Charge of the work that it is safe to start work.

If you are the Supervisor or the Person in Charge of the work you should:
·        Confirm isolation is in place, for example, lock switches, separate pipes with spades, or lock access doors.
·        Confirm no stored energy or other dangers remain.
·        Confirm that it is safe to start work.


4.     Obtain authorization before entering a confined space.

A confined space, such as a vessel, tank or pipe, can contain explosive gas, poisonous air or other dangers such as lack of oxygen, things that can fall on you or you can fall from. Authorised access keeps everyone safe.

You should:
·        Confirm with the Supervisor or the Person in Charge of the work that it is safe to start work.
·        Confirm with the Attendant that you can enter a confined space.
·        Follow the requirements of the Work Permit.

If you are the Attendant you should:
·        Approve and control access to a confined space.
·        Have means of communication with people in the confined space.

If you are the Supervisor or the Person in Charge of the work you should:
·        Confirm that the requirements of the Work Permit are in place.
·        Confirm that a qualified Attendant is always present when people are in a confined space.
·        Confirm that gas testing is carried out as per Work Permit.
·        Confirm that it is safe to start work.


5.     Obtain authorization before overriding or disabling safety critical equipment.

Obviously, safety-critical equipment must work correctly to keep workers safe. Some xamples of safety-critical equipment include isolation devices/emergency shut down valves, lock out/tag out devices, trip systems, relief valves, fire and gas alarm systems, certain level controls, alarms, crane computers and In-Vehicle Monitoring Systems.

You should:
·        Obtain authorization from the Supervisor or the Person in Charge before overriding or disabling safety-critical equipment.

If you are the Supervisor or the Person in Charge you should:
·        Point our the safety-critical equipment in your work place.
·        Confirm the authorization comes from the right level.


6.     Protect Yourself against a fall when working at height.

Always use fall protection equipment when working outside a protective environment where you can fall over 1.8 meters (6 feet) to keep you safe. A protective environment includes approved scaffolds, stairs with handrails and man lifts.

You should:
·        Have authorization to work at height outside a protective environment.
·        Be aware of what fall protection equipment to use and how to use it.
·        Check equipment before using it.
·        Always tie off when at height outside of a protective environment.

If you are the Supervisor or the Person in Charge of the work you should:
·        Confirm that it is safe to start work at height.


7.     Do not walk under a suspended load.

Working or walking immediately under a suspended load is unsafe as the load can fall on you. A suspended load is an object that is temporarily lifted and hangs above the ground. (Rig floors are excluded from this rule).

You should:
·        Never cross a barrier controlling an area with a suspended load without authorization.
·        Follow the instructions of the Flagman or the Person in Charge of the lift.

If you are the Person in Charge of the lift you should:
·        Mark the unsafe area and put barriers in place.
·        Ensure that nobody walks under a suspended load.


8.     Do not smoke outside of designated smoking areas.

Smoking or use of matches or cigarette lighters could set on fire flammable materials. Designated smoking areas, such as a smoking hut or a smoking room, will keep you safe from causing fire and explosion.

You should:
·        Know where the designated smoking areas are.
·        Intervene if you see someone smoking outside a designated area.

If you are the Supervisor or Person in Charge you should:
·        Inform people about designated smoking areas.
·        Ensure that designated smoking areas are clearly marked.


9.     No alcohol or drugs while working or driving.

Using alcohol, illegal drugs and misusing legal drugs or other substances will reduce your ability to do your job safely.

You should:
·        Always inform the Supervisor or the Person in Charge if you are taking medicine that may have an affect on your performance.
·        If in doubt always check with the Supervisor or the Person in Charge who may seek medical advice.
·        Not use, keep, sell or distribute illegal drugs.
·        Intervene if you see a case of alcohol or drugs abuse.

If you are the Supervisor or Person in Charge you should:
·        Only assign work to people who are fit to work.


10. While driving, do not use your phone and do not exceed speed limits.

Speeding or using your phone while driving increases the risk of losing control of your vehicle.

If you are a Driver you should:
·        Not use a mobile phone or pager, send or read a text message, or use a hands-free mobile phone device.
·        Stay at or below the maximum allowable speed for the road your are driving on as indicated by road signs or Journey Management instructions.
·        Stay at or below the maximum allowable speed limit for the vehicle you are driving.
·        Adjust your speed to the prevailing conditions.

If you are a Passenger you should:
·        Intervene if a Driver is using a phone in a moving vehicle.
·        Intervene if a Driver is exceeding the maximum allowable speed.


11. Wear your seat belt.

This rule is one of the most often violated, as people often don’t think that driving even a short distance requires a seatbelt.  A seatbelt protects you from injury in the event of an incident while driving and keeps you safe. No matter how small of a distance or how slow the speed, safety belts should always be used, whether in (rental) cars, taxis, (mini) buses, trucks, cranes, or forklift trucks, and the situation involves persons in moving vehicles when engaged on Shell business. Putting on a seatbelt should be a well formed habit. The only exceptions include vehicles where only lap seatbelts are available or in public transport where seat belts are not available.

You (Drivers and Passengers) should:
·        Always use a 3-point seatbelt (please note exceptions above).
·        Check that your seatbelt works properly.
·        Keep your seatbelt properly fastened while in a moving vehicle.
·        Check that everyone in the vehicle is wearing a seatbelt properly before starting to drive.
·        Intervene when your fellow passengers are not wearing seatbelts properly.


12. Follow prescribed Journey Management Plan.

A Journey Management Plan is a plan for you as a Driver that will help you to travel and arrive safely.

Journey Management Plans are required for any travel time that is over 4.5 hours.

If you are a Driver you should:
·        Confirm if a Journey Management Plan is required before starting the journey.
·        Discuss the Journey Management Plan with the authorized person.
·        Understand the Journey Management Plan before starting the journey.
·        Comply with the duty, driving and rest hours specified in the Journey Management Plan.
·        Follow the route specified in the Journey Management Plan.
·        Always tell the authorized person immediately if changes occur.

If you are the Supervisor or Person in Charge you should routinely:
·        Check that the Journey Management Plan is in place and being followed.
·        Check that the Driver understands and complies with the Journey Management Plan.

This Code of Conduct to be revised on 08/26/18.