Carbonite supplier code of conduct
At Carbonite, we value our role as a leader in data protection for consumers and businesses. We provide a robust Data Protection Platform for businesses, including backup, disaster recovery, high availability and workload migration technology. Carbonite strongly values its principles, standards and practices and we expect our trusted suppliers to do the same. You play a key role in our success as a business and as a member of the community.
Compliance with Laws
Suppliers are expected to comply with all applicable laws, rules and regulations in all jurisdictions in which Supplier conducts its business.
Employment Practices and Human Rights
Regardless of the type or location of service provided, Carbonite’s Suppliers should adhere to all applicable legal and any other binding obligations concerning employment practices and workplace conditions, including the protection of internationally proclaimed human rights. Suppliers are expected to conduct their employment practices in compliance with all applicable laws, rules and regulations, and should, without limitation:
- Commit to a workforce and workplace free of harassment and unlawful discrimination. Supplier will abide by the requirements of 41 CFR 60–1.4(a), 60–300.5(a) and 60–741.5(a), if applicable or any similar laws in the countries in which you carry out business. These regulations prohibit discrimination against qualified individuals based on their status as protected veterans or individuals with disabilities and prohibit discrimination against all individuals based on their race, color, religion, sex, sexual orientation, gender identity or national origin. Moreover, these regulations, if applicable, require that Supplier take affirmative action to employ and advance in employment individuals without regard to race, color, religion, sex, sexual orientation, gender identity, national origin, disability or veteran status.
- Not engage in or support in any way the use of forced labor; whether in the form of indentured labor, bonded labor, or prison labor. Not engage in or support in any way human trafficking; whether in the form of involuntary labor through threat, force, fraudulent claims or other coercion. We aim to ensure that there is no modern slavery or human trafficking in our supply chains. We expect that all Suppliers will act in accordance with the UK Modern Slavery Act 2015, if applicable, or any similar laws in the countries in which they carry out business to ensure that no employee or individual working in any supply chain is being exploited.
- Comply with all local, state, provincial and national minimum working age laws and regulations, including without limitation child labor laws.
- Not utilize or endorse in any manner corporal punishment, physical or verbal abuse, financial punishment such as deduction from wages for disciplinary purposes or other unlawful harassment and any threats or other forms of intimidation.
- Provide all workers with clear and understandable written information about their employment conditions in a language understood by the worker with respect to wages, benefits and location of work, and if applicable, the hazardous nature of any work before they enter employment and as needed throughout their term of employment.
- Not require workers to work more than the maximum hours of daily labor set by local, state, provincial and national laws or regulations. Suppliers must ensure overtime is voluntary and paid in accordance with applicable local, state, provincial and national laws or regulations.
- Keep employee records in accordance with applicable local, state, provincial and national laws or regulations and provide in a timely manner, via pay stub or similar documentation, the basis on which employees are paid.
- Respect workers’ rights to freedom of association and collective bargaining in accordance with applicable local, state, provincial and national laws.
Health, Safety and Security
Suppliers are expected to integrate sound health, safety and security management practices into all aspects of their business. Carbonite expects Suppliers to provide a safe and healthy work environment and comply with all applicable safety and health laws, regulations, and practices including those related to occupational safety, emergency preparedness, occupational injury and illness, industrial hygiene, physically demanding work, sanitation, food, and housing. Adequate steps must be taken to minimize the causes of hazards inherent in the working environment. In all instances, though, Suppliers must refrain from any form of conduct that is considered dangerous, threatening, or harassing, and must perform service in a manner that is compliant with applicable health and safety laws and regulations.
Supplier may not knowingly engage in, or otherwise facilitate, money laundering activities. Nor may Supplier enter into any contracts or transactions with parties appearing on the Office of Foreign Assets Control’s list of Specially Designated Nationals.
