Code of Conduct
We know that you share our belief in the importance of integrity and our concern over the potential for misconduct in business practices. Because these issues are so important, we want you to know what we expect in our business interactions, to understand our commitment to the highest ethical standards and to help us protect both our companies and our stakeholders. We therefore ask you to help us ensure that employees of both our companies abide by these standards to protect integrity in our mutual business dealings.
Netrality has publicly committed to safe and ethical business practices to protect the welfare of those with whom we conduct business and those who are affected by our businesses, wherever we operate. This commitment carries an obligation for each of us to behave ethically and legally in all aspects of our daily business lives.
The Supplier Code of Conduct outlines our expectations regarding workplace standards and business practices. Each of our directors, officers, employees and business partners is required to comply with these principles wherever they act on behalf of Netrality. We ask that you click on the link and familiarize yourself with the Code of Conduct and that you make your employees aware of our Supplier Code of Conduct. By continuing to sell to Netrality, you affirm that you comply with the requirements set forth in the Code of Conduct.
We rely on our employees, suppliers and customers to raise concerns about potentially improper business practices or conduct by any employee or other party conducting business on behalf of Netrality. We in turn pledge to take appropriate action. Please use the following methods to contact us about potentially improper business practices or conduct that you think we should know about.
Regular mail: Legal Department, Netrality Properties, LP, 1330 Avenue of the Americas, Suite 700B, New York, NY 10019
Telephone: Contact the Legal Department at 212-317-1800
All reports are confidential.
Netrality requires every supplier to comply with our Supplier Code of Conduct. Please read and review our expectations to understand the requirements and to ensure you comply.
Table of Contents
- Our Operating Norms
- Business is conducted lawfully.
- All employees, agents and representatives are treated equally with respect and dignity, and are not discriminated against.
- Work is conducted on a voluntary basis and all employees, agents and representatives are of an appropriate age.
- All employees, agents and representatives are paid legal wages and work hours consistent with applicable law.
- Health and safety are protected at work.
- Business is conducted in a manner which embraces sustainability and reduces environmental impact.
- Audits; Operating Effectiveness; Investigations
- Conflicts of Interest
- Confidential Information
- Intellectual Property
- Training and Compliance with the Supplier Code of Conduct
- Reporting Non-Compliance
Netrality Properties, L.P. (including its subsidiaries, “Netrality”) is built on a foundation of strong corporate values and a commitment to doing business with honesty, integrity and professionalism. We are committed to conducting business in a legal, ethical, and professional manner. We expect the highest ethical conduct from our employees and partners. Accordingly, we expect that our suppliers will share and embrace the letter, values and spirit of our business practices, including those set forth in this Supplier Code of Conduct (the “Supplier Code of Conduct”). The Supplier Code of Conduct applies to our business partners, including but not limited to our vendors, resellers, consulting partners, suppliers, and service providers. It states our expectations of our business partners and their employees, agents, and subcontractors when conducting business with or on behalf of Netrality.
Though suppliers are independent entities, the business practices and actions of our suppliers reflect upon Netrality’s reputation and brand. As a result, Netrality expects that all suppliers and their employees, agents and subcontractors will adhere to the requirements set forth in this Supplier Code of Conduct while they are conducting business with and/or on behalf of Netrality. All suppliers should educate their representatives to ensure they understand and comply with the requirements set forth in this Supplier Code of Conduct.
This Supplier Code of Conduct (2017.1) supersedes and replaces any previous versions of the Supplier Code of Conduct. Any reference to the Supplier Code of Conduct in any documentation or contracts with a supplier is intended to refer to this Supplier Code of Conduct, which is maintained and updated from time to time.
2. Operating Norms
Netrality expects high standards of behavior from its employees and those with whom it does business. By becoming a supplier of Netrality, you agree that you share in, and comport yourself at all times in a manner consistent with, the operating norms which are further set forth below.
A. Business is Conducted Lawfully.
Netrality expects its suppliers and supplier representatives to conduct their business activities in compliance with all applicable laws and regulations. This means that in addition to, and not in lieu of, any specific obligations under any agreement between a supplier and Netrality, suppliers are required to meet the following standards:
Anti-Bribery and Corruption. Netrality’s business practices are based on honesty, integrity, and compliance with the law. Suppliers must not offer, provide, authorize, or receive bribes, kickbacks or other improper payments for any reason. Suppliers also must comply with all applicable anti-bribery and corruption laws, including but not limited to the U.S. Foreign Corrupt Practices Act (FCPA) and the U.K. Bribery Act.
Competition and Fair Dealing. Netrality is committed to dealing fairly and honestly with all of our business partners, regardless of where they are located or the type of products or services they provide. Netrality suppliers must not propose or enter into any agreement with a competitor to fix margins, prices or contractual terms or to divide up the market in any way.
Health and Safety. Netrality suppliers must comply with applicable health and safety laws and regulations at all times.
Permitting. Each Netrality supplier must obtain necessary permits and licenses required to conduct the activities for which it is engaged by Netrality. Netrality suppliers must at all times be transparent and honest with regulatory agency representatives, auditors and governmental officials.
Environmental Laws. Netrality suppliers are expected to comply at all times with all applicable environmental laws and regulations regarding hazards materials, air emissions, waste and wastewater discharges, including the manufacture, transportation, storage, disposal and release into the environment of such materials.
Freedom of Association. Netrality suppliers must conduct employment practices in compliance with all applicable laws and regulations.
Data Protection and Privacy. Netrality suppliers are expected to comply at all times with all applicable laws and regulations regarding the privacy of information, data protection and cross border data flows.
Document Retention. Netrality suppliers are expected to create, retain and dispose of business records in full compliance with applicable legal and regulatory requirements.
B. All Employees, Agents and Representatives are Treated Equally with Respect and Dignity, and are Not Discriminated Against.
Suppliers shall ensure that their representatives, employees and agents are treated with respect and dignity. Supplier representatives, employees and agents shall not be subjected to any physical, sexual, psychological or verbal harassment, abuse or other form of intimidation. No employee will be unfairly disadvantaged, favored or ostracized due to ethnic or racial status, nationality, descent, religion, gender, age, physical appearance, sexual orientation, political affiliation or parental status.
C. Work is Conducted on a Voluntary Basis and All Employees, Agents and Representatives are of an Appropriate Age.
Employment must be voluntary. Forced labor is not acceptable. Mental and physical coercion, slavery and human trafficking are prohibited. Under no circumstances will supplier employ workers under the minimum age for work or mandatory schooling, whichever is greater, as specified by applicable law.
D. All Employees, Agents and Representatives are Paid Legal Wages and Work Hours Consistent with Applicable Law.
Suppliers shall ensure that their representatives, employees and agents are provided with a total compensation package that meets or exceeds the legal minimum standards. Working hours may not exceed the maximum amount permitted by applicable law.
E. Health and Safety are Protected at Work.
In addition to complying with applicable legal and regulatory requirements, Netrality suppliers must ensure a safe work environment and minimize hazards through proper design, engineering and administrative controls, preventive maintenance and safe work procedures, as well as ongoing safety training, audits and corrective actions as applicable to the services or products they provide.
F. Business is Conducted in a Manner Which Embraces Sustainability and Reduces Environmental Impact.
Suppliers must comply with all applicable laws and regulations with respect to sustainability and environmental requirements. Suppliers must also comply with such Netrality internal standards with respect to environmental impact and sustainability as are communicated to suppliers from time to time. Netrality encourages its suppliers to consider implementation of processes designed to reduce the impact on the environment in the services or products they provide.