CODE OF CONDUCT FOR VENDORS

INTRODUCTION

Company holds its employees and directors to the highest standards of ethics and professional conducts. The Company believes that its Suppliers should hold themselves to the same high standards, and it will insist on the same standard of ethics and professional conduct in its interactions with Suppliers. This [24]7 Supplier Code of Conduct (“Code”) has been adopted for that purpose.

Although the Company understands and recognizes that its Suppliers are independent entities operating in diverse legal and cultural environments, the Company requires each of its vendors to conduct themselves in any interaction with the Company in accordance with the Code.

The term “Company” includes [24]7, Inc., a California corporation, and each of its subsidiaries, individually or collectively, as the context requires. The term “Supplier” shall mean and include any company, firm, partnership, corporation or other entity or individual which/who provides any products or services to the Company and is provided this Code.

NO CONFLICTS OR THE APPEARANCE OF CONFLICTS

Suppliers and their employees, agents or representatives shall not offer or give to an officer, employee, agent or representative of the Company any services, gifts, entertainment, payments, loans or other special favors or engage in other conduct of the type which is or appears to be offered for the purpose of influencing the award of a contract, to obtain favorable treatment under a contract or which would otherwise create a conflict of interest or the appearance of one.  The Supplier shall comply with all applicable laws, statutes, regulations relating to anti-bribery and anti-corruption including but not limited to the Foreign Corrupt Practices Act, 1977 and not engage in any activity, practice or conduct which would constitute an offence under the said laws.

HONEST AND ETHICAL CONDUCT

We expect all our Suppliers to act in accordance with the highest standards of personal and professional integrity, honesty, promptness and ethical conduct, while performing services for us on the Company's premises and at offsite locations or at any other place where they are representing the Company.

We consider honest conduct to be conduct that is free from fraud or deception. We consider ethical conduct to be conduct conforming to the accepted professional standards of conduct.

COMPLIANCE WITH GOVERNMENTAL LAWS, RULES AND REGULATIONS

Suppliers understand and acknowledge that their failure to comply with the requisite Central, State and Local Governmental Laws, Rules, Regulations directly affects the Company and therefore vendors must at all times comply with all applicable governmental laws, rules and regulations. Suppliers must acquire appropriate knowledge of the legal requirements relating to their business while performing services for or on behalf of the Company so as to enable them to appropriately offset any threat on account of non-compliance.

CONSISTENCY WITH [24]7 CODE OF CONDUCT

Suppliers must understand that the Company maintains its own Code of Business Conduct and Ethics. Suppliers must be mindful of this Code and conform their behavior to its principles, in any interaction with the Company or its personnel. These underlying principles are:

  • As we strive to outperform our clients’ best centers by 10% or more, we interact with our clients and their customers with the utmost care, integrity, honesty and business ethics.
  • Our workplace is one in which we respect each other.  We act with the utmost professionalism toward one another.  Our workplace must be safe and healthy and free from unlawful discrimination, harassment and retaliation.   
  • We treat confidential information, particularly customer data, with the utmost protection and care.   
  • We base our business decisions on business merit and value, not on personal or family influence.
  • We use Company property efficiently and only for proper business purposes.  
  • We follow proper record keeping and financial reporting procedures.
  • We comply with laws that apply to our Company.
  • We notify the Company if we observe, or learn of, unethical business conduct or illegal acts.

VIOLATIONS OF THE CODE AND PENALTIES

The Suppliers, as part of their services, have to ensure that this Code is adhered to both in letter and spirit. Suppliers shall cooperate in any internal or external investigations of possible violations.

The Company will enforce penalties on the Supplier for violations of the Code. By signing the acknowledgement below, Supplier agrees and accepts the penalties and agrees that any agreement that Supplier has with the Company, whether written or oral, will incorporate these penalty provisions.

Upon violating the Code, Supplier will immediately pay the Company a penalty of three (3) months worth of the previous payments made to Supplier by the Company, regardless of the amount. Amounts due and owing from the Company to Supplier at the time of such violation may be applied to such penalty. Supplier understands that payment of the penalty is not exclusive and does not preclude the Company from pursuing any other remedies, whether legal or equitable, which may be available to it. The Company shall also have the right to terminate any agreement with Supplier immediately upon such violation without penalty or cost of any kind.

WAIVERS AND AMENDMENTS OF THE CODE

We are committed to continuously reviewing and updating our policies and procedures. Therefore, this Code may from time to time be subject to modification as the Company in its sole and absolute discretion deem fit.

GENERAL STATEMENT REGARDING CODE

Suppliers are instructed to that this Code is intended to provide only broad guidelines as to the expected standard of conduct. It does not and cannot address every situation that a vendor might encounter in its interaction with [24]7. Ultimately, we rely on each vendor’s good faith and ethical standards to guide actions in specific circumstances, and [24]7 will evaluate its vendor relationships on this basis.