Pangea LogoPangea, Formerly GST Seton

Social Responsibility Statement

Corporate Social Responsibility Statement

Pangea has enjoyed a working relationship with the auto industry for nearly a century starting from its origins as a tannery in Roxbury, Mass., to become a global enterprise with operations on four continents.

Approaching processes from a holistic perspective includes both a well-calibrated operational strategy and upholding the highest ethical standards. Headquartered in Rochester Hills, Mich., and acting in accordance with the highest standards of excellence, Pangea has set forth to delineate its values in a comprehensive document known as a Corporate Social Responsibility statement.

A common thread connecting the organization’s strategic plan and core pillars of excellence is a commitment to financial growth and customer-driven results enriching the environment and communities where we work and live. Along with key supply partners, we focus on driving sustainability improvements: new product-composition breakthroughs; natural solutions; upcycling/recycling opportunities; and manufacturing innovations that minimize our carbon footprint by reducing energy consumption, water use, waste production and greenhouse emissions.

Along with financial success and environmental stewardship, we also understand our employees are the undergirding of Pangea, which means our commitment to sustainability transcends production quotas and bottom lines. To that end, we invite you to familiarize yourself with our governing principles of operation, corporate ethics and environmental sustainability.



Responsible Sourcing of Materials

As a manufacturer of leather products, which are derived from natural resources, the ethical sourcing of raw material is critical to Pangea, our employees, customers and the global community. We take animal welfare extremely seriously as we source our products. We require our suppliers adhere to all applicable laws and governmental regulations in our continuing effort to ensure the global best practices. Specifically, Pangea requires every supplier used can verify they provide animals humane treatment: freedom from thirst and hunger; no discomfort, pain, injury and disease; freedom to express normal behavior; and freedom from fear and distress.

Additionally, we oblige our suppliers conduct the necessary due diligence required to verify the sources of all raw materials used in their products, which includes them to certify that conflict-free smelters and refiners are employed in the procurement of any tin, tungsten, tantalum and gold contained in the products they produce.


Compliance, Anti-Corruption and Corporate Malfeasance

We are only as good as our name — and with more than eight decades of reputation to protect we aim to keep our reputation above board. It is our duty to the company’s founders — and our customers — that we operate in a transparent, honorable and lawful manner. Every employee, from the C-Suite to the factory floor, is held to the same standards of honesty and professionalism. Pangea demand sits employees strictly adhere to the requirements of all governing and applicable laws where we operate and that affect our business. These requirements include, but are not limited to, the following U.S. governmental agencies and statues: the federal Internal Revenue Code and all applicable federal, state and local laws; all public and private regulatory agencies affecting our business. Additionally, Pangea prohibits the disclosure of material or confidential proprietary information that would adversely affect our shareholders. We maintain full compliance with all applicable antitrust laws, including the Sherman Act, the Clayton Act, the Robinson-Patman Act and the Federal Trade Commission Act. These legislative acts include prohibitions on price fixing, improper price inducements or allowances on the sale or purchase of merchandise; discriminatory allowances for various services; or false and misleading advertising.


Pangea operates in full compliance with the Foreign Corrupt Practices Act (FCPA), and applies that standard to all our employees, agents and representatives worldwide. Specifically, the FCPA prohibits offers of, or payments to, foreign officials, political parties or candidates for public office, to obtain preferential government treatment. This prohibition extends beyond monetary payments and includes offering anything of value not only to government officials, but also to their representatives or family members.


We also expressly prohibit the receipt of “gifts,” provided — directly or indirectly — by vendors, customers or other parties doing or attempting to do business with us that exceed $25. Customary tokens of appreciation, which are customary within the industries where we operate that have a value of less than $25 are permitted. Reasonable business-related expenditures for food and beverage are allowed between the company’s suppliers. Payments in the nature of a bribe or kick back from corporate funds or other assets are prohibited.


