Supplier and partner code of conduct

Version 1.1 as of October 31, 2024

Our Principles

At Trinetix, our commitment to ethical excellence is the foundation of all our business relationships. We believe that integrity, respect, and responsibility are not just internal values but are also essential in our engagements with suppliers and partners. This Supplier and Partner Code of Conduct extends these core principles to our external collaborations, ensuring that our high standards are upheld throughout our supply chain and partnerships.

Integrity: We conduct our business with honesty and fairness, and we expect the same from our suppliers and partners. This means engaging in transparent transactions, honoring commitments, and adhering to ethical practices at all times.

Respect: Mutual respect is the cornerstone of our relationships. We value diversity and inclusivity and expect our suppliers and partners to share this commitment by respecting the rights and dignity of all individuals associated with their operations.

Responsibility: We are committed to making responsible decisions that consider the well-being of people and the planet. This includes environmental stewardship, responsible sourcing, and considering the social impact of business decisions.

Collaboration for Mutual Success: We believe in building relationships that are mutually beneficial. By working together with our suppliers and partners, we aim to create shared value and contribute to each other's success, fostering a sustainable and prosperous business environment.

This Supplier and Partner Code of Conduct is a testament to our dedication to these principles and our expectation that our suppliers and partners will join us in this commitment to ethical excellence.

1. Scope, Purpose, and Users

1.1. Scope: This Supplier and Partner Code of Conduct (the “Code”) sets the standards and expectations for our suppliers and partners' ethical and professional conduct. It covers all aspects of our business relationships and is applicable to every interaction and transaction with Trinetix.

The Code applies to all suppliers and partners of our company around the globe, irrespective of their geographic location, nature of business, legal status, or type of collaboration.

The Code is not intended to replace Trinetix’ other policies related to establishing or terminating business relations with suppliers and partners but rather to codify the fundamental standards for them. We reserve the right to refuse to collaborate with potential or existing suppliers and partners for reasons other than those presented in the Code.

1.2. Purpose: The purpose of this Code is to serve as a guiding framework for our suppliers and partners in their general conduct and their cooperation with us. It is intended to reflect a shared commitment to integrity, professionalism, and adherence to the highest ethical standards.

1.3. Users: This Code is intended for use by all current and potential suppliers and partners of our company. Adherence to this Code is expected from all entities and individuals who engage in business with our company, as it forms the basis of our mutual commitment to ethical business practices.

Additionally, those from our team who are involved in managing, coordinating, or working directly with suppliers and partners are expected to be familiar with the Code and uphold its principles in their interactions.

2. Human Rights and Labor Standards

2.1. Humane Treatment: We firmly believe in the humane treatment of all individuals. Physical punishment, mental or physical coercion, and verbal abuse are strictly prohibited in all our operations and those of our suppliers and partners. We expect every workplace to uphold dignity and respect for all.

2.2. No Slavery and Human Trafficking: Our commitment to human rights extends to a zero-tolerance approach towards all forms of modern slavery and human trafficking. We require our suppliers and partners to rigorously ensure that these practices have no place in their operations or supply chains.

2.3.No Forced Labor: We stand against forced, bonded, or indentured labor in any form. Labor must be voluntary, and workers should have the freedom to terminate their employment with reasonable notice, in accordance with local laws and international standards.

2.4. No Child Labor: Child labor is strictly prohibited. We adhere to the International Labour Organization’s minimum age provisions and the laws of each jurisdiction and require that from our suppliers and partners. Hereby, we expect that their business practices will not impede the education and well-being of children.

2.5. No Harassment and Discrimination: We are committed to a workplace free of harassment and discrimination. This commitment extends to our suppliers and partners, who are expected to ensure equal treatment of all individuals regardless of their race, color, religion, sex (including pregnancy, sexual orientation, or gender identity), marital status, national origin, disability, age or genetic information (including family medical history), veteran status or any other characteristic protected by applicable laws and regulations.

2.6. Equal Opportunity: Equality of opportunity is non-negotiable. We expect our suppliers and partners to embrace this principle, offering a work environment that is inclusive, supportive, and free from bias.

2.7. Working hours: We adhere to, and expect our suppliers and partners to adhere to, local laws and standards regarding working hours, rest periods, and overtime. Working schedules should be fair, humane, and appropriately compensated.

