Vendor Code of Conduct

UPDATED: July 2, 2019

The Vendor Code of Conduct (COC) outlines the expectations of vendor resources providing services or goods to ClickDimensions, LLC (“ClickDimensions” or “Company”). This COC applies globally to the engagement and execution of activities with all vendors. For purposes of this COC, a vendor is defined as an external third-party that the Company has entered into a contractual relationship with to provide business goods, services, functions or activities.

ClickDimensions is committed to conducting business in a legal, ethical and responsible manner and requires that our approved vendors work at the same high level of standards. The ClickDimensions Vendor Management COC sets out the principles, guidelines and expectations we have of our vendors in conducting business responsibly and with integrity. In addition, ClickDimensions vendors are expected to fully comply with the laws and regulations of the countries in which they operate.

ClickDimensions requires all vendors to comply with the COC. Where the COC may conflict with the terms of a vendor contract, the contract terms will prevail. Further information regarding monitoring and compliance is found later in this document. Vendors are expected to enforce the COC with their employees and any sub-contractors.

Vendors should contact ClickDimensions at Accounts.Payable@ClickDimensions.com with any questions or concerns related to the COC. ClickDimensions values the contribution its vendors make to the success of the company and building mutually beneficial client-vendor relationships.

All Vendors and their employees must adhere to this COC while conducting business with, or on behalf of, ClickDimensions. Vendors must promptly inform their ClickDimensions Vendor Manager when any situation or circumstance develops that causes, or reasonably might expect to cause, the vendor, or a vendor employee, to be in violation of this Code. ClickDimensions vendors are expected to self-monitor their compliance with this COC. ClickDimensions may audit vendors or their facilities at any time in accordance with the vendor contract, to confirm compliance with this COC. Terms for COC non-compliance may generally be covered within individual contractual agreements. Penalties for non-compliance may include, but not be limited to:

• Immediate removal from ClickDimensions account;
• Vendor account sanctions- These may include barring engaging on new SOWs for periods up-to 90 days; repeated account sanctions may lead to vendor dismissal from ClickDimensions; permanent embargo from doing business with ClickDimensions.

At any time, ClickDimensions may require the vendor to participate in training on this COC.

Ethical Dealings

• Vendors will operate with integrity, in an ethical manner and in compliance with all applicable laws, rules and regulations applicable to their industry and place of business. Vendors will not engage in bribery, corruption, embezzlement, extortion, kickbacks, excessive commission, inducements or fees and any other prohibited business
• Vendors are expected to:
• Comply with applicable laws, including trade and export/import laws and regulations;
• Comply with applicable privacy and data laws, including data exportation/importation laws and regulations;
• Comply with antitrust laws and fair competition laws that govern the jurisdiction in which they conduct business;
• Not represent themselves as employees of ClickDimensions;
• Not use ClickDimensions’ trademarks, intellectual property or confidential information without prior authorization from ClickDimensions;
• Not disclose its relationship with ClickDimensions without prior authorization from ClickDimensions, excluding cases where permitted under the applicable vendor agreement, or where required by law, regulation or to comply with an active law enforcement investigation;
• Not utilize social media in any way where the activity may adversely impact ClickDimensions’ reputation, analytic impartiality or create an actual or potential conflict of interest, or any appearance of a conflict, with ClickDimensions.

Data Security and Confidentiality

• Vendors will handle and process data only for the purposes for which it was collected or otherwise made available. Vendors shall demonstrate appropriate industry standard and best practices data security controls to ensure that all information is protected and secure from damage and unauthorized.
• In addition to the above minimum requirements, vendors shall follow any data security requirements specified in contractual agreements with ClickDimensions.
• Vendors must respect and maintain the confidentiality of all non-public information about ClickDimensions or its activities and all non-public information obtained in the performance of the employee’s duties about ClickDimensions’ customers, clients or applicable third parties. For example: (a) employees or members of their families possessing non-public information regarding studies or pending negotiations by ClickDimensions to acquire all or part of a company shall not divulge such information to other persons and shall not trade in the securities of such a company unless and until the studies or negotiations have been permanently terminated or completed by ClickDimensions; and (b) employees obtaining material non-public information about another company or securities shall not trade in the securities of such other company until such non-public information becomes publicly.
• Vendors will immediately notify ClickDimensions of any known or suspected data security breaches and will work with ClickDimensions and, if applicable, law enforcement to contain the breach and determine a root.

