Vendor Code of Conduct

Intrado seeks to operate in a socially, environmentally, and ethically responsible manner, and expects the same of its vendors. The conduct of Intrado’s vendors may significantly impact or reflect on Intrado and its investors, employees, and other stakeholders. Therefore Intrado extends these expectations and commitments to its vendors, their products, services, and business operations, as stated below.

  1. Application of this Code
    This Vendor Code of Conduct (“Code”) sets out the standards and requirements for all vendors of goods and services to Intrado (each, a “Vendor”). Subcontractors engaged by vendors to provide goods or services to Intrado must be made aware of the Code, and the conduct of subcontractors is the responsibility of the contracting Vendor.

  2. Employment and Working Conditions
    Intrado seeks to foster sound labor practices in accordance with UN Global Compact Principles 1-5 and other international conventions on human rights. The same is expected of Vendors by adhering to the below requirements:

    • Modern slavery, human trafficking, and forced labor: Intrado opposes slavery, forced labor, and human trafficking in any form. Vendors must not use or permit any form of forced, bonded or indentured labor, nor unreasonably restrict workers’ freedom to move into, out of or within working facilities. Vendors must take all reasonable steps to ensure that any goods or services obtained from their upstream vendors are not manufactured by forced or indentured labor – to this end, Vendors are expected to have procedures of their own (such as precertification and prequalification questionnaires, rights of site inspection and audit, and other vendor diligence requirements) to identify, prevent and mitigate occurrences of modern slavery or other human rights abuses.
    • Child labor: Vendors must never use child labor and must only use workers who meet the minimum legal age for employment, in no event less than 15 years old. Our vendors must ensure that workers under the age of 18 do not perform work that is likely to jeopardize their health or safety, other than as allowable under local laws with required training and safety (such as trained apprenticeships or trade employment).
    • Human rights: Vendors are to enact policies and practices conducive to maintaining a respectful and safe workplace, free from physical violence, threats, punishment, mental coercion, bullying and harassment, or other forms of abuse or inhumane treatment.
    • Freedom of association: Vendor employees and representatives must be free to join organizations of their own choice. Vendors must respect and recognize the right of employees to join and organize associations of their own choosing, and to bargain collectively in accordance with local laws.
    • Compensation, hours, and employment laws: Vendors must not require workers to work more than the regular and overtime hours permitted by applicable laws, and must comply with all laws regarding wages. Temporary, contract or other forms of itinerant or outsourced labor must comply with local laws.

  3. Employee Health and Safety
    Vendors should adhere to the following requirements:

    • Comply with all applicable health and safety laws and regulations. Intrado expects vendors to adopt practices to minimize health and safety risks, support accident prevention, and ensure a safe workspace for all workers.
    • Provide employees with essential amenities, including free drinking water, clean bathrooms, rest areas, and sanitary eating areas.

  4. Legal and Ethical Standards, Sanctions, and Conflict Minerals
    Vendors must adhere to the following requirements:

    • Obey all relevant laws relating to the prevention of bribery, corruption, fraud, tax evasion or other activities (e.g., U.S. Foreign Corrupt Practices Act, UK Bribery Act etc.), and not engage directly or indirectly in trade activities or include in the supply chain any goods or services sourced from sanctioned persons or countries;
    • Avoid actual and potential conflicts of interest;
    • Respect and protect intellectual property rights;
    • Maintain a policy and process for the reporting of workplace concerns, which is transparent and understandable, and protects reporting individuals from actual or fear of retaliation; and
    • Maintain a policy and process to ensure that any tin, tungsten, tantalum, gold, or cobalt manufactured, used or procured directly or indirectly were not sourced from or near the Democratic Republic of Congo or other regions designated as a Conflicted-Affected and High- Risk Area under Regulation (EU) 2017/821.

  5. Diversity, Inclusion, and Freedom from Harassment or Discrimination
    Intrado is committed to promoting relationships with diverse and underrepresented businesses in the strategic sourcing and procurement process. Further, Intrado maintains strict anti-harassment and antidiscrimination policies.

    Vendors are expected to adhere to the following requirements in keeping with Intrado’s policies:

    • Use of search and assessment processes that are both unbiased and transparent, ensure that Vendor procurement teams provide diverse businesses with fair access to bids, and promote diversity and inclusion within their own workplaces (including in recruitment, retention and promotion practices).
    • Comply with all applicable laws relating to discrimination in hiring, employment practices, and harassment. Vendors must maintain and implement policies to ensure workplaces are free of discrimination of any kind, including but not limited to age, disability, race, gender, nationality, veteran status, marital status, sexual orientation, religious beliefs, political convictions, or ethnic, national or any other characteristic protected by law. This policy applies to all personnel relationships, including but not limited to: promotions, transfers, training, job assignments, job stations, hours of work, rates of pay, working conditions, terminations, and all terms and conditions of employment.

  6. Environmental Responsibility and Sustainability
    Intrado seeks to reduce the environmental impact of its operations, and expects its Vendors to do the same by complying with all applicable environmental laws and improve the sustainability of their operations (via the reduction of emissions, reducing the consumption of energy, electricity and water, and recycling where feasible).

  7. Data Privacy and Security
    Intrado requires its vendors to protect the privacy of individuals and the security of confidential information by:

    • Ensuring appropriate cybersecurity measures are in place to mitigate against the risk of cyber threats.
    • Designing and maintaining processes to provide appropriate protections for Intrado’s confidential information.
    • Informing Intrado of any material data breach or incident.