2.8. Health and Safety: A safe and healthy working environment is a fundamental right. We require that our suppliers and partners implement proactive health and safety measures, provide necessary training, and comply with all relevant legislation and standards.

2.9. Freedom of Association: Respecting the rights of workers to form and join trade unions and engage in collective bargaining is essential. We expect our suppliers and partners to recognize and facilitate these rights in accordance with local laws and international labor standards.

3. Sustainability and Environmental Standards

3.1. Commitment to Sustainability: Our commitment to sustainability is a cornerstone of our business philosophy. We expect our suppliers and partners to share this commitment and actively contribute to sustainable development. This includes adopting practices that minimize environmental impact, maximizing the use of green technology, and promoting a sustainable future.

3.2. Permits and Registrations: Our suppliers and partners are required to obtain and maintain all environmental permits, licenses, and registrations necessary to conduct their activity. Compliance with all applicable environmental laws and regulations is mandatory. We also expect our suppliers and partners to conduct their operations in accordance with both local and international environmental standards, ensuring legal and ethical environmental management.

3.3. Resource Efficiency and Waste Reduction: We emphasize the importance of efficient resource utilization and waste reduction. Suppliers and partners should strive to minimize resource consumption, optimize energy use, and reduce waste generation. We support efforts to move towards a circular economy, where materials are reused and recycled, reducing the overall environmental footprint.

3.4. Emissions and Pollution Control: Managing and reducing emissions and pollution is critical in protecting the environment. Suppliers and partners are expected to have measures in place for controlling emissions, including greenhouse gasses, and managing waste and pollution effectively.

4. Integrity and Ethics

4.1. Honest and Accurate Dealings: We require all interactions and transactions to be conducted with utmost honesty and accuracy. Our suppliers and partners must ensure that all business dealings with Trinetix are transparent, records are kept accurately, and commitments are fulfilled with integrity. Misrepresentation or deception in any form is strictly prohibited.

4.2. Accurate Representation and Relationship: Any public statements or representations regarding the relationship with our company must be accurate, authorized, and in line with any agreed terms. Suppliers and partners should not misrepresent their relationship with our company in any public communication or advertisement.

4.3. Confidential Information: Suppliers and partners must respect and safeguard confidential information. This includes not disclosing or misusing any sensitive information obtained through business relationships with our company. The obligation to protect confidential information extends beyond the duration of our mutual relations.

4.4. Intellectual Property: Respect for intellectual property rights is critical. Suppliers and partners are expected to honor all intellectual property laws and provisions, including adhering to licensing agreements and avoiding infringement of patents, copyrights, trademarks, or any other intellectual property rights.

4.5. Conflicts of Interest: Suppliers and partners should avoid conflicts of interest with our company. Any situation that could be perceived as a conflict must be disclosed immediately. Transparency in such matters ensures fairness and integrity in our business relationships.

4.6. Fair Competition: We are committed to fair competition and expect our suppliers and partners to comply with all applicable antitrust and competition laws and regulations. This includes avoiding practices that unfairly restrict trade or inhibit competition.

4.7. No Bribery and Corruption: Our zero-tolerance policy towards bribery and corruption applies to all suppliers and partners. This prohibition includes any form of bribery, kickbacks, or any other illegal payments or inducements to or from any party, including government officials.

4.8. Trade Controls: Suppliers and partners must adhere to all applicable trade control laws and regulations. This includes compliance with international trade laws, export controls, and sanctions programs, ensuring that all business activities are legally and ethically conducted. We require that our suppliers and partners do not do any business in sanctioned jurisdictions, countries, and territories, including militarily occupied territories.

4.9. No Money Laundering: Suppliers and partners are required to actively prevent money laundering and comply with all laws and regulations designed to combat such activities. This involves undertaking due diligence and reporting any suspicious financial activities.

4.10. No Fraud and Tax Evasion: We do not support fraudulent activities or tax evasion and hope that our suppliers and partners do not engage in such dealings. We require that our suppliers and partners conduct all transactions honestly, ensuring accuracy in financial reporting and adherence to applicable tax laws.

4.11. Public Stance: We expect our suppliers and partners to uphold and publicly advocate for positions that align with universally recognized ethical standards and human rights, especially on significant public matters.

5. Quality, Security, and Data Protection

5.1. Quality Assurance and Compliance: We expect our suppliers and partners to maintain the highest quality standards in all products and services. This commitment includes compliance with relevant industry standards and continuous improvement in quality assurance processes. Regular quality audits and adherence to agreed specifications are essential. We especially rely on our suppliers to consistently ensure that their products and services meet our stringent quality criteria.

