Supplier Code of Conduct - Outerwall Inc.

Supplier
Code of Conduct
Approved by the Chief Legal Officer. Effective May 1, 2015
Introduction
At Outerwall, we are creating a better way, the right way, every day. We measure success not just by the results
we achieve, but by the way we achieve them. Suppliers play an important part in how we achieve our goals. This
Supplier Code of Conduct (“Code”) articulates our expectation that our Suppliers share Outerwall’s commitment
to building and sustaining ethical business practices.
Supplier Compliance
Suppliers and their employees, agents and subcontractors (“Suppliers”) must adhere to the letter and spirit of
this Code while conducting business with or on behalf of Outerwall, its subsidiaries and various lines of business
(collectively “Outerwall”). The standards that apply are U.S. standards, unless a Supplier operates in a jurisdiction
with more stringent standards in which case the more stringent standards apply. Suppliers are required to selfmonitor and demonstrate compliance with this Code upon request.
Legal and Regulatory
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Suppliers must ensure compliance with all applicable federal and local laws and regulations. These
include compliance with applicable trade controls, antitrust laws, boycotts sanctioned by the United
States, data protection requirements and anti-corruption measures.
Health and Safety
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Suppliers must ensure a safe and healthy working environment and comply with the letter and
spirit of all applicable health and safety laws. Procedures and systems to manage, track and report
occupational injury and illness must be established.
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Workplaces must have adequate safety precautions and preparedness in place which guard against
fires and plan for natural disasters and other emergencies. Adequate heating, air-conditioning and
ventilation systems, personal space, first-aid supplies, toilets, break-room facilities and emergency
exits should be in place.
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Suppliers must prohibit the use, possession, distribution, or sale of illegal drugs and alcohol while on
Outerwall premises or while performing Outerwall work.
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Weapons are prohibited in Outerwall facilities or on Outerwall property, unless expressly permitted
by law.
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Workplace violence including behavior that is violent, hostile or intimidating is prohibited.
Labor Practices
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Suppliers’ employment practices must comply with all applicable laws and regulations, including antidiscrimination and anti-harassment laws, in all aspects of employment.
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Suppliers must comply with all local and national minimum working age laws or regulations and must
not use child labor. The minimum age for employees should be at least fifteen (15) years old, if allowed
under the laws of the country where the work is performed, or the age for completing compulsory
education in that country, whichever is higher. Hazardous work should not be done by anyone under
the age of eighteen (18).
2 / Supplier Code of Conduct
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Suppliers should pay at least the legally required minimum wage and provide all legally mandated
benefits relevant to where the work is performed. Suppliers should abide by the maximum legally
allowed number of working hours. Only voluntary labor should be used.
Intellectual and Physical Property
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Suppliers must respect intellectual property rights and protect customer information and information
assets of Outerwall 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.
Business Practices
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Suppliers must protect Outerwall’s proprietary and confidential information.
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Suppliers should not buy or sell Outerwall or another company’s securities if they possess information
that is not available to the investing public and that could influence an investor’s decision to buy or
sell the security.
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Gifts (something of value provided for personal use) exchanged with Outerwall employees should be
customary, reasonable, legal and valued at less than $100. Suppliers should never give a gift or provide
business entertainment in close proximity to a major business decision such as a contract award or in
an attempt to influence a business decision.
•
Suppliers must not engage in bribery or other corrupt business practices. Outerwall is committed to
the standards set by the US Foreign Corrupt Practices Act (FCPA) and local jurisdiction anti-corruption
laws.
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Suppliers should avoid real or perceived conflicts of interests. Suppliers should not work directly
with any Outerwall employee or employee’s family member who holds greater than a 5% interest in
Supplier.
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Suppliers should keep accurate financial books and business records as required by local laws and
accepted accounting practices. Invoices and reports shall be issued without falsification and in a
timely manner. Business records should be retained and disposed in a legal and ethical manner.
Corporate Responsibility
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Suppliers must have environmental programs and policies designed to comply with the letter and
spirit of environmental laws and reduce their impact on the environment.
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We encourage our Suppliers to continually seek opportunities to:
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Reduce their carbon footprint
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Reduce waste in manufacturing and operations
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Improve the energy efficiency of our kiosks
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Foster social and economic development of communities in which they operate
3 / Supplier Code of Conduct
Supplier Downstream Selection & Diversity
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Suppliers should engage in fair and ethical dealings in all procurement-related activities, including
any bid evaluation, negotiation, award decision and the administration of their own purchasing and
sourcing activities.
•
Suppliers should proactively seek to engage competitive, diverse suppliers.
Exceptions and Reporting
Exceptions to this Code must be reviewed in advance by Outerwall’s Head of Compliance and pre-approved by
Outerwall’s General Counsel. In the event Supplier becomes aware of activities prohibited by the Code that have
not been pre-approved, those activities must be brought to Outerwall’s attention via [email protected]
within 30 days of learning about the prohibited activity,
Misconduct Reports
Suppliers are encouraged to report any behavior or activity that they believe in good faith violates a law or this
Code. Reports may be made via the secure Outerwall EthicsLine Reporting Site or the EthicsLine telephone line
for the U.S. and Canada, 1-800-699-3097. The EthicsLine 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 to the extent possible
and may be submitted anonymously where permitted by law.
4 / Supplier Code of Conduct
©2015 Outerwall Inc. All Rights Reserved. Outerwall and their associated logos are trademarks of Outerwall Inc. Rev. 1 - Supplier. 6531.0515