Vendor Code of Conduct

Effective 10/1/2023

Evolution Global, Inc., together with its subsidiaries (collectively, “Evolution Global” or “we”), is committed to maintaining the highest standards of business conduct and embracing internationally recognized standards for business integrity, human rights, and environmental sustainability. We see this as a shared commitment that extends to our network of vendors, contractors (including subcontractors), consultants, and other providers (collectively, “Vendors”).  

This Vendor Code of Conduct (the “Code”) reflects the basic business practices we require of our Vendors and should be regarded as a minimum standard that operates in addition to (and not in replacement of) a Vendor’s existing legal and contractual obligations to Evolution Global. Evolution Global reserves the right to review, suspend or, under the appropriate circumstances, terminate any and all of its contractual relationships with a Vendor that is found to be in breach of this Code.

2. Business Integrity

Conducting business ethically and with integrity is essential for corporate accountability. Vendors are expected to adopt the highest standards for business ethics and ensure that they and all of their operations adhere, at a minimum, to the following standards:

2.1. Anti-corruption

2.1.1. Never attempt to improperly influence Evolution Global business decisions or the decisions of any other company. This means refraining from corruption in any form, including bribes, kickbacks, inappropriate gifts and/or entertainment, and similarly, avoiding corrupt arrangements with customers, suppliers, government officials or other third parties

2.1.2. Comply with relevant laws and regulations regarding money laundering, terrorism financing, bribery and corruption (including but not limited to the Foreign Corrupt Practices Act and the UK Bribery Act) wherever business is conducted on Evolution Global’s behalf. This applies whether a Vendor works with government officials or individuals in the private sector.

2.2. Conflicts of Interest

2.2 .1. Remain free from influences that conflict with the best interests of Evolution Global or that might deprive Evolution Global of due loyalty in business dealings. Even the appearance of a conflict of interest can be damaging and should be avoided.

2.3. Insider Trading

2.3.1. Avoid insider trading and refrain from buying or selling the stock of Evolution Global or any other company when in possession of non-public information that could influence a decision to buy or sell stock.

2.4. Data Privacy and Confidentiality

2.4.1. Respect individual privacy rights and maintain privacy and security policies that meet or exceed all applicable data protection laws.

2.5. Competition and Antitrust

2.5.1. Promote market competition and fair dealings in interactions with Evolution Global, Vendor customers, Vendor competitors and all other market participants.  

2.5.2. Comply with applicable domestic and international competition and consumer protection laws.

2.5.3. Refrain from anti-competitive arrangements such as price fixing, market allocation, bid-rigging, boycotting, abuse of market power and concerted practices.

2.6. Intellectual Property

2.6.1. Respect the intellectual property rights of Evolution Global and others, including, but not limited to patents, copyrights, trademarks, and trade secrets.

2.7. Export and Trade

2.7.1. Comply with applicable customs and import laws and respect international trade restrictions, international sanctions and all laws and regulations concerning export controls.

2.8. Respect for Human Rights & Labor Standards

Evolution Global takes its commitment to human rights and fair labor conditions seriously, and we require the same from our Vendors. Vendors must provide and maintain a safe and ethical workplace and require the same from their own vendors, including, at a minimum, ensuring they and all of their operations:  

- Promote equal opportunities and treatment of all employees and a workplace environment that is free from discrimination, exploitation, harassment, or other unacceptable treatment of individuals.  
- Treat employees with respect and dignity and observe rights to freedom of association and collective bargaining.
- Prohibit the use of forced or involuntary labor – including prison, indentured, bonded, or slave labor – and any engagement in human trafficking.  
- Prohibit the use of child labor and only employ individuals who meet applicable legal age requirements in the Vendor’s countries of operation.
- Comply with all applicable wage and hours – including overtime – labor laws in the Vendor’s countries of operation.
- Maintain a working environment that is safe and fully compliant with applicable occupational health and safety laws.

3. Questions and Reporting Potential Violations

Evolution Global relies on Vendors to uphold our values and ethical standards on a global basis. We reserve the right to review and update this Code in our sole discretion.

You must report any suspected violation of laws, regulations, of this Code immediately. If you wish to report any such violations or have questions or concerns about this Code, please contact our Legal Department:

Once Evolution Global has received a report, we will promptly follow internal policy to take appropriate action to investigate the report and respond accordingly. Evolution Global expects Vendors to cooperate fully with any resulting investigation, and we will make every effort to protect confidentiality and, where permitted by local law, anonymity.

Evolution Global will not tolerate retaliation taken against any individual who has in good faith raised questions, sought advice, or reported misconduct, questionable behavior or a possible violation of law or this Code.