Code of Conduct
A. Audits; Operating Effectiveness of Supplier; Investigations
Netrality suppliers must make available to Netrality, confidentially and upon request, a copy of any audit that has been performed on the controls and/or operating effectiveness of the supplier (e.g., SOC Type I and Type II). Netrality suppliers must respond to requests for information about compliance with this Supplier Code of Conduct. Netrality suppliers are expected to cooperate with audits conducted by or on behalf of Netrality and are expected to cooperate in any investigation Netrality conducts into any allegation of inappropriate or unethical behavior involving either a Netrality employee or an employee of a supplier where the allegation involves Netrality.
B. Conflicts of Interest
Netrality suppliers should avoid situations that create, or even appear to create, a conflict of interest with Netrality. Transparency is essential to avoiding conflicts of interest. If a supplier employee has a spouse, relative or close friend who works for Netrality, you should disclose that relationship to Netrality or ensure that the Netrality employee does so. Netrality employees and their family members may not hold a material financial interest in a Netrality supplier and Netrality suppliers are required to avoid such relationships with Netrality employees.
C. Confidential Information
Each supplier must keep Netrality confidential information, including but not limited to information about Netrality and its customers, other suppliers and other third parties that is not available to the public, strictly confidential. A supplier’s obligation to protect Netrality’s confidential information continues even after the completion of the supplier’s assignment or contract with Netrality. Suppliers are required to protect Netrality’s property and resources and use them only for legitimate business with Netrality.
D. Intellectual Property
Suppliers may only use Netrality’s intellectual property to the extent permitted under their contract with Netrality. Suppliers will not infringe or misuse the intellectual property of Netrality or others. Intellectual property includes Netrality copyrights, patents, trademarks, trade secrets and other intangible property. Suppliers are encouraged to notify Netrality upon discovering any unauthorized use of Netrality intellectual property or confidential information by supplier or by a third party.
E. Training and Compliance with the Supplier Code of Conduct
It is the responsibility of the supplier to ensure its employees and representatives understand and comply with the Supplier Code of Conduct and to inform Netrality if and when a situation develops that causes the supplier to be in violation of this Supplier Code of Conduct.
F. Reporting Non-Compliance
Netrality requires that suppliers report any conduct, including conduct of any Netrality employee, that a supplier believes in good faith to be an actual, apparent or potential violation of this Code to Netrality’s leadership team at firstname.lastname@example.org. Prompt reporting of misconduct is in the best interest of everyone and helps ensure our continued ethical business relationship. Netrality will investigate any reported violation. Netrality will maintain confidentiality to the extent possible when performing the investigation. Netrality will not tolerate any retaliation taken against any individual who has, in good faith, reported questionable behavior or a possible violation of this Supplier Code of Conduct.