Supplier Code of Conduct

Effective date: November 1, 2021

This Supplier Code of Conduct clarifies the standards we expect from our suppliers and their supply chains. These principles should be viewed as ‘best practice’ expectations. They are not intended to conflict with or modify the terms of any supplier contract with PrivacyPlan. If a PrivacyPlan contract, and/or applicable law or regulation, addresses any area covered by this Supplier Code of Conduct, suppliers must comply with the contract and/or legal or regulatory requirement.

Our Code of Conduct sets out the values, responsibilities, and rules of behavior for all our employees, subsidiaries, and joint ventures controlled by PrivacyPlan. We expect our suppliers to adhere to their own similar code of conduct. Having regard to the size and nature of their business, we also expect our suppliers to have management systems in place which support compliance with applicable laws and regulations.

Anti-Bribery and Corruption

We expect our suppliers to comply with all applicable laws and regulations that prevent bribery and corruption. PrivacyPlan will not tolerate, in particular, corrupt activity involving government officials, our commercial business partners, or the receipt of bribes or ‘kickbacks’ or any other improper inducements for business or financial gain. PrivacyPlan expects its suppliers to be similarly intolerant of corrupt activity and to have appropriate and adequate procedures to prevent such activity from taking place. In short, PrivacyPlan expects its suppliers to adhere to standards similar to those contained within PrivacyPlan’s own Anti-Bribery and Corruption Policy.

Trade Sanctions and Customs Regulations

We expect our suppliers to conduct business in compliance with all applicable laws, regulations, and sanctions governing:
– Export, re-export, import of products, technical data, software, and services; and
– Economic sanctions and embargoes.

Anti-Trust and Competition

We expect our suppliers to conduct business in accordance with all applicable competition and anti-trust laws and regulations. Our suppliers are expected not to enter into formal or informal anti-competitive arrangements that improperly restrict competition.

Conflicts of Interest

We expect our suppliers to avoid conflicts of interest or situations giving the appearance of a potential conflict of interest in their dealings with PrivacyPlan. It is understood that such actual or potential conflicts do arise in the course of business from time to time, in which case we expect our suppliers to disclose them to PrivacyPlan in a timely way.

Accurate Record Keeping

We expect our suppliers to accurately and securely capture, store, and retain, as appropriate, business records.

Personal, Confidential, and Proprietary Information

We expect our suppliers to protect all sensitive information, including confidential, proprietary, and protected personal information. Information should not be used for any purpose other than the business purpose for which it was provided without prior authorization. Where such information is held or transferred electronically, we expect our suppliers to implement appropriate IT cyber security and to notify us of any suspected or actual data breaches. We expect our suppliers to comply with all applicable intellectual property rights and data privacy laws.

Personal Conduct: Workplace/Employees

We expect our suppliers to follow the principles set out in PrivacyPlan’s own Code of Conduct. Our suppliers are expected to ensure the well-being of their staff where individuals are treated with dignity and respect. Accordingly, we expect our suppliers to comply with applicable non-discrimination laws and regulations. We also expect our suppliers to ensure that employees may perform work in an environment that is free from harassment or other abusive conduct.

We expect our suppliers not to engage in the use of forced or bonded labor, slavery, or trafficking of persons. We also expect our suppliers to ensure that any form of child labor is not used and oppose practices that inhibit the development of children.

We expect our suppliers to comply with applicable laws and regulations on pay, benefits, working hours, health and safety, the rights of individuals to join trade unions, and participate in collective bargaining.

We expect our suppliers to provide employees and third parties with access to adequate reporting channels to seek advice or raise legal or concerns about unethical conduct in the workplace, including opportunities for anonymous reporting. We expect our suppliers to take action to prevent, detect and correct retaliatory actions.

Quality, Health, Safety and Environment (QHSE)

PrivacyPlan expects a strong commitment to QHSE management. We expect our suppliers to help us fulfill our QHSE goals and, in particular, to ensure safe working conditions for their employees and contractors We expect our suppliers to comply with applicable laws and regulations regarding the environment and to conduct their business in a manner that actively manages environmental risks.

As an essential part of our commitment to protecting the environment, we expect our suppliers to have particular regard to the following matters that are identified in our Code of Conduct, PrivacyPlan QHSE Policy, PrivacyPlan Environmental Policy, and the PrivacyPlan Sustainability Policy.

Corporate and Personal Integrity

In addition to the standards set out in this Supplier Code of Conduct, PrivacyPlan is committed to the respect for human rights set out in the United Nations Declaration of Human Rights and we endorse the principles set out in the UN Global Compact’s Ten Principles and the OECD Guidelines for Multinational Enterprises. We expect our suppliers, where applicable and appropriate, to act in a manner supportive of our commitment in this regard.

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If you have any questions about this Code, please contact us.