Vendor Code of Conduct
Working with Integrity
Integrity Marketing Group, LLC (collectively, “Integrity”) are committed to driving forward our committed values of integrity, service, respect and partnership. These values can be accomplished by actively partnering with manufacturers, distributors, vendors, and other suppliers (each a “Vendor” and collectively “Vendors“) that align to our values. Therefore, Integrity expects our Vendors to embrace these same values by complying with the principles outlined in this Vendor Code of Conduct (“Code of Conduct“).
The principles reflected in this Code of Conduct establishes the minimum standards that must be met by any Vendor that does business with Integrity, regarding:
- Human rights and fair labor practices;
- protecting information;
- the impact of Vendor’s activities on the environment; and
- Vendor’s ethical business practices.
1. COMPLIANCE WITH THIS CODE OF CONDUCT
This Code of Conduct applies to all Vendors that provide goods and services to Integrity. Vendor is responsible for compliance with the standards set out in this Code of Conduct throughout its operations and throughout its entire supply chain. Without limiting Vendor’s obligations hereunder, Vendor is responsible for compliance with the Code of Conduct by all of its employees, suppliers, vendors, agents, and subcontractors (“Partner(s)”).
While Vendors are expected to self-monitor and demonstrate their compliance with this Code of Conduct, Integrity may audit Vendor or inspect Vendor’s facilities to confirm compliance. Vendors that behave in a manner that is unlawful or inconsistent with the this Code of Conduct, or any Vendor policy provided to Vendor, risk termination of their business relationship with Integrity. Complying with this Code of Conduct is required in addition to meeting any other obligations contained in any contract a Vendor may have with Integrity. Integrity may immediately terminate its business relationship with Vendor if Vendor or its Partners fail to meet this Code of Conduct.
2. HUMAN RIGHTS AND FAIR LABOR PRACTICES
2.1 Slavery and Human Trafficking
All labor must be voluntary. Vendor shall not support or engage in slavery or human trafficking in any part of its supply chain. Without limiting Vendor’s obligations hereunder, Vendor shall not, and shall ensure that its Partners do not, support or engage in, or require any:
- compelled, involuntary, or forced labor;
- labor to be performed by children;
- bonded labor;
- indentured labor; or
- prison labor.
2.2 Compliance and Documentation
Vendor shall implement and maintain a reliable system, including a recordkeeping systems, to verify and record the eligibility of all workers.
2.3 Freedom of Movement
Without limiting Vendor’s obligations hereunder, Vendor shall ensure that workers have the right to freedom of movement without delay or hindrance; or the threat or imposition of any discipline, penalty, retaliation, or fine or other monetary obligation.
2.4 Work Hours
Vendor shall not require or allow workers to work more than the maximum legally permitted number of regularly paid hours worked per week.
2.5 No Discrimination, Abuse, or Harassment
Vendor shall not discriminate in hiring, compensation, training, advancement or promotion, termination, retirement, or any other employment practice based on race, color, national origin, gender, gender identity, sexual orientation, military status, religion, age, marital or pregnancy status, disability, or any other characteristic other than the worker’s ability to perform the job. Vendor shall treat workers with respect and dignity. Vendor shall not subject workers to corporal punishment, or physical, verbal, sexual, or psychological abuse or harassment. Vendor must not condone or tolerate such behavior by its Partners.
2.6 Health and Safety
Vendor shall provide a safe, healthy, and sanitary working environment. Vendor shall implement procedures and safeguards to prevent workplace hazards, and work-related accidents and injuries, including procedures and safeguards to prevent industry-specific workplace hazards, and work-related accidents and injuries, that are not specifically addressed in this Code of Conduct. Vendor shall provide workers adequate and appropriate personal protective equipment to protect workers against hazards typically encountered in the scope of work.
Without limiting Vendor’s obligations hereunder, Vendor shall ensure that all facilities it uses meet all applicable building codes and industry design and construction standards.
3. PROTECTING INFORMATION
Protection of intellectual property rights is vital for any company. All Vendors must respect intellectual property rights, protect confidential information, comply with security standards, policies, and controls, and comply with privacy rules and regulations, as applicable. Without limitation, Vendors must:
3.1 Business Continuity
As applicable, ensure maintenance of a measurable documented emergency response and disaster recovery plan to protect data and intellectual property and the business continuity of the services and/or goods being provided to Integrity.
3.2 Physical and Intellectual Property
- Protect and responsibly use the physical and intellectual assets of Integrity, including but not limited to: intellectual property, tangible property, supplies, consumables, and equipment, when authorized by Integrity to use such assets.
- Comply with the intellectual property ownership rights of Integrity and others and properly manage the transfer of technology and know-how in a manner that protects intellectual property rights.
- Consider all data stored or transmitted on Integrity-owned or leased equipment as property of Integrity. Integrity may monitor all use of the corporate network, all systems (including email), and may access all data stored or transmitted using the Integrity network.
- Do not provide access to Integrity data and any of Integrity’s information to any third party, without a legitimate business need, and permission from the responsible owner at Integrity.
- If an Integrity asset or personal device containing Integrity business-related data is lost or stolen, report it as soon as possible.
- Promptly report to Integrity any potential incident that involves Integrity data.
- Follow all local privacy and data protection laws.
- Provide clear and accurate privacy notices when collecting or processing personal data.
- Honor privacy choices by using data only as agreed to by Integrity representatives or Integrity’s customers.
4. ENVIRONMENTAL PROTECTION
4.1 Operation of Vendor’s Facilities
Vendor shall operate its facilities in compliance with all environmental laws, including laws and international treaties relating to waste disposal, emissions, discharges; and hazardous and toxic material handling.
4.2 Inputs and Components
Vendor must ensure that the goods that it manufactures (including the inputs and components that it incorporates into its goods) comply with all environmental laws and treaties. Vendor must ensure that it will only use packaging materials that comply with all environmental laws and treaties.
5. BUSINESS PRACTICE AND ETHICS
5.1 Publicity and Press
Vendors may not issue press releases or other publicity related to their relationship or agreements with Integrity without the prior written consent of Integrity’s Chief Technology Officer and Chief Marketing Officer.
Vendors may only speak to the press on behalf of Integrity if expressly authorized in writing to do so by Integrity’s Chief Marketing Officer.
5.2 Ensuring Adequate Information
Vendors shall be responsible for ensuring all information used by Integrity to pay Vendor’s invoices is up-to-date and correct. To the extent Integrity provides access to a Vendor to use a system to process invoices, Vendor shall verify all information and promptly notify Integrity of any changes.
5.3 Counterfeit Goods
Vendor shall not furnish counterfeit goods to Integrity, defined as goods or separately-identifiable items or components of goods that: (i) are an unauthorized copy or substitute of an Original Equipment Manufacturer or Original Component Manufacturer (collectively, “OEM”) item; (ii) are not traceable to an OEM sufficient to ensure authenticity in OEM design and manufacture; (iii) do not contain proper external or internal materials or components required by the OEM or are not constructed in accordance with OEM design; (iv) have been re-worked, re-marked, re-labeled, repaired, refurbished, or otherwise modified from OEM design but not disclosed as such or are represented as OEM authentic or new; or (v) have not passed successfully all OEM required testing, verification, screening, and quality control processes.
5.4 Compliance with Laws
Vendor shall comply with all applicable national and local laws and regulations, including laws and regulations relating to all goods and services Vendor is providing to Integrity. Where this Code of Conduct requires Vendor to meet a higher standard than set out by law or regulation, Vendor shall meet such higher standards. Vendor acknowledges that this Code of Conduct sets out audit standards that Integrity may use to determine whether Vendor is meeting the requirements set out in this Code of Conduct.
5.5 Anti-bribery, Anti-corruption, and Gifts.
Vendor must maintain the highest ethical standards. Vendors shall comply with all anti-bribery laws, regulations, and legislation, including the Foreign Corrupt Practices Act and similar anti-bribery laws of other countries. Vendors must not offer or accept anything of value to secure an improper advantage or benefit. Vendors shall not offer or accept, either directly or indirectly, kickbacks, bribes, or payoffs in cash or any other form. It does not matter that a prohibited payment may be demanded by a public official; the prohibited payment still may not be made. Vendors shall not facilitate payments on our behalf nor engage in any activity on behalf of Integrity including, without limitations, lobbying, charitable or political donations and appearances before governmental entities, officials, or representatives.
5.6 Anti-tax Evasion and Anti-facilitation of Tax Evasion.
Integrity does not tolerate unlawful tax evasion or any facilitation of unlawful tax evasion. Vendors shall not directly or indirectly engage in, or facilitate the engagement by others in, the deliberate and fraudulent diversion of funds from a tax authority. Vendors are expected to ensure the same of their Partners by adopting, maintaining, and implementing processes to prevent such conduct.
6. REPORTING VIOLATIONS
Vendor shall self-report any violations of the Code of Conduct. Vendor shall not retaliate or take disciplinary action against any worker who has, in good faith, reported violations or questionable behavior, or who has sought advice regarding this Code of Conduct.
Integrity has established a confidential reporting tool through Lighthouse Services, Inc. for the specific purpose of reporting fraud, unlawful, unethical or other types of improper behavior. A report may be filed at https://www.lighthouse-services.com/integritymarketing.
For regular business matters that do not require anonymity, Vendor can also submit questions and comments regarding the Code of Conduct to Integrity’s liaison set out below:
Jayne Rothman, Chief Legal Officer
1445 Ross Ave, Floor 40
Dallas, TX 75202