Oath Supplier Code of Conduct

Oath holds itself and its suppliers to the highest ethical and business practices. Oath employees apply our Standards of Business Conduct (“SBC”) to our business. This Supplier Code of Conduct (“Supplier Code”) provides our expectations for suppliers and contractors working on your behalf who provide goods and services to Oath. The Supplier Code supplements, but does not supersede, contract terms between you and Oath.

We expect you to fully comply with laws, rules and regulations that apply where you operate and/or provide goods and/or services to Oath. In some cases, the Supplier Code includes higher standards than the law prescribes. In those cases, we expect that you will adhere to the higher standards. We also expect you to:

  1. Engage with ethics and integrity. Oath expects its suppliers to engage in all activities with the highest degree of ethics. Suppliers may not engage in illegal or inappropriate activities in conducting business for or with Oath. As examples, Oath strictly prohibits corruption, extortion, embezzlement or bribery, and expects suppliers to prepare accurate, truthful and complete records. Compliance with laws is not enough; we expect that you will avoid any situation that has any appearance of impropriety.
  2. Comply with laws related to bribery and anticorruption. Suppliers must comply with all laws and regulations related to bribery and corruption. This includes, but is not limited to, the United States Foreign Corrupt Practices Act, the UK Bribery Act, France’s Law on Transparency, the Fight against Corruption and Modernization of Economic Life, and similar local laws. We also expect that you will not engage in any conduct that would result in harm to your or our reputation, whether or not it is illegal.
  3. Compete fairly. Suppliers must apply fair business standards in all Oath-related activities, including advertising, sales, and competition. Only reference Oath or any of its products, services, employees, or affiliates in advertising, marketing or promotional activities if you have received prior written permission from Oath’s Corporate Communications team. In each case, we expect that you will accurately and honestly represent Oath.
  4. Help us maintain a professional workplace. We at Oath treat each other fairly and with respect and dignity. We give every employee an equal opportunity to succeed. We create a business atmosphere that encourages and celebrates diversity. Oath business operations do not include child or forced labor, slavery, or human trafficking. We do not tolerate discrimination based on any characteristic protected by law and do not tolerate any type of harassment. Oath supports employee rights to freedom of association and to engage in concerted activity protected by law without fear of retaliation. Our suppliers should apply all of these same standards.
  5. Help us maintain a safe and healthy workplace. Work areas should be conducive to healthy working and free from unsafe conditions. Conflict should be resolved in a respectful and productive manner without threats, bullying, violence, or hostility. Oath is a drug-free workplace, and does not permit illegal drugs or controlled substances in our workplace, even where local law permits. Do not abuse alcohol or prescription drugs while working or attending business functions on Oath’s behalf.
  6. Use and protect our resources responsibly. Never permit unauthorized access to our space or systems. Handle our company property - including assets and data - responsibly, honestly, and in accordance with applicable policies. Protect our intellectual property. Respect the intellectual property of others when working on our behalf. Promptly inform us if you are aware of any violations of these conditions.
  7. Respect our gifts and entertainment policy. In addition to our anti-bribery requirements, we do not exchange cash or cash equivalents, such as gifts cards, with suppliers or other business partners. Gifts and entertainment offered should be reasonable and have a legitimate business purpose. They may not be offered in an effort to improperly influence a business decision or business relationship. Gifts should be nominal courtesies. If they could even appear to be a bribe or improper payment, do not offer or receive them. Entertainment should not embarrass your company or ours, and should not occur in a way that could harm our companies’ reputations. It is never acceptable for an Oath employee to solicit gifts, gratuities or entertainment, and gifts or special favors are not conditions of doing business with Oath. Report any attempted bribery or inappropriate gifts or entertainment to our ethics helpline as noted below.
  8. Report possible violations. Supplier employees should have the ability to report ethical concerns or violations of this Supplier Code or of Oath’s Standards of Business Conduct through an anonymous helpline to the extent permitted by law. Suppliers who operate a hotline that allows employees to report violations or integrity issues can direct its employees to that hotline. You may provide any staff engaged on Oath matters with the following Oath Helpline information.

Email: ECO@oath.com
Phone: 833-ASK-Oath, 833-275-6284
Online Webform: https://iwf.tnwgrc.com/sbcteamaol