Supplier Code of Conduct

Introduction

ecoATM is committed to conducting our business ethically and in compliance with law. This Supplier Code of Conduct (“Code”) details our expectations that our Suppliers share ecoATM’s commitment to building and sustaining ethical business practices.

Supplier Compliance

Suppliers and their employees, agents, and subcontractors (“Suppliers”) must adhere to this Code and the laws of the United States while conducting business with or on behalf of ecoATM, its subsidiaries, and various lines of business (collectively “ecoATM”).Suppliers are required to self-monitor and demonstrate compliance with this Code upon request.

Legal and Regulatory

  • Suppliers must ensure compliance with all applicable federal and local laws and regulations. These include compliance with applicable trade controls, antitrust laws, boycotts sanctioned by the United States, data protection requirements, and anti-corruption measures.
  • Suppliers must obtain and maintain all permits and/or licenses necessary to provide goods and services to ecoATM.

Health and Safety

  • Suppliers must ensure a safe and healthy working environment and comply with the letter and spirit of all applicable health, and safety laws. Procedures and systems to manage, track, and report occupational injury and illness must be established.
  • Workplaces must have adequate safety precautions and preparedness in place which guard against fires and plan for natural disasters and other emergencies. Adequate heating, air-conditioning and ventilation systems, personal space, first-aid supplies, toilets, break-room facilities and emergency exits should be in place.
  •  Suppliers must prohibit the use, possession, distribution, or sale of illegal drugs and alcohol while on ecoATM premises or while performing ecoATM work.
  • Weapons are prohibited in ecoATM facilities or on ecoATM property, unless expressly permitted by law.
  • Workplace violence including behavior that is violent, hostile or intimidating is prohibited.

Privacy and Information Security

Suppliers must comply with privacy and information security laws, other relevant regulatory requirements and ecoATM’s information security standards when collecting, using storing, processing, transmitting or sharing personal or proprietary information on behalf of or relating to ecoATM’s business.

Labor Practices

  • Suppliers’ employment practices must comply with all applicable laws and regulations, including anti-discrimination and anti-harassment laws, in all aspects of employment.
  • Suppliers must comply with all local and national minimum working age laws or regulations and must not use child labor. The minimum age for employees should be at least fifteen (15) years old, if allowed under the laws of the country where the work is performed, or the age for completing compulsory education in that country, whichever is higher. Hazardous work should not be done by anyone under the age of eighteen (18).
  • Suppliers should pay at least the legally required minimum wage and provide all legally mandated benefits relevant to where the work is performed. Suppliers should abide by the maximum legally allowed number of working hours. Only voluntary labor should be used.

Intellectual Property and Consumer Data Protection

  • Suppliers must use software, technology, hardware, and content which has been legitimately acquired and only in accordance with their associated licenses and/or terms of use.
  • Suppliers must respect intellectual property rights, and protect customer information, confidential data, and any other information assets of ecoATM and other third parties.

Business Practices

  • Suppliers must protect ecoATM’s proprietary and confidential information.
  • Gifts (something of value provided for personal use) exchanged with ecoATM employees should be customary, reasonable, legal and valued at less than $100. Suppliers should never give a gift or provide business entertainment in close proximity to a major business decision such as a contract award or in an attempt to influence a business decision.
  • Suppliers must not engage in bribery or other corrupt business practices. ecoATM is committed to the standards set by the US Foreign Corrupt Practices Act (FCPA) and local jurisdiction anti-corruption laws.
  • Suppliers should avoid real or perceived conflicts of interests. Suppliers should not work directly with any ecoATM employee or employee’s family member who holds greater than a 5% interest in Supplier.
  • Suppliers should keep accurate financial books and business records as required by local laws and accepted accounting practices. Invoices and reports shall be issued without falsification and in a timely manner. Business records should be retained and disposed in a legal and ethical manner.
  • Suppliers may not use ecoATM’s name or logo or hold themselves out as providing goods or services to ecoATM, without ecoATM’s prior consent.

Corporate Responsibility

  • Suppliers must have environmental programs and policies designed to comply with the letter and spirit of environmental laws and reduce their impact on the environment.
  • We encourage our Suppliers to continually seek opportunities to:

    o Reduce their carbon footprint;
    o Reduce waste in manufacturing and operations; and
    o Foster social and economic development of communities in which they operate.
     

Supplier Procurement Selection & Diversity

  • Suppliers should engage in fair and ethical dealings in all procurement-related activities, including any bid evaluation, negotiation, award decision and the administration of their own purchasing and sourcing activities.
  • Suppliers should proactively seek to engage competitive, diverse suppliers. 
  • Suppliers may not engage subcontractors without ecoATM’s prior written consent.
     

Exceptions and Reporting

Exceptions to this Code must be reviewed in advance by ecoATM’s Director of Regulatory Affairs and pre-approved by ecoATM’s Chief Legal Officer. In the event Supplier becomes aware of activities prohibited by the Code that have not been pre-approved, those activities must be brought to ecoATM’s attention via ecoatmlegal@ecoatm.com within 30 days of learning about the prohibited activity.

Misconduct Reports

Suppliers are encouraged to report any behavior or activity that they believe in good faith violates a law or this Code directly to ecoATM. Reports will be treated as confidential to the extent possible.