5.2. Security and Risk Management: Robust security measures are crucial in today’s business environment. Our suppliers and partners must implement effective security practices to manage and mitigate risks. This includes maintaining the physical security of facilities and implementing strong internal controls to prevent any security breaches. Regular risk assessments should be conducted to identify potential vulnerabilities and develop strategies to address them.

5.3. Information Security and Cybersecurity: In an era where information is a critical asset, we require our suppliers and partners to uphold the highest standards of informational security and cybersecurity. This involves protecting sensitive and confidential information from unauthorized access, disclosure, alteration, and destruction. Practices such as data encryption, secure network protocols, and regular cybersecurity audits are vital. We expect proactive measures to safeguard against data breaches and cyber threats.

5.4. Personal Data Protection: The protection of personal data, also known as personal identifiable information (PII), is of significant importance. Suppliers and partners are expected to handle personal data responsibly, ensuring adherence to global data protection and privacy regulations. This includes implementing policies and procedures for data privacy, ensuring the lawful collection, processing, and storage of personal data, and respecting the privacy rights of individuals. We emphasize the importance of maintaining the confidentiality and integrity of all data handled.

6. Raising Concerns

6.1. Reporting: We expect our suppliers and partners (and their employees) to promptly report any violations or suspected violations of laws, regulations, or this Code, particularly those related to our business transactions or engagements. Reports should be made to your primary contact within our company or directly to our Legal and Compliance Department at legal@trinetix.com

6.2. No Retaliation: We are committed to maintaining an environment where open communication is valued and protected. It is Trinetix’ policy not to retaliate against anyone who, in good faith, reports a violation or assists in the investigation of reported concerns and we expect the same treatment from our suppliers and partners. However, if direct reporting to your primary contact within our company or the Legal and Compliance Department is not feasible or appropriate, concerns may also be directed through a special whistleblowing hotline.

7. Monitoring, Compliance, and Termination

7.1. Monitoring and Compliance: We actively monitor compliance with this Code among our suppliers and partners. This includes regular reviews and audits to ensure adherence to the standards and principles outlined herein. We expect our suppliers and partners to cooperate fully in these compliance efforts and to provide all necessary information and access required for effective monitoring.

7.2. Addressing Non-Compliance: In instances of non-compliance with the Code, we are committed to working collaboratively with our suppliers and partners to address and rectify issues promptly. This may involve corrective actions, additional training, or other measures to ensure future compliance. We view non-compliance as an opportunity for improvement, rather than just a contractual breach.

7.3. Termination for Cause: While we prefer to resolve issues through corrective action, we reserve the right to terminate our relationship with any supplier or partner that consistently fails to comply with the Code or in cases of serious violations. Such termination will be according to the terms and conditions outlined in our contractual agreements. Decisions to terminate will be considered carefully, taking into account the severity of the violation and the willingness and ability of the supplier or partner to achieve compliance.

7.4. Collaboration and Support: We recognize that compliance is an ongoing process and are committed to supporting our suppliers and partners in meeting these standards. We encourage open dialogue and provide guidance to assist in understanding and implementing the requirements of the Code.

8. Responsibility and Implementation

8.1. Contacts: Those from our team who are involved in managing, coordinating, or working directly with suppliers and partners are responsible for:

promptly relaying any reports of ethical violations to the Legal and Compliance Department and/or the Chief Operating Officer while ensuring confidentiality;
informing suppliers and partners about this Code, ensuring their understanding and compliance, and providing necessary guidance to reinforce its standards and principles.

8.2. Legal and Compliance Department: The Legal and Compliance Department is responsible for:

keeping abreast of relevant legal and regulatory changes and proposing updates to the Code as necessary;
reviewing reported cases to check adherence to the Code’s standards;
offering guidance related to the Code and maintaining essential documentation for compliance and oversight.

8.3. Chief Operating Officer: The Chief Operating Officer is ultimately responsible for:

ensuring that the Code is integrated and operational within the company;
reviewing and handling major reported cases and issues arising from violations of the Code;
addressing the raised concerns and making necessary modifications to the Code, company policies, and internal processes;
overseeing the communication with suppliers and partners and ensuring that no misunderstandings and conflicts arise out of enforcement of the Code.