Ensuring the Accuracy of Corporate Records and Reporting
All transactions must be properly and accurately recorded on Tronox’s books and records, in compliance with Generally Accepted Accounting Principles, Tronox’s internal controls over financial reporting and other internal controls, and any other applicable Company policies and procedures.
No unrecorded bank accounts, corporate funds or assets may be maintained, and all entries made in any corporate books or records must be accurate and comply with Tronox’s policies and procedures. Furthermore, it is your responsibility, within the scope of your duties, to ensure that all financial recordkeeping and records to governmental agencies be truthful and accurate.
All Tronox personnel subject to this Code are prohibited from coercing, manipulating, misleading or fraudulently influencing any independent or certified accountant involved in auditing or reviewing Tronox’s financial statements, for the purpose of rendering the financial statements misleading.
Tronox is committed to the prevention, detection, and reporting of money laundering and terrorist financing.
Money laundering is the process of converting illegal proceeds so that funds are made to appear legitimate. To protect our Company, you must act diligently to prevent any Tronox products or services from being used to further money laundering evasion.
Securities and Exchange Commission (“SEC”) Reporting; Other Public Communications
As a public company, Tronox is committed to full, fair, accurate, timely and understandable disclosure in reports and documents that it files with, or submits to, the United States Securities and Exchange Commission (the “SEC”) and in other public communications made by Tronox, in compliance with the SEC, stock exchange, or other applicable rules and regulations.
In support of this commitment, Tronox has, among other measures, (a) designed and implemented disclosure controls and procedures (within the meaning of applicable SEC rules) and (b) requires the maintenance of accurate and complete records, the prohibition of false, misleading or artificial entries on its books and records, and the full and complete documentation and recording of transactions in Tronox’s accounting records.
Within the scope of your duties, you are expected to comply with Tronox’s disclosure controls and procedures to ensure that material information relating to Tronox is timely recorded, processed, summarized, and reported in accordance with all applicable SEC and other rules and regulations. If your duties involve the reporting of material information, you will be trained in these controls and procedures. In order to ensure that all disclosures of company information are accurate and in full compliance with applicable laws and regulations, all such disclosures are to be made only through specifically established channels. See “Media Contact” for more information.
In addition to performing their duties and responsibilities under these requirements, each of the Company’s senior officers will establish and manage Tronox’s reporting systems and procedures with due care and diligence to ensure that:
- reports filed with or submitted to the SEC and other public communications contain information that is full, fair, accurate, timely, and understandable and do not misrepresent or omit material facts;
- business transactions are properly authorized and completely and accurately recorded on Tronox’s books and records in accordance with generally accepted accounting principles and Tronox’s established financial policies; and
- retention or disposal of company records is in accordance with established Tronox policies and applicable legal and regulatory requirements.