About this Supplier Code of Conduct
Seabras Group LLC and its’ subsidiaries (collectively, “Seaborn” or “Company”) has established this Supplier Code of Conduct (“Supplier Code”) to provide its agents, consultants, contractors, suppliers, vendors and other business partners (collectively, “Suppliers”) with whom we do business our expectations as to how Suppliers should conduct their business to ensure the highest standards of integrity and compliance with the law, and to follow the principles set forth in this Supplier Code.
This Supplier Code contains general requirements applicable to all Seaborn Suppliers. Individual Supplier agreements may have more specific provisions addressing some of the same issues covered in this Supplier Code. Nothing in this Supplier Code will supersede any more specific provision in a particular agreement, and if there is any conflict between the two, the agreement will control unless applicable law requires otherwise.
This Supplier Code should be read in conjunction with Seaborn’s Code of Business Conduct and Ethics, which can be found at https://seabornnetworks.com/compliance/code-of-business-conduct-and-ethics/ and Human Rights Policy which can be found at https://seabornnetworks.com/compliance/human-rights-policy/. Suppliers are responsible for ensuring that this Supplier Code is communicated and understood by their employees, agents, subcontractors and representatives doing business with or on behalf of Seaborn.
Core Unifying Values
Seaborn depends on its reputation for quality, service and integrity. The Company is committed to the highest standards of ethics and business conduct in all our relationships, whether with employees, directors, shareholders, customers, associates, suppliers, competitors, or the communities in which we operate and the environment we share.
Seaborn selects our Suppliers based not only on the quality and cost of their services, but also their commitment to high standards of integrity and ethical business conduct. We fully expect those working on the Company’s behalf, including Suppliers, to adhere to Seaborn’s ethical standards.
- Human Rights and Fair Employment Practices
The protection of human rights is a core Seaborn value and critical to the successful operation of our business and we expect our Suppliers to share our commitment by complying with our Human Rights Policy, which can be found at https://seabornnetworks.com/compliance/human-rights-policy/. Seaborn requires its’ Suppliers to comply with applicable laws and regulations regarding non-discrimination and fair treatment in its employment practices. We expect our Suppliers to share our values of respecting and promoting a diverse and inclusive work culture, where each employee is respected, valued and treated fairly.
1.1 Safe and Healthy Work Environment
Suppliers must provide a safe and healthy work environment to minimize risk of accident and injury. Suppliers must require its employees, agents, vendors and subcontractors to comply with all applicable safety and health laws and regulations.
1.2 Non-Discrimination and Anti-Harassment
Seaborn requires Suppliers to comply with all applicable laws regarding discrimination in their hiring and employment practices. The Company expects Suppliers to provide a respectful and professional workplace that is free from acts or threats of violence, harassment or discrimination. Suppliers must ensure equal opportunities and treatment of employees without regard to race, religious creed (including religious dress and grooming practices), color, national origin, ancestry, physical disability, mental disability, medical condition, genetic information, marital status, sex (including pregnancy), gender, gender identity (including transgender identification), gender expression, age, sexual orientation, military and veteran status of any person, or any other category made unlawful by applicable law. Suppliers must also prohibit unacceptable treatment of individuals, including sexual harassment or bullying.
1.3 Wages, Benefits and Working Hours
Suppliers must pay their employees fair wages and comply with applicable wage and benefit laws, including minimum wage laws, legally mandated benefits and working hours regulations.
1.4 Slavery, Forced Labor and Human Trafficking
Suppliers must not permit any form of force or involuntary labor of any kind in any location in which it operates. Supplier must prohibit the use of all forms of forced labor and must not use any vendors, subcontractors or business partners who engage in forced labor, whether directly or indirectly. The Company requires its’ Suppliers to comply with all applicable slavery, forced labor and human trafficking laws and legal conventions.
1.5 Child Labor
Suppliers must not employ any child labor and must take necessary steps to ensure that their vendors, business partners and subcontractors do not utilize child labor. Suppliers must comply with all applicable working age laws and regulations.
1.6 Freedom of Association
Seaborn respects the legal rights of workers including the rights to freedom of association and to engage in collective bargaining. Suppliers must recognize employee rights to join trade unions and to bargain collectively in accordance with applicable laws and neither disadvantage nor prefer members of employee organizations or trade associations.
- Ethical Business Practices
Seaborn is committed to operating its business in accordance with the highest ethical standards and in compliance with all applicable laws, rules and regulations. The Company expects Suppliers to comply with the Company’s Code of Business Conduct and Ethics to ensure that its employees, business partners, suppliers, agents and subcontractors understand and adhere to these standards, as applicable.
2.1 Anti-Corruption Laws,
Suppliers must comply with the U.S Foreign Corrupt Practices Act, Brazil’s Anti-Corruption Law (#12.846/2013), as amended and Decree #8.420/15, the U.K. Bribery Act and all applicable anti-corruption laws. Anti-Corruption laws prohibit, among other things, bribery of government officials or agents, directly or through intermediaries, for any business- related purpose. Suppliers must scrupulously adhere to these laws and not engage directly or indirectly in any form of corruption or bribery and must never give, grant, offer or promise anything of value to any government official or agent or to a counterparty in the private sector to influence official action or obtain an improper advantage.
2.2 Anti-Trust and Fair Competition Laws; Unfair Business Practices
Supplier must respect and comply with all applicable anti-trust and fair competition laws. Suppliers must ensure that they never engage in any activity that may restrain trade or reduce competition. Suppliers must not take unfair advantage of others through manipulation, concealment, abuse of privileged information, misrepresentation of material facts or any other unfair dealing practice.
2.3 Export Control and Sanctions
Supplier must comply with all applicable sanctions and trade embargoes. Suppliers must not engage in any transactions, including providing goods or services to, or acquiring goods or services from, any individuals against whom, or entities or jurisdictions against which the United States government has imposed sanctions.
2.4 Privacy and Data Protection
Supplier must comply with all applicable privacy, data protection and information security laws and regulations. Supplier must provide reasonable protections for personal, proprietary and confidential information.
2.5 Gifts and Entertainment
Seaborn’s Code of Conduct and Business Ethics requires the undivided loyalty of its employees to the interests of the Company. Suppliers must not, directly or indirectly, offer to any Seaborn employee money, goods or services as a consideration or expectation of a favorable outcome, decision, recommendation or any other form of favoritism which creates a conflict of interest or qualifies as corruption. Gifts and entertainment must be appropriate, lawful and in line with Seaborn’s Code of Conduct and Business Ethics.
- Environment and Sustainability
Seaborn is committed to principles of environmental compliance and sustainability, and encourages Suppliers to reflect the same commitment in its operations by adhering to responsible and best environmental practices. Suppliers must comply with applicable environmental laws and regulations. Suppliers are encouraged to track energy usage, endeavor to reduce greenhouse gas emissions and promote renewable energy use.
- Reporting Supplier Code Violations
Suppliers are encouraged to report potential or actual violations of this Supplier Code and any other legal or ethical concern. To report a violation involving Seaborn, immediately contact the General Counsel or Chief Financial Officer, or sending an email to Compliance@seabornnetworks.com.
Seaborn does not tolerate any retaliatory action against any person who makes a good faith report of a violation of this Supplier Code. (Retaliation is broadly defined to include conduct that intimidates, coerces, penalizes, or otherwise discriminates against a person because they have made or attempted to make a complaint or have participated in the investigation of a complaint.)