Promotastic Supplier Code of Conduct

Last Updated July 17, 2024

At Promotastic, we hold ourselves to the highest standards of ethics and integrity, and we expect the same from our vendors, suppliers, contractors, and business partners (collectively, “Suppliers”). This Supplier Code of Conduct (“Code”) outlines our minimum requirements and expectations, and is designed to complement each Supplier’s own policies, legal requirements, and agreements with Promotastic.

Compliance with Laws

Suppliers must comply with all applicable laws and regulations in the jurisdictions where they operate.

Human Rights and Labor

Promotastic is committed to human rights and equal opportunity. We expect our Suppliers to:

• Freely Chosen Employment and Combating Modern Slavery: Prohibit any form of forced, bonded, or indentured labor, and comply with laws against compulsory labor and human trafficking.
• Working Hours, Wages, and Benefits: Ensure fair compensation, working hours, and benefits as per applicable laws.
• Humane Treatment and Non-Discrimination: Maintain a workplace free from harassment and unlawful discrimination.
• Health and Safety: Adhere to all health and safety laws, regulations, and best practices.

Ethics and Compliance

Suppliers are expected to uphold high ethical standards, promoting honesty and integrity, including:

• Business Integrity: Avoid corruption, extortion, embezzlement, and bribery. Comply with anti-money laundering and anti-corruption laws, including the U.S. Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act.
• Intellectual Property: Respect the intellectual property rights of Promotastic and others, including copyrights, patents, trademarks, and trade secrets. Do not use the Promotastic brand or trademarks without written permission.
• Privacy and Information Security: Comply with all relevant privacy and information security laws when handling personal information.
• Accurate Books and Records: Ensure all business dealings are transparently conducted and accurately reflected in company records.
• Gifts and Entertainment: Refrain from giving or receiving personal gifts, fees, or entertainment that could influence business decisions. Any gifts to Promotastic employees must comply with our Code of Business Conduct.
• Personal Relationships: Disclose any known family or close personal relationships with Promotastic employees or directors involved in the engagement.

Environmental Responsibility

Promotastic values environmental sustainability. Suppliers should evaluate their environmental impact, comply with environmental laws, and operate in a manner that protects the environment and human health.

Confidentiality

Suppliers must safeguard Promotastic’s confidential information, which includes all non-public information that could benefit competitors or harm Promotastic if disclosed. Confidential information should only be used for legitimate business purposes and disclosed only when authorized or legally required. Further restrictions may be outlined in agreements with Promotastic.

Speak Up

For questions or concerns about this Code or your relationship with Promotastic, please contact your Promotastic business representative or the procurement team at partnership@promotastic.co.

Compliance and Updates

Promotastic reserves the right to review compliance with this Code and may suspend or terminate relationships with Suppliers found in breach. We may update this Code at our sole discretion.

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