Privacy, Intellectual Piracy and Employee Conduct

Our products are held to the highest standards because of our exacting demand for excellence. Those standards include manufacturing techniques and other modes of operation that proprietary information which, if exposed, would put the company at risk of financial harm. Therefore, it is incumbent upon our employees to maintain the confidentiality of information entrusted to them by Pangea or its customers, except when disclosure is authorized, legally mandated or contravenes our best practices. Confidential information includes all non-public information that might be of use to competitors, or harmful to our customers, if disclosed. Confidential information may never be used for personal advantage.


The ubiquity of social media is of particular concern today, and the inadvertent disclosure of sensitive material, whether or not intentional, must be vigilantly prohibited. Regardless of whether our employees access social media via our systems or theirs, Pangea expects all its employees to protect confidential company (e.g. internal strategies, internal sales results, pricing information or comparisons)and customer information. It is prohibited to post photos on social media that include company processes, products, customers, equipment, or any other company’s confidential information, etc.


As important as company and client data are, we place the same value on our employees’ personal information. Pangea treats all employee data, such as payroll records, reviews, reprimands other sensitive material as proprietary information. We strictly adhere to all regulations — federal, state and local — that cover employee information protection.


Financial Integrity

Honesty governs our operations and that certainly extends to our accounting and financial practices. Pangea employees are required to comply with all generally accepted accounting principles that fall within the fiduciary framework as well as our system of internal accounting controls. In addition, Pangea complies with the applicable provisions of the Sarbanes-Oxley Act requiring all corporate financial records accurately and fairly reflect, in reasonable detail, the transactions and dispositions of our assets.


As a best practice, our employees should also provide our constituents with information that is full, fair, accurate, complete, objective, relevant, timely and understandable. Specifically:

• No false, misleading or artificial entries shall be made on corporate books, records and reports for any reason;

• No undisclosed or unrecorded corporate funds or assets shall be established for any purpose, nor should any off-balance sheet transactions or financing occur without the

expressed knowledge and approval of the Chief Executive Officer and Chief Financial Officer of the Company.

Payments to vendors, suppliers, or other parties owed money by Pangea with corporate funds or other assets will only be approved with corresponding and verifiable documentation that support the remittance. All payments are required to be accompanied by approved purchase orders, invoices or receipts, expense reports or other customary documents, all in accordance with Pangea ’s financial best practices.


Fair Play

A level playing field is the under pinning of a successful free market. To stray from that notion would be a violation of Pangea best practices. It is paramount that all employees refrain from any action that would even give the appearance of impropriety or offer an organization a competitive advantage over others, similarly situated. Specifically, this includes using, having, or otherwise disclosing confidential or trade secret information of a former employer, or in contravention of an agreement, such as a non-disclosure, confidentiality, non-competition or similar agreement.


Conflicts Interest

As with our Fair Play doctrine, conflicts of interest must be avoided to circumvent the appearance of impropriety. Pangea employees must take appropriate measures to avoid conflicts of interest that could impair their independence of judgment concerning our business. Employees must act in good faith, responsibly, with due care, competence and diligence, without misrepresenting material facts or allowing their independent judgment to be subordinated. If there is any question that a conflict of interest might be involved in an existing situation or in some proposed action, employees are required to bring that potential conflict to the attention of decision-makers to safeguard Pangea's reputation and ensure all parties are treated equally.


Product Integrity

Some say the idiom, “the real McCoy,” has its roots dating back to 1872 being associated with a man named Elijah McCoy who patented an oil-drip cup for trains. The theory goes that railroad engineers looking to avoid inferior copies would request it by name, inquiring if a locomotive was fitted with “the real McCoy” system. So is it true with Pangea and our Company Quality Policy: Delivering customer and stakeholder satisfaction by providing exemplary quality products and services while fulfilling statutory, regulatory and industry requirements. To that end, we have implemented methods and processes to minimize the risk of accepting incoming counterfeit parts and materials. Should counterfeit parts be detected, they will be quarantined, and the proper authorities and customers will be notified accordingly.


Export Controls

Pangea will always comply with applicable restrictions on export or re-export of goods, software, services and technology, as well as with applicable restrictions on trade involving certain countries, regions, companies or entities and individuals as dictated by statute.


