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Supplier Code of Conduct
Standards of conduct for subcontractors and suppliers


Preamble
This Supplier Code of Conduct (“Code”) reflects the standards of conduct required of subcontractors and suppliers (collectively “Suppliers”) of Storage Strategies, Inc. (“SSI”) in the delivery of services to SSI and/or its ultimate customers, including the United States Government (“Government”).  The terms and conditions herein are in addition to, and are not intended to conflict with or modify, the terms and conditions of any subcontract, purchase order or other applicable agreement (“Agreement”).  In the event of any conflict, applicable law or regulation shall take precedence, followed by the terms and conditions of any applicable Agreement (including other attachments thereto), followed by the terms of this Code.


1. Compliance with Law
Supplier will fully comply with all applicable laws and regulations, including local laws and regulations outside the United States where the Supplier conducts business or maintains a place of business. 


2. Records
SSI expects transparency from itself and all levels of its supply chain.  Supplier will create and maintain complete and accurate records and not alter any records to conceal or misrepresent the underlying transaction to which the record pertains.  Supplier should retain records based on its applicable retention requirements, provided that if Supplier is ultimately performing for SSI under a US Government contract, Supplier shall comply with the requirements stated in FAR 4.703 as well as the applicable requirements of the customer agency and any relevant National Archives and Records Administration applicable to that agency.


3. Human Rights
Supplier is expected to treat all people with respect, encourage diversity, promote equal opportunity for all, and foster an inclusive and ethical culture.


a. Child Labor:  Supplier will ensure that illegal child labor (as that term is defined in the location where the work is to be performed) is not used in the performance of work on behalf of SSI.

 
b. Combatting Trafficking in Persons: Supplier shall comply with applicable regulations prohibiting human trafficking including, without limitation FAR 22.17 and all applicable local laws in the countries in which Supplier conducts business.  The following activities are prohibited:

  • Destroying, concealing, or confiscating identity or immigration documents; and

  • Using misleading or fraudulent tactics in recruiting; and

  • Charging recruitment fees or providing inadequate housing based on local standards, laws, and directives; and

  • Failing to provide employment contracts and documentation in the employee’s native language; and

  • Failing to provide return transportation at the end of employment in the case of employees brought in-country for the purpose of working directly or indirectly on a Government contract; and

Supplier shall educate employees on prohibited activities, discipline employees who violate applicable law, and notify the contracting officer of violations and action taken against employees responsible for such violations.  Supplier shall also notify SSI of violations under an SSI contract.


4. Employment Practices
Supplier will ensure its employees are afforded an employment environment free from physical, psychological, and verbal harassment, or other abusive conduct.  Supplier will provide equal employment opportunity to all employees and candidates for employment without regard to any legally protected characteristic.  Supplier will also maintain a workplace free from illegal use, possession, sale, or distribution of controlled substances.


5. Anti-corruption
Supplier shall comply with the anti-corruption laws, directives and regulations that govern operations in the countries in which they do business, including without limitation the US Foreign Corrupt Practices Act and the UK Bribery Act.  Supplier is required to refrain from offering or making, or authorizing or enabling any third party to offer or make on Supplier’s behalf, any improper payments of money or any other thing of value to government officials, political parties, or candidates for public office.  Facilitating payments, intended to expedite or ensure performance of routine governmental actions, are also prohibited regardless of whether they are permitted under local law.  We expect Supplier will conduct appropriate due diligence to prevent and detect corruption in its business arrangements and contracts.


6. Business Courtesies
The exchange of business courtesies may not be used to advance any improper purpose or obtain an unfair competitive advantage.  Supplier must ensure that the offering or receipt of any gift or business courtesy is permitted by law and regulation, and that these exchanges do not violate the rules and standards of the recipient’s organization and are consistent with reasonable marketplace customs and practices.


7. Anti-trust
Supplier must not participate in price fixing, bid rigging or cartel activity, nor exchange current, recent or projected pricing information or other sensitive or non-public information (“Protected Information”) with competitors.  Similarly, supplier must not share with SSI the Protected Information of its competitors except as authorized by the owner of the information.


8. Insider Trading
Supplier and its personnel must not use material non-public information obtained in the course of our business relationship as the basis for trading or for enabling others to trade in the securities of our company or any other company.


9. Money-Laundering
Supplier shall maintain appropriate mechanisms to ensure neither it nor its employees use Supplier’s relationship with SSI to disguise the sources of illegally obtained funds.


10. Conflict of Interest
Supplier must avoid all actual or apparent conflicts of interest in its dealings with SSI.  We expect Supplier to notify SSI in the event of any circumstances or interests that give rise to that any such conflict, whether organizational or personal (including interests of employees or their close relatives, friends or associates) in nature.


11. Confidential and Proprietary Information Protection and Security
Supplier will properly handle, store and secure sensitive information such as confidential or proprietary information or personally identifiable information.  Supplier shall comply with applicable data privacy laws.  Supplier is expected to utilize appropriate physical and electronic security measures to protect such information against unauthorized access, use, destruction, modification or disclosure and ensure compliance with DFARS clause 252.204-7012 – “Safeguarding Covered Defense Information” when applicable. Such information should not be used for any other purpose than the specific business purpose for which it was provided.


12. Intellectual Property Protection
Supplier is expected to comply with all laws governing use, disclosure and protection of intellectual property, including patents, copyrights, trademarks and service marks.


13. Environmental Health and Safety
We expect Supplier to comply with all applicable environmental, health, and safety laws, regulations and directives, and to protect the health, safety and welfare of its employees and other impacted individuals or entities.


14. Trade Compliance
a. Import/Export:  Supplier is expected to ensure its business practices are in accordance with all applicable laws, regulations, and directives governing the import or export of parts, components, technical data and defense items or services, including the requirement to register with the U.S. State Department’s Directorate of Defense Trade Controls if Supplier is either a manufacturer or an exporter of defense articles.


b. Anti-boycott:  Consistent with the requirements of the 1977 Export Administration Act and the 1976 Tax Reform Act, Supplier must not participate in, cooperate with, submit to or otherwise further the cause of any unsanctioned boycott.


c. Conflict minerals:  Supplier will have appropriate due diligence processes in place to allow SSI to meet its obligations to report or certify as to the use of conflict minerals that may have originated in the Democratic Republic of the Congo or adjoining country.


15. Counterfeit Parts
Supplier will comply with DFARS 252.246-7007 as applicable.  Supplier will develop, implement, and maintain policies, procedures and methods to detect and avoid counterfeit electronic parts.  Supplier will promptly notify SSI and recipients of counterfeit parts when appropriate.  Supplier will hold those in its supply chain accountable for the same obligations with respect to work performed for SSI.


16. Ethics Program
We expect Supplier to comply with FAR 52.203-13 as applicable and, commensurate with the size and nature of its business, to have effective systems in place to comply with laws, regulations and the standards set forth in this Code.  We encourage Supplier to implement its own written code of conduct and flow down the principles of that code to its suppliers and subcontractors.  Additionally, we expect Supplier to provide employees reasonable avenues to raise legal or ethical concerns without fear of retaliation and take preventative or corrective action when warranted.


17. Audit and Enforcement
We expect Supplier will implement and maintain measures to audit its compliance with these standards and to take appropriate corporate or personnel action to correct identified deficiencies.


18. Consequences for Violating Code
SSI reserves the right to pursue corrective action to remedy any violation of any of these standards.  In the case of a violation of law or regulation, SSI may be required to report such violations to the proper authorities