In accordance with EveryoneCounts Community Standards, we have established this Supplier Code of Conduct to ensure its suppliers are committed to the same principles.
Suppliers, their employees, agents, and subcontractors (collectively referred to as “Suppliers”) may enter into agreements with EveryoneCounts to conduct business with us or on our behalf. All Suppliers are required to comply with this Supplier Code of Conduct, or at least all applicable laws and regulations.
In rare circumstances, such agreements can still move forward if EveryoneCounts identifies sufficient compensating controls in place to reasonably ensure legal compliance. EveryoneCounts expects Suppliers to have strong corporate governance in place to support their compliance with this Code of Conduct.
EveryoneCounts may audit a Supplier upon reasonable notice to help confirm compliance with this Code of Conduct. EveryoneCounts reserves the right to discontinue a Supplier relationship in the event they are found to be acting unlawfully or in violation of this Code of Conduct or any applicable EveryoneCounts policy.
Legal and Regulatory Compliance
Anti-Corruption: Never give or offer anything of value to gain an improper advantage, whether it be in dealings with government officials or the private sector. Suppliers are required to comply with all applicable laws and regulations, including, for example, the Foreign Corrupt Practices Act and the United Kingdom Bribery Act of 2010.
Antitrust: Do not participate in any anti-competitive conduct such as discussing or exchanging competitively sensitive information or agreeing to geographic markets, customers, or pricing with competitors. Suppliers are required to comply with all applicable antitrust and fair competition laws.
Trade: Comply with applicable import and export laws, act in accordance with trade restrictions of the US Treasury Department’s Office of Foreign Assets Control (OFAC) and any other applicable trade restrictions.
Business Practices and Ethics
Conflicts of Interest: Avoid conflicts of interest or even the appearance of conflicts of interest. Suppliers must not deal directly with any EveryoneCounts employee whose spouse, domestic partner, or other relative has an interest in the Supplier as an employee, partner, owner, investor, or similar roles, including negotiating the Supplier contract.
Gifts and Hospitality: Avoid giving gifts or providing lavish hospitality to EveryoneCounts employees. If offering a gift or hospitality to an EveryoneCounts employee, Suppliers should use good judgment and ensure it complies with applicable laws and is consistent with local customs.
Insider Trading: Do not buy or sell EveryoneCounts stock when in possession of material nonpublic information, or pass such information to any others, including friends or family.
Records Management: Accurately record, maintain and report financial and business information. Ensure compliance with all applicable laws and regulations regarding such information.
External Communications: Do not speak publicly on EveryoneCounts’ behalf unless authorized to do so by EveryoneCounts Legal.
Risk Management: Implement internal policies, procedures, and controls to identify, address, and remediate risks addressed in this Code of Conduct as well as applicable legal requirements.
Training and Communication: Communicate this Code of Conduct to all employees or contractors who will be conducting business with EveryoneCounts and conduct training for employees, when necessary.
Anti-harassment and Unlawful Discrimination: Provide equal opportunity employment and maintain a respectful work environment that is free of discrimination, violence harassment, and intimidation.
Human Rights: Respect human rights, provide fair working conditions, and prohibit forced, compulsory, or child labor.
Compensation: Provide compensation (including overtime and benefits) that at a minimum, complies with local laws. Suppliers must pay their employees in a timely manner and provide documentation detailing the basis of their pay (e.g., paystub).
Parental Leave: Abide by all applicable laws pertaining to parental leave, and offer paid benefits that are gender-inclusive when possible.
Freedom of Association: Abide by all applicable laws pertaining to freedom of association and collective bargaining. Do not retaliate against employees who choose to organize.
Compliance with Environmental Laws and Regulations: Abide by all applicable laws for hazardous materials, air emissions, waste, and wastewater discharges.
Ecological Footprint: Conduct business in an environmentally responsible and sustainable manner, including resource-efficient consumption of energy, water, and other natural resources, minimizing waste and diversion from landfills, and reducing harmful chemical use.
Protection of Data, Intellectual Property, and Assets
Data Protection: Protect confidential and proprietary information of EveryoneCounts, EveryoneCounts employees, members, and others with whom we do business. Information should not be disclosed without proper authorization and should only be used for a legitimate business purpose. All information uses must comply with all applicable laws, regulations, and governing contracts.
Protect EveryoneCounts’ Intellectual Property and Assets: Protect and use EveryoneCounts’ intellectual property and tangible assets responsibly. EveryoneCounts’ intellectual property (including name, logo, trademarks, etc.) and tangible assets should be used for legitimate business purposes and only when authorized to do so by EveryoneCounts.
If a Supplier is in violation of this Code of Conduct they are required to notify EveryoneCounts immediately.
Whistleblower Hotline: To report concerns about activity related to violations of this Supplier Code of Conduct you may do so confidentially, anonymously (if desired), and free of retaliation. You may report violations to firstname.lastname@example.org.
Last updated on August 23, 2021