Anti-Corruption and Anti-Bribery
Suppliers should not participate in bribes or kickbacks of any kind in dealings with Carbonite, public officials or individuals in the private sector. Carbonite expects its Suppliers to comply with all applicable anti-corruption and anti-bribery laws, as well as laws governing lobbying, gifts, and payments to public officials, political campaign contribution laws, and other related regulations. Suppliers should not, directly or indirectly, offer or pay anything of value (including travel, gifts, hospitality expenses, and charitable donations) to any official or employee of any government, government agency, political party, public international organization, or any candidate for political office to improperly influence any act or decision of the official, employee, or candidate. Moreover, Supplier should not offer gifts to Carbonite employees in an attempt to influence our business decisions or to gain advantage over other suppliers. Supplier should not offer anything of value to obtain or retain a benefit or advantage for the giver, and do not offer anything that might appear to influence, compromise judgment, or obligate the Carbonite employee. Any gifts, meals, or entertainment must comply with applicable law, must not violate the giver’s and/or recipient’s policies on the matter, and must be consistent with local custom and practice. Even when gifts are permissible under law and policy, Suppliers must still exercise discretion and good judgment, since even “routine” business courtesies have the potential to cause embarrassing situations or create risk for those involved.
Business and Ethics Practices
Carbonite’s Suppliers should conduct their business interactions and activities with integrity and commit to the highest standards of ethical conduct when managing its operations. Without limitation, Suppliers must:
- Comply with all applicable trade controls, as well as all applicable export, re-export, and import laws and regulations.
- Conduct business in full compliance with antitrust and fair competition laws that govern the jurisdictions in which they conduct business, and actively avoid situations that could have the appearance of impropriety or deception.
- Raise any concerns (or potential for concerns) to your primary Carbonite contact about a conflict of interest when a friendship, family relationship, financial interest, or other similar circumstances interferes (or has the potential to interfere with) your ability to make honest and fair business decisions, or to provide products or services to Carbonite. It is important to avoid actual or even the appearance of improprieties of this nature.
- Refrain from engaging in any transaction involving a purchase or sale, or offer to purchase or sell, Carbonite’s equity, debt or derivative securities, while in the possession of material non-public information concerning Carbonite. Supplier and its employees must refrain from disclosing Carbonite’s material non-public information to third parties. This applies not only to you and your employees directly, but to family, friends, or others who might be in a position to make investment decisions based on the material non-public information.
Privacy and Data Protection
Suppliers are expected to comply with all applicable data protection and privacy laws and ensure that any personal data is obtained properly, stored securely and is used only for those business purposes for which the data is obtained and only in accordance with our written instructions. Suppliers acknowledge that there are rules regarding the transfer of personal data between certain countries and is aware that such restrictions may apply to its activities. Handling of any information on our behalf – whether it’s our employees’ or our customers’ – we expect that Suppliers apply levels of data protection that are similar to our own – and never below the legal, contractual, or other binding obligations that may apply. Suppliers are expected to ensure the confidentiality of data provided and ensure that any person processing the data is bound by appropriate confidentiality obligations. Suppliers are expected maintain effective physical, technical, and administrative controls over the privacy and security of the data you are handling. You must only engage subcontractors with our prior written consent and ensure that data protection obligations are imposed on such subcontractors by way of written contract. You must report any suspected or actual data breaches involving the exposure of our data – whether it’s that of our employees or customers. You may also be required to undergo Carbonite’s Privacy Assessment.
We expect our Suppliers to share our commitment to a clean and safe environment and sustainable business practices. We encourage initiatives to reduce the impact on the environment, particularly through the use of environmentally-friendly technologies and efforts to reduce or eliminate waste of all types, including water and energy, through recycling, re-using or material substitution programs. All required environmental permits, approvals and registrations are expected to be obtained, maintained and kept current and their operational reporting requirements are to be followed.
Use of Subcontractors
In today’s business environment, Carbonite recognizes that Suppliers may have reason to subcontract certain aspects of their service delivery (which may be subject to Carbonite’s consent). If you delegate duties to subcontractors, you are expected (and may be required by law or contract) to perform due diligence on them, and to flow-down all appropriate legal and contractual obligations (including special provisions that may be required when providing services to the government). You are then responsible for monitoring and enforcing the compliance of your subcontractors with the obligations you pass along.
Suppliers are expected to promptly report concerns and potential or actual violations of this Supplier Code of Conduct, the law or other violations related to your business with Carbonite. You are encouraged to report any observations to your primary Carbonite contact. When that is not possible or appropriate, please contact Carbonite Legal at email@example.com. All reports are taken seriously and are thoroughly investigated. Any information you provide will be handled with discretion and will be kept as confidential as possible.
Any infringements of this Supplier Code of Conduct may affect our ongoing relationship with the Supplier.