Zeem Solutions is committed to conducting business with honesty and uncompromising integrity. This commitment applies with equal vigor to Zeem Solutions’ supply chain. This Supplier Code of Conduct (“Code of Conduct”) contains principles to promote ethical business practices among entities, including their subcontractors and agents, providing products, people or services to Zeem Solutions (“Suppliers”). Zeem Solutions expects its Suppliers to: (a) comply with applicable laws and regulations; (b) conform to or exceed industry best practices; and (c) meet or exceed the expectations set forth in this Code of Conduct and any agreements between Zeem Solutions and the respective Supplier.
As used in this Code of Conduct, “Zeem Solutions” refers to Zeem Solutions Inc. and its subsidiaries. References to “Zeem Solutions teammates” are to Zeem Solutions employees and contingent workers performing services for Zeem Solutions. In this Code of Conduct, the term “including,” and any variation of such term, means “including without limitation.” The use of the word “or” in this Code of Conduct is not exclusive. This Code of Conduct is deemed to supplement, but not to supersede, any contract between Zeem Solutions and the Supplier (“Master Agreement”). In the event of a conflict between the Master Agreement and this Code of Conduct, the more restrictive terms shall apply.
Labor and Human Rights
Zeem Solutions expects its Suppliers to demonstrate a commitment to human rights, which includes, at a minimum, the following:
Fair Treatment. Provide equal opportunity in all aspects of employment and ensure a workplace free of harassment, abuse, coercion, and other inhumane treatment of workers. Strictly prohibit discrimination against workers and any other covered individual based on any class protected under applicable federal, state or local law, including race, color, religion, national origin or ancestry, ethnicity, sex, gender (including gender identity and expression, and status as a transgender individual), sexual orientation, age, physical or mental disability, citizenship, past, current or prospective service in the uniformed services, genetic information, and marital status.
Involuntary and Child Labor. Prohibit trafficking in persons or using any form of slave, forced, bonded, indentured or involuntary prison labor. Do not use child labor. Comply with all applicable minimum working age laws, regulations and industry best practices, including with respect to the minimum age for performance of hazardous work.
Compensation, Benefits and Working Hours. Provide all workers with at least the minimum wage, compensation for overtime hours, and benefits, in each case as mandated by applicable laws and regulations. Limit the number of working hours to the maximum legally allowed under applicable laws.
Freedom of Association. Abide by applicable law governing the rights of employees to join or not join trade or labor unions.
Health and Safety
Zeem Solutions expects its Suppliers to maintain a safe work environment for its workers and Zeem Solutions’ teammates, as well as the general public and others with access to job sites or surrounding areas. Suppliers must establish and observe safety protocols that, at a minimum, address the following:
Occupational Safety. Take appropriate precautionary measures to protect the health and safety of workers by: (a) implementing, maintaining and enforcing safety management practices that conform to or exceed legal and industry standards, including those mandated by the Occupational Safety and Health Act of 1970; (b) supplying workers with requisite, well-maintained personal protective equipment and mandating its use when performing work for Zeem Solutions; (c) providing regular safety training to workers and monitoring and enforcing their compliance with safety standards, procedures and industry best practices; (d) familiarizing workers with Zeem Solutions’ safety expectations and procedures and enforcing their compliance with Zeem Solutions’ safety requirements, including those specified in the Master Agreement; (e) ensuring workers are, at all times, properly qualified to perform their job responsibilities and designated tasks; (f) obtaining and keeping current all required health and safety permits, worker training certifications and credentials; (g) promptly reporting to Zeem Solutions all incidents and near misses; (h) preparing and implementing corrective action plans to manage risks and promote safe practices; and (i) prohibiting workers from performing services for, or on behalf of, Zeem Solutions while under the influence of any substance, including drugs or alcohol, which may impair their ability to work safely and effectively.
Occupational Injury and Illness. Maintain procedures and systems to manage, track and report: (a) occupational injuries and illnesses and (b) violations and fines from the Occupational Safety and Health Administration or equivalent state and local regulatory agencies. Such procedures and systems must be designed to: (i) encourage reporting; (ii) classify and record injury and illness cases; and (iii) investigate cases and implement corrective actions.
Emergency Preparedness. Implement emergency plans and procedures that, at a minimum, address: (a) emergency preparedness, reporting and notification (including to Zeem Solutions); (b) evacuation and rescue procedures, training and drills; (c) appropriate hazard detection and mitigation procedures; and (d) adequate exit facilities from job sites.
Information and Property
Zeem Solutions takes great care of its assets and expects its Suppliers to extend the same level of care for the assets entrusted or made available to the Suppliers. Accordingly, Zeem Solutions expects Suppliers to comply with the following:
Confidentiality. Safeguard confidential and proprietary information entrusted to the Supplier by Zeem Solutions and its customers. Such information includes all non-public information that, if disclosed, might be of use to competitors, or harmful to Zeem Solutions or its customers, including business plans, financial or competitive information, strategies, information systems and other business, operational, financial and performance data. That data is valuable to Zeem Solutions, and it is secret. Limit disclosure of Zeem Solutions information as legally mandated or expressly authorized by law, this Code of Conduct, the Master Agreement and any other applicable agreements. Any documents, papers, records or other tangible items that contain confidential and proprietary information relating to Zeem Solutions are the property of Zeem Solutions.
