Supplier Code of Conduct

Signant Health is committed to the highest standards of integrity and social responsibility, and Signant Health expects all its Suppliers engaged in providing products and services to Signant Health (“Suppliers”) to have, or to make, a similar commitment. Our Supplier Code of Conduct describes Signant Health’s expectations of how its Suppliers conduct business. Signant Health expects Suppliers to act in accordance with this Code of Conduct. In instances where expectations outlined in this Code of Conduct differ from local laws, Suppliers must follow these expectations within the bounds of applicable local laws.

This Supplier Code of Conduct sets forth the minimum standards of business conduct that we expect from all of our Suppliers:

1. Compliance with laws: Suppliers shall comply fully with all applicable laws and regulations within the geographies where they operate and be open and cooperative with the regulators enforcing such laws.
2. Environmental policy: Signant Health expects its Suppliers to demonstrate a clear understanding of the environmental risks, impacts and responsibilities associated with the products and services they provide.

• Suppliers shall have processes in place to ensure that their operations conform to all applicable environmental legislation. All required environmental permits, approvals and registrations are to be obtained, maintained and complied with in accordance with the conditions and requirements defined therein.
• Suppliers shall make practical efforts to minimize the use of energy, water and raw materials.
• Emissions to air that are likely to cause pollution or contribute to climate change shall be monitored, controlled and minimized where possible.
• Suppliers shall make practical efforts to eliminate or reduce levels of generated waste and reuse and recycle waste materials wherever possible. The handling, storage, movement, treatment and disposal of all waste shall be carried out in accordance with applicable regulations and in an environmentally responsible manner.
• Supplier shall endeavor to make continuous improvements in environmental performance through practicable measures and employ leading practices where possible.
• Suppliers shall consider the environmental credentials and performance of vendors within their own supply chain and require them to operate to a minimum set of standards.

Human rights:

• Modern slavery / human trafficking: Signant Health does not tolerate slavery, forced labor, bonded labor or human trafficking in any form. Signant Health requires Suppliers to fully comply with the applicable legal requirements of slavery, forced labor and human trafficking laws and expects Suppliers to enact practices to ensure compliance with such laws.
• Child labor: Signant Health does not tolerate child labor in any form. Suppliers must act in compliance with all laws regulating minimum working age for each position, including any laws pertaining to the employment, apprenticeships, and internships of youths and students.
• Human rights: Signant Health does not tolerate human rights violations in any form. Signant Health expects Suppliers to enact practices to maintain a respectful and safe workplace and not tolerate physical violence, threats, corporal punishment, mental coercion, verbal abuse, disrespectful behavior, bullying or harassment of any kind.

Employment laws:

• All use of permanent, temporary or outsourced labor shall be in accordance with local law.
• At a minimum, the legal minimum wage standard shall be adhered to across the entire workforce, employees shall receive clear information on their wages, and unfair deductions from wages as a disciplinary measure are not permitted.
• Working hours shall be limited according to national or local law. Overtime shall be voluntary, shall not replace regular employment and shall be fairly compensated.
• A safe and hygienic working environment shall be provided with an awareness of any industry-specific hazards. Suppliers are encouraged to adopt practices to minimize health and safety risks and support accident prevention.
• All employees shall be provided with a written employment contract setting out their terms and conditions in accordance with the local relevant legal jurisdiction. We expect all employment and the termination of employment to be carried out in a fair manner.
• Suppliers shall comply with all applicable laws relating to discrimination in hiring, employment practices, and harassment and retaliation. Signant Health expects Suppliers to operate workplaces free of discrimination, harassment, victimization, and any other abuse on any grounds including but not limited to age, disability, ethnic or social origin, gender, gender identity, nationality, race, sexual orientation, marital status, parental status, pregnancy, political convictions, religious beliefs, union affiliation, or veteran status.

Ethics:

• Bribery and anti-corruption: Suppliers shall fully comply with requirements of all applicable bribery and anti-corruption laws (e.g., U.S. Foreign Corrupt Practices Act, UK Bribery Act). Suppliers shall not offer or provide money or anything of value to any person if it is probable that it is given to influence official action or to obtain a business advantage.
• Gifts and entertainment: Suppliers shall not offer any gift to obtain improper advantages or influence for the Supplier. Gifts or entertainment shall never be offered to Signant Health personnel or representatives under circumstances that create the appearance of impropriety.
• Subcontractors: Suppliers shall use only subcontractors or other third parties who comply with all applicable laws and regulations, and who adhere to the same (minimum) standards set forth in this guide.
• Anti-trust and other competition laws: Supplier shall be committed to conduct its business in a fair way and adhere to anti-trust and other competition laws.
• Confidential information: Suppliers shall protect Signant Health’s and its clients’ confidential assets and information. Suppliers shall protect personal information in compliance with all applicable local laws. Personal information provided by or on behalf of Signant Health shall only be used, accessed, and disclosed as permitted by the Supplier agreement.
• Trade regulations: Suppliers shall comply with all applicable trade control laws and regulations in the import, export, re-export or transfer of goods and services (including software and technology).
• Background checks and training: Suppliers shall ensure that all Supplier personnel involved in providing the services to Signant Health
  • complete a background checks, provided it is permitted by the applicable local law;
  • receive all trainings necessary to perform their tasks and to comply with this Code of Conduct.

Compliance with the Code of Conduct:

• Suppliers are required to promptly report to Signant Health legal violations or violations of this Code of Conduct. To report a violation, please contact us at supplier.compliance@signanthealth.com. Signant Health will keep the reported information confidential, provided that it is permitted to do so by law.
• In order to ensure and demonstrate compliance with this Code of Conduct, Supplier shall keep record of all relevant documentation, and provide them to Signant Health upon request.
• Signant Health will evaluate Suppliers’ compliance with this Code of Conduct during the Supplier selection process and periodically during the term of the agreement with the Supplier.
• Signant Health reserves the right to update or change this Code of Conduct.