Vendors shall comply with all relevant laws and regulations in all locations in which they operate.

ClickDimensions is committed to developing an organizational culture which implements a policy of support for internationally recognized human rights and labor standards. All ClickDimensions’ vendors must conduct their employment practices in full compliance with all applicable laws and regulations.

Child Labor

• Vendors will not use child labor. The minimum age for employment will be the greater of (i) the minimum age under local law, (ii) the minimum age pursuant to the Convention Concerning Minimum Age to Employment adopted by the International Labor Organization or (iii) 15.
• Workers below the age of 18 should not be involved in activities likely to jeopardize their health, safety or morals or interfere with their compulsory.
• Vendors may be required to disclose any workers under the age of 18 and detail the specifics of their job functions, including what, if any, support they may be providing to ClickDimensions.

Involuntary Labor

• Vendors will not use any forced, compulsory or involuntary labor, whether bonded, indentured, or voluntary labor, whether bonded, indentured, or imprisoned.
• Employees shall be able to terminate their employment within reasonable notice.

Non-Discrimination

• Vendors will not discriminate on the basis of race, religion, age, nationality, social or ethnic origin, disability, sexual orientation, gender, gender identity, marital status, veteran status or political affiliation, in its hiring or employment practices; such as, compensation and benefits, access to training, promotion, termination and retirement.

Wages, Benefits and Working Hours

• Vendors will comply with applicable wage and working hour laws and regulations, including those relating to minimum wages, overtime, maximum hours and legally mandated benefits.

Fair Treatment

• Vendors will treat employees with dignity and respect. Physical abuse, the threat of physical abuse, sexual or other harassment, verbal abuse or any other form of intimidation are prohibited.
• Vendors will not retaliate against employees who report abuse, discrimination, ethical concerns or violations of law.

Work Environment

• Vendors will provide employees with a safe and healthy workplace in compliance with all applicable laws and regulations. Vendors will take adequate steps to prevent accidents and injury to health at work including providing workers with appropriate workplace health and safety information and.

Sanitation, Fire and Water

• Vendors will provide clean toilet facilities, access to clean water, and adequate heat and ventilation.
• Vendors will ensure physical facilities where employees work from have sufficient fire prevention, alert and suppression systems, including having sufficient facility exit points for escape.

Emergency Preparedness and Response

• Vendors will identify and assess emergency situations and minimize their impact by having adequate emergency preparedness plans and response procedures to ensure their employees’ health and safety. Specifically, vendors that operate from high-rise buildings (75 feet or higher) are to maintain fire and emergency building evacuation procedures.
• Vendor will maintain and provide an accurate copy of its disaster recovery plan and business continuity plan in connection with the Services that is in accordance with industry-standards. Where applicable, vendors will at a minimum test annually their fire, emergency, continuity, disaster recovery or other contingency plans.

Protection of the Environment

• Vendors will comply with all applicable environmental laws and regulations.
• Vendors are expected to operate in an environmentally responsible manner and strive, as far as practical, to manage and minimize negative environmental impact including use of energy, greenhouse gas emissions, water, biodiversity, waste, hazardous materials and other natural resources.

Environmental Management System

• Vendors will continually evaluate the need for an environmental management system detailing the process of managing their environmental impacts and implement as appropriate.

Expected of Vendors

• Vendors may contact ClickDimensions with any questions or concerns related to this COC. ClickDimensions offers a site is hosted by a third-party provider, Navex, and accessible at https://clickdimensions.ethicspoint.com Through this site, you are able to submit reports relating to actual or suspected violations of the Vendor Code of Conduct.
• ClickDimensions will communicate the COC internally and externally to relevant parties. Vendors are responsible for communicating the provisions of this COC to their employees, suppliers and any sub-contractors.
• Where appropriate, relevant training and guidance will be given to employees of vendor to support implementation of this.

Expected of ClickDimensions

• Vendors will treat ClickDimensions – and expect to be treated by ClickDimensions- with respect and have open and honest communications.
• ClickDimensions will maintain a fair climate for our vendors.