Ensuring Ethical Business Practices
Introduction
Simeio Solutions, LLC and its affiliates (“Simeio”) are committed to promoting corporate integrity, transparency, responsible product sourcing, and the safety and wellbeing of workers across the global supply chain. These principles apply to all aspects of Simeio’s business, and encompass all manufacturers, distributors, vendors, and other suppliers that provide services or products to or otherwise do business with Simeio (each a “Supplier” and collectively “Suppliers”).
This Supplier Code of Conduct (“Code of Conduct”) addresses various ethical concerns and establishes the minimum standards that must be met by Simeio’s Suppliers regarding:
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- the Supplier’s treatment of workers;
- workplace safety;
- the impact of the Supplier’s activities on the environment; and
- the Supplier’s ethical business practices.
Applicability
This Code of Conduct applies to all Suppliers that provide services or products to or otherwise do business with Simeio. Every Supplier is responsible for compliance with the standards set out in this Code of Conduct (“Standards”) throughout its operations and throughout its entire supply chain.
Without limiting the Supplier’s obligations hereunder, each Supplier must comply with the Standards in all aspects of its business practices. Each Supplier in turn is responsible for compliance with the Standards by all of its suppliers, vendors, agents, and subcontractors and their respective Facilities (“Partner(s)”).
Human Rights and Social Sustainability
Suppliers must conduct all operations in a socially responsible, non-discriminatory manner and in full compliance with applicable laws including, but not limited to, those associated with Equal Opportunity, Child Labor, Forced or Compulsory Labor, Working Hours, Compensation, Freedom of Association, Collective Bargaining, and Harassment Free Work Environment.
Slavery, Child Labor, and Human Trafficking
All labor must be voluntary. Suppliers must adhere to all applicable laws regarding labor practices and must not engage in or condone slavery, forced labor, human trafficking, or child labor in any part of their supply chain. All employees should be treated with respect and provided with safe working conditions, fair wages, and the freedom to work voluntarily.
Without limiting the Supplier’s obligations hereunder, Suppliers must not, and must ensure that its Partners do not, support, engage in, or require any:
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- compelled, involuntary, or forced labor;
- labor to be performed by children;
- bonded labor;
- indentured labor; and
- prison labor.
Health and Safety
Suppliers must provide a safe, healthy, and sanitary working environment and implement procedures and safeguards to prevent workplace hazards and work-related accidents and injuries.
Discrimination and Harassment
Suppliers must ensure equal employment opportunities without discrimination or harassment on the basis of race, color, religion, creed, age, sex, sex stereotype, gender, gender identity or expression, transgender, sexual orientation, national origin, citizenship, disability, marital status, pregnancy, veteran or military service status, genetic information, or any other characteristic protected by law. Harassment, whether verbal, physical, or psychological, will not be tolerated, and Suppliers must take proactive steps to promote a respectful and inclusive environment.
Freedom of Association and Collective Bargaining
Suppliers must respect, and must not interfere with, the right of workers to decide whether to lawfully associate with groups of their choice, including the right to form or join trade unions and engage in collective bargaining.
Environmental Responsibilities
Simeio recognizes the critical importance of a healthy environment to our global society, our economy, our business and our people. Suppliers are expected to actively minimize their environmental impact, including, but not limited to, reducing waste, conserving energy, and promoting sustainable practices. Suppliers should continuously seek ways to improve their environmental performance.
Ethical Business Practices
Suppliers are required to comply with both the letter and spirit of all laws, rules, regulations, and regulatory guidance that would be applicable to Simeio if Simeio were providing the goods and services, including those laws, rules and regulations addressing corruption, kickbacks, bribery and other prohibited business practices.
Conflicts of Interest
Suppliers must avoid any situations in which personal interests may conflict with professional responsibilities. A conflict of interest occurs when a Supplier’s activities, relationships, or financial interests unduly influence their ability to act impartially. Suppliers, their employees and their family members cannot receive improper benefits through their relationship with Simeio or allow other activities to conflict with acting in the best interests of Simeio. All potential conflicts must be disclosed promptly to ensure transparency and avoid compromising decision-making processes.
Bribery and Anti-Corruption
Simeio does not tolerate bribery or corruption in any form. Suppliers are forbidden from offering, promising, authorizing, recommending, giving, receiving, or soliciting, directly or indirectly, anything of value to any person or entity if it is intended, or could reasonably appear as intended, to influence improper action, obtain or retain business, or secure an improper advantage for Simeio. All transactions must be conducted fairly and transparently, with zero tolerance for unethical behavior.
Material Non-Public Information (MNPI) and Insider Trading
Suppliers with access to Simeio’s confidential information should not disclose such information to any other person without Simeio’s advance written consent. Unless otherwise documented in an agreement between the Supplier and Simeio, Simeio expects Suppliers to comply with applicable federal securities laws which govern insider trading. Federal laws prohibit the purchase or sale of securities by any entity or individual possessing material non-public information (“MNPI”) which includes without limitation information they possess as a result of their association with Simeio, related to that security or proprietary funds and accounts. Accordingly, Suppliers and their employees must keep MNPI confidential and may not buy or sell shares or other securities, derivatives or financial instruments relevant to such information until the information becomes public or is no longer material. Advising others to trade in a security while in possession of MNPI is also a violation of federal securities laws and is prohibited.
Partner Responsibilities
Suppliers are responsible for ensuring that their own suppliers, subcontractors, and service providers have practices and policies that are substantially compliant with these Standards. Suppliers are expected to notify Simeio of any non-compliance and provide any information requested by Simeio to evaluate the risk and monitor as needed.
Monitoring and Compliance
Simeio values strong, transparent partnerships with its Suppliers and encourages open communication to support ongoing compliance with this Code of Conduct. Simeio reserves the right to audit Suppliers upon provision of reasonable notice, conducting periodic reviews, discussions, or assessments to better understand, ensure, and support compliance efforts. In some cases, this may involve sharing best practices or requesting relevant documentation.
Simeio encourages its Suppliers to implement their own binding guidelines for ethical behavior. Simeio reserves the right to discontinue any relationship with a Supplier that does not adhere to this Code of Conduct.
Reporting Violations
Simeio values the help of those who identify and speak up in good faith about potential violations and concerns that need to be addressed or explained. Any concerns or observed potential violations of this Code of Conduct should be reported immediately to dl-gc@simeio.com. Simeio does not retaliate nor permit retaliation against anyone who makes a good faith report about any potential violation. Simeio is committed to investigating reports thoroughly and taking appropriate action to address any breaches of conduct.