Whistle-Blower Protections

Government and corporate malfeasance can take place even with the most stringent guardrails in place, which is why the “whistle blower” has a notable place in our nation’s history. For those employees who wish to confidentially report violations that contravene Pangea’s Code of Ethics and Business Conduct policy, they may send a confidential email to No retaliation will be tolerated against anyone who comes forward to raise concerns about possible violations. Any submissions to this email address will be managed with strict confidence by Pangea ’s Ethics Committee.



Carbon Footprint Reduction

Because the nature of our business depends on nature, Pangea is committed to reducing our carbon footprint where and whenever possible. Whether through innovation or other means, we are fully committed to the following propositions: the conservation of resources; waste reduction; pollution prevention; and the efficient use of energy in all site operations. Our products are wholly dependent on a clean, sustainable, carbon-reducing approach to the environment. Pangea is committed to complying with all applicable environmental, health and safety legislation and regulations, as well as any other requirements to which Pangea  subscribes.




Human Rights and Working Conditions

Pangea’s Code of Business Conduct and Ethics is based upon conducting business as a good corporate citizen in strict compliance with all governing laws of the United States, which also applies to any employees outside U.S. jurisdiction. As well, because we believe that human rights are universal and inalienable, we will promote those rights vociferously. We believe in fair wages and equal pay, gender equality non-discrimination. Racial, religious and sexual orientation discrimination have no place in our company and will not be tolerated. These values extend to our business relationships, including with our suppliers and customers. We are wholly committed to the protection and advancement of human rights in our worldwide


operations, and these concepts are reflected in our long-held policies and practices, already in place. Our Code of Business Conduct and Ethics represents our standards and best practices. “Human Rights” include prohibitions against child labor as defined by applicable employment laws and regulations, slavery, human trafficking, forced labor or any other unlawful employment practice.


Wages, Benefits and Hiring Practices

As stated previously, Pangea recognizes its employees as its most valuable resource and we are committed to fair wages and a safe working environment, free of harassment and hostility. We are dedicated in providing a workplace environment that promotes productivity, communication, creativity, teamwork and employee engagement. As a global company, we are committed to offering a competitive compensation package according to each local market. Our best practices in employment include recruiting and hiring, compensating and training, promoting — and, when need be, disciplining, demoting and discharge — employees in strict compliance with the laws of the jurisdictions where we operate.


Corporate Workplace Standards

A happy employee is a productive employee, and Pangea is committed to our employees’ welfare — and the notion of work-life balance. To that end, we are fully committed to establishing work schedules as appropriate to meet business needs as required by law and/or union agreements, and that take employees’ needs in mind. We are committed to providing employees a healthy and safe workplace with site conditions that protect the safety and health of our employees, contractors, and visitors. We commit to be proactive in identifying and mitigating environmental, health and safety risks all to prevent accidents, reduce our environmental impact and prevent emergency situations from occurring. We will always fully comply with all applicable environmental, health and safety legislation and regulations, as well as any other requirements to which we subscribe. We strive to continuously improve our environmental, health and safety management systems, and increase our performance through the establishment and maintenance of meaningful objectives and targets. We commit to the conservation of resources, waste reduction, pollution prevention and the efficient use of energy.


We aim to provide all employees with the knowledge and skills necessary to work in a safe and environmentally responsible manner. To ensure compliance with these propositions, Pangea conducts routine monitoring and evaluation of environmental, health and safety performances as it relates to applicable requirements and established objectives and targets. To safeguard against non-compliance with the aforementioned best practices, we commit to ongoing consultation and participation of all employees and stakeholders in the proactive management of the Pangea Environmental, Health, and Safety Management System.


Non-Discrimination and Harassment-Free Workplace

We will not tolerate harassment of any employee. Period. Our best practices seek to attract and retain the best qualified people available without regard to race, color, religion, national origin, gender, sexual orientation, gender identity, age, physical or mental disability, or veteran status. Our nondiscrimination policy applies to applicants as well as employees, and covers all terms and conditions of employment, including recruiting, hiring, transfers, promotions, terminations, compensation and benefits. Discrimination or harassment based on any of the above factors is strictly prohibited and violators are subject to termination. We take pride in striving to provide a positive and harassment-free work environment, offering all employees the opportunity to perform to their full potential.