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Supplier Code of Conduct

OVERVIEW

ABOUT THIS POLICY

Adenza Group, Inc., together with its direct and indirect subsidiaries (collectively “Adenza”), is committed to conducting its business with integrity. Our suppliers play an important role in helping to reach our goals of high ethical standards and compliance with laws and regulations. This Supplier Code of Conduct (this “Code”) reflects the minimum standards by which all suppliers (each, a “Supplier”) must conduct themselves in connection with providing goods and/or services to Adenza. This Code applies to Supplier and its personnel, including any third party or subcontractor engaged by Supplier, and to Supplier’s upstream supply chain.

Supplier is expected to report any actions or decisions that contravene the standards set out in this Code. Supplier may report to our hotline, as set out at the end of this Code under “Reporting Violations”.

 

POLICY STATEMENT

BRIBERY AND CORRUPTION

Adenza conducts its business ethically with zero tolerance for corruption or bribery. Adenza never accepts, requests, or offers anything of value, such as cash, gifts, discounts or contributions, to obtain or retain business, influence a decision or gain an advantage. Supplier must conduct its business consistent with this approach.
Supplier must comply with anti-bribery and anti-corruption laws wherever it does business, including but not limited to the United States Foreign Corrupt Practices Act (“FCPA”) and the United Kingdom Bribery Act 2010 (“UKBA”). Supplier must not accept, request, or offer anything of value to obtain or retain business, influence a decision or gain an advantage for, or in connection with its relationship with, Adenza.

COMPLIANCE WITH LAWS

Supplier must conduct its business activities in compliance with laws and regulations, including but not limited to all fair competition and antitrust laws, rules and regulations.

Supplier must not make any contributions to political candidates on Adenza’s behalf.

CONFLICTS OF INTEREST

Adenza expects that business conducted by Suppliers is done in good faith and at arm’s length. Conflicts of interest between Supplier and Adenza, or the appearance thereof, should be avoided. When an actual, potential or perceived conflict of interest occurs, that conflict must be disclosed, in writing, by Supplier to a person in authority at Adenza other than the person who has the relationship with Supplier. If Supplier has concerns about any situation, contact Adenza as provided in the Section on “Reporting Violations”.

EXPORT CONTROLS AND SANCTIONS

Supplier must comply with all applicable trade restrictions, export controls, trade embargoes, economic sanctions and boycotts imposed by the U.S. government and any other government with authority over its business. This involves avoiding participation in certain business activities in specified countries, and with specified individuals and entities.

MODERN SLAVERY AND HUMAN RIGHTS

Adenza is committed to ensuring that its supply chain is free from modern slavery.
Modern slavery is a crime and a violation of fundamental human rights. Adenza expects Suppliers to respect the human rights of their personnel and to comply with all relevant laws relating to human rights. Supplier must not be involved in any form of human trafficking and must prohibit the use of all types of forced labor and slavery. Suppliers must provide a safe working environment and adhere to all applicable federal, state and/or international minimum labor standards and fair employment practices, including but not limited to practices related to discrimination, harassment, and worker safety. Suppliers should respect the right to free association and collective bargaining.
Suppliers should ensure that child labor is not used in the provision of Supplier’s goods and services and that its personnel are paid wages that meet legally mandated minimums.
Supplier is expected to treat its personnel fairly and with dignity. Supplier must prohibit all discrimination on the basis of a protected activity or other status or classification protected by applicable law, including, without limitation, race, color, ancestry, national origin, religion, age, disability, sex, gender, sexual orientation, gender identity, gender expression/characteristics, medical condition, genetic information, marital status, and/or military and veteran status.

ENVIRONMENT

Adenza expects Supplier to support sound environmental management principles and reduce Supplier’s impact on the environment within which Supplier operates. Supplier must comply with all laws relating to the protection of the environment which relate to Supplier’s business. Suppliers are expected to have a written sustainability/environmental policy appropriate to the size and nature of Supplier’s operations.

COMPLIANCE WITH THIS CODE

Adenza may audit compliance with this policy or appoint a third party to conduct an audit. It is the intention of Adenza to discontinue its relationship with Suppliers who do not comply with this Code or, upon discovery of noncompliance, do not commit to a specific plan to achieve compliance.

REPORTING VIOLATIONS

Options to report violations include the following: