The Elements of Governance

At Wilbur-Ellis, our Code of Conduct outlines the elements of effective Governance.

Anti-Corruption and Bribery

Wilbur-Ellis shall not engage in corruption, extortion, embezzlement, or bribery. Wilbur-Ellis shall comply with all applicable anti-corruption laws and regulations of the countries in which it operates, including the U.S. Foreign Corrupt Practices Act (FCPA) and applicable international anti-corruption conventions. 


Wilbur-Ellis is committed to dealing both lawfully and ethically with all of its suppliers, customers, and other parties. Wilbur-Ellis shall comply with the antitrust laws of every jurisdiction in which Wilbur-Ellis does business. Every employee of Wilbur-Ellis is responsible for compliance with the antitrust laws. 


Wilbur-Ellis shall establish guidelines and procedures to enable the reporting and investigation of any fraudulent activities or misconduct. Wilbur-Ellis shall encourage and facilitate fraud awareness throughout the enterprise and continue its strong commitment to prevention, detection, and correction of fraud misconduct. 

Conflict of Interests

Wilbur-Ellis employees shall carry out their professional responsibilities with integrity and with a duty of loyalty to Wilbur-Ellis. Employees shall avoid any situation that involves a possible conflict of interest or an appearance of a conflict of interest between their personal interests and the interests of Wilbur-Ellis. 

Responsible Sourcing

Wilbur-Ellis shall integrate social, environmental, and governance criteria in its sourcing decisions to promote sustainability objectives in the supply chain. 

Customer Data Security

Wilbur-Ellis shall protect and safeguard all non-public information related to its customers and suppliers. Wilbur-Ellis shall manage technology and implement guidelines and procedures in a manner that safeguards all such information. 

Product Quality

Wilbur-Ellis shall apply effective measures to ensure that its products meet agreed specifications.  

Customer Health and Safety

Wilbur-Ellis shall provide products and services that are safe and do not carry unacceptable levels of risks when used in compliance with their labels and other written instructions. 

©2023 Wilbur-Ellis Holdings, Inc.