Supplier Code of Conduct

Introduction

Lytx, Inc. (“Lytx”) is committed to conducting our business ethically and in compliance with law.  All of our Suppliers (as defined below) are expected to share this commitment and are required to follow this Supplier Code of Conduct (“Code”) in connection with their dealings with or on behalf of Lytx.

Compliance with Supplier Code of Conduct

Suppliers, resellers, vendors and others with which we do business along with their employees, agents and subcontractors (collectively referred to as “Suppliers”) are expected to adhere to this Code while conducting business with or on behalf of Lytx.  Suppliers are expected to maintain internal policies and procedures that are consistent with this Code and make relevant agents, employees, and subcontractors aware of the requirements of this Code.  Suppliers are required to self-monitor and demonstrate compliance with this Code upon request.  Lytx reserves the right to audit Supplier compliance with this Code.  Any violations of this Code may jeopardize the Supplier’s business relationship with Lytx, up to and including termination of the Supplier relationship.

Legal and Regulatory Practices

  • Suppliers must conduct their business activities in full compliance with all applicable laws and regulations while conducting business with and/or on behalf of Lytx, including without limitation compliance with all applicable trade controls, antitrust laws, boycotts sanctioned by the United States, data protection requirements and anti-corruption regulations.
  • Suppliers must obtain and maintain all permits and/or licenses necessary to provide goods and services to Lytx.

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 not use any form of forced labor – indentured, bonded, prison or otherwise.  Suppliers must not traffic workers or in any other way exploit workers by means of threat, force, coercion, abduction or fraud.  All work must be voluntary and workers should be free to leave work or terminate their employment with reasonable notice. Workers must not be required to surrender any government-issued identification, passports, or work permits as a condition of employment.
  • Suppliers must not use child labor and comply will all local and national minimum working age laws or regulations. 
  • Suppliers must not engage in any physical discipline or abuse.  Physical abuse or discipline, the threat of physical abuse or discipline, sexual or other harassment, and verbal abuse or other forms of intimidation are prohibited.
  • Suppliers must pay at least the legally required minimum wage and provide all legally mandated benefits relevant to where the work is performed. 
  • Suppliers must abide by the maximum legally allowed number of working hours.
  • Suppliers must recognize and respect the right to free association, and Suppliers are expected to comply with the terms of any applicable collective bargaining agreement.

Health and Safety

  • Suppliers are expected to ensure a safe and healthy working environment and must comply with all applicable health and safety laws.
  • Suppliers are expected to have policies and practices in place that minimize the risk of accidents, injury and exposure to health risks.

Environmental Responsibility

  • Lytx expects our Suppliers to conduct business in ways that protect and preserve the environment. At a minimum, Suppliers are required to comply with applicable environmental laws, rules and regulations in the countries in which they do business.

Business Integrity

  • Suppliers must protect Lytx’s proprietary and confidential information.
  • Gifts (something of value provided for personal use) exchanged with Lytx employees should by customary, reasonable, and legal.  Suppliers should not offer any gift in an attempt to influence a business decision.
  • Suppliers must not engage in bribery or other corrupt business practices.  Lytx expects its Suppliers to maintain control procedures to prevent bribery in accordance with all applicable local, state, federal or national laws, including the U.S. Foreign Corrupt Practices Act (FCPA) and the U.K. Bribery Act.
  • Suppliers should avoid real or perceived conflicts of interests.  Suppliers must not deal directly with a Lytx employee whose spouse, domestic partner or other family member or relative holds a significant financial interest in the Supplier.
  • Suppliers must keep accurate financial books and business records as required by local laws and accepted accounting practices.  Business records should be retained and disposed in a legal and ethical manner.
  • Suppliers many not use Lytx’s name or logo, or hold themselves out as providing goods or services to Lytx, without Lytx’s prior consent.

Intellectual Property

  • Suppliers must respect intellectual property rights and protect information assets of Lytx and other third-parties.
  • 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.

Reporting of Misconduct

Suppliers and other stakeholders are encouraged to report any behavior that they believe in good faith violates a law or this Code.  Reports may be made through Lytx’s ethics web reporting site at www.reportlineweb.com/lytx or by telephone at 844.877.5441.  Lytx’s ethics reporting site is a 24-hour, seven-day-a-week dedicated website and telephone line maintained by a third-party vendor.  Reports will be treated as confidential and anonymous to the extent possible.

 

 

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This Supplier Code of Conduct does not confer, nor shall it be deemed to confer, any rights on the part of third-parties, including any third-party beneficiary rights. For example, no employees of any Supplier shall have any rights against Lytx by virtue of this Supplier Code of Conduct, nor shall such employees have any rights to cause Lytx to enforce any provisions of this Supplier Code of Conduct, the decision with respect to any such actions being reserved by Lytx in its sole discretion.

Nothing herein should be construed as a representation of legal, or other requirements necessary for a Supplier to conduct its business. Each Supplier retains the sole responsibility to know, understand, and comply with the applicable statutes and regulations necessary to conduct its business. Lytx is not responsible for providing legal requirements to Suppliers.