Protection and Proper Use of Assets; Improper Payments. Use best efforts to protect from loss, theft, abuse and unauthorized use any physical assets that Zeem Solutions made available to the Supplier. Ensure that Zeem Solutions' assets are used only for legitimate Zeem Solutions business purposes and are not maintained for use for non-business related purposes. Prohibit payment on behalf of Zeem Solutions that is made in furtherance of any unlawful or improper purpose. Respect Zeem Solutions’ intellectual property rights and comply with Zeem Solutions’ intellectual property licensing arrangements.
Privacy and Information Security. Exercise caution when collecting, storing and distributing confidential information regarding Zeem Solutions’ customers, teammates and shareholders. Abide by all applicable privacy, data protection and information security laws and regulations, and with Zeem Solutions’ privacy, data protection and information security policies (as they may be updated by Zeem Solutions from time to time).
Integrity and Compliance
Zeem Solutions is committed to operating ethically and responsibly and expects its Suppliers (including its workers and subcontractors) to share in Zeem Solutions’ commitment, including with respect to the following areas:
Conflict of Interest. Avoid relationships with or situations involving any of Zeem Solutions' teammates, customers and other business partners that compromise or could compromise or otherwise reasonably appear to compromise the ability of that party or the Supplier to perform his or her work objectively and effectively. Conflicts of interest occur when a person (or such person’s immediate family member) or entity has a private interest (including financial interest) that interferes with the interests of Zeem Solutions as a whole or when improper personal benefits (including gifts) are conveyed to or solicited by individuals in a position to make a decision on behalf of Zeem Solutions. Refrain from offering or giving Zeem Solutions teammates any gifts or entertainment that could undermine or influence their good business judgment or that might appear to have that result. On occasion, a Zeem Solutions teammate may accept gifts of nominal or modest value if (a) the gifts are consistent with the giver’s rules, (b) such teammate has determined and confirmed with the appropriate internal parties that the acceptance of the gift is in compliance with Zeem Solutions’ policies (as in effect at such time), and (c) open disclosure of the gift would not embarrass or reflect poorly on Zeem Solutions, the giver or the recipient. Zeem Solutions teammates are prohibited from soliciting gifts or favors from any person or entity with whom Zeem Solutions does business. Zeem Solutions teammates serving in a sourcing or procurement role or engaged in sourcing or procurement activities, and their immediate family members, are prohibited from receiving from Suppliers any gifts or gratuities, including those of nominal or modest value. Suppliers are expected to promptly report any situation, relationship or conduct that would give rise to actual, potential or the appearance of a conflict of interest.
Books and Records. Maintain accurate and complete books and records. Create, and ensure accuracy of, a record of all transactions, and retain, for a reasonable amount of time, all documentation pertaining to services rendered or goods delivered to, or on behalf of, Zeem Solutions.
Competition and Fair Dealing. Prohibit any activity, including bribes, kickbacks and extortion, designed to improperly or illegally advance any interest associated with Zeem Solutions. Monitor and enforce compliance with such restriction. Implement business practices designed to promote fair competition. Abide by anti-trust and anti-corruption laws.
Responsible Sourcing. Implement a policy designed to reasonably ensure that the products such Suppliers manufacture or contract to manufacture for Zeem Solutions do not contain conflict minerals, such as tin, tantalum, tungsten and gold, that directly or indirectly finance or benefit the perpetration of human rights abuses. Exercise due diligence in determining the source of these minerals and retain documentation of such efforts for inspection by Zeem Solutions upon request.
Environmental Protection. Establish, maintain, and enforce rules, guidelines, and standards regarding environmental protection, including restrictions on materials, labeling, information obligations, re-use, environmentally compatible product use, maintenance and disposal and, where applicable, measures for protection against hazardous substances.
International Trade Regulations
When engaged in performing any services for Zeem Solutions, Suppliers are required to comply with U.S. and local trade regulations, regardless of where in the world they are operating. Specifically, these regulations require that business may not be conducted on Zeem Solutions’ behalf with any persons, entities, or countries subject to U.S. sanction or embargo or to an end user or entity who has been prohibited from participating in U.S. export transactions. No matter where located, all Suppliers must comply with the U.S. Export Administration Regulations and any Office of Foreign Assets and Control regulations. In connection with any Zeem Solutions business, Suppliers are also prohibited from participating in boycotts that are not sanctioned by the U.S. government.
Reporting Concerns
Zeem Solutions expects its Suppliers (including its workers) to promptly report any situation or relationship involving Zeem Solutions that is perceived as a violation of law, regulations or this Code of Conduct. Suspected violations and concerns should be reported by calling the Ethics Alert Line at 877-383-5338 (selection #3). Suspected violations and concerns can be reported anonymously and confidentially. All complaints should include sufficient information to determine the specific issue, the period of time during which the violation or misconduct occurred, and who to contact for additional information. All reports are taken seriously. Each allegation is investigated and, if substantiated, resolved through appropriate corrective action and/or discipline. Zeem Solutions maintains a strict, non-retaliation policy for concerns raised in good faith.