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Supplier Ethics Policy

Montreal Associates is committed to the highest standards of quality and business integrity.

MA requires all of its suppliers and employees to conduct themselves with the highest standards of honesty, fairness, and integrity, complying with all applicable laws and avoiding even the appearance of impropriety.

Suppliers shall ensure that their employees, subcontractors, agents, and third parties assigned to provide services or products to MA act consistently with this Supplier Ethics Policy. MA may require suppliers to confirm compliance with this Policy. Failure to adhere to this Policy may result in disqualification from consideration for future business with MA and may result in termination of existing business.

Suppliers may contact Montreal Associates’ Ethics Officer at ethics@montrealassociates.com for questions relating to its obligations under this Policy.

 

Compliance with applicable law and MA policies

Supplier shall comply with all local laws, regulations, and policies applicable to it and its dealings with MA, including employment laws prohibiting discrimination and harassment. If this Policy or any other applicable MA policy conflicts with applicable law, applicable law will govern such conflict to the extent it is impossible for Supplier to comply with both the law and the policy. If this Policy conflicts with any other applicable MA policy, this Policy will govern to the extent it is impossible for Supplier to comply with both policies.

 

Insider trading

The Criminal Justice Act 1993 and similar laws in other countries prohibits trading in securities by anyone with material information not available to the public. A supplier’s interactions with MA may result in the supplier having access to material, non-public information about MA or another company (including Montreal Associates’ customers, suppliers, and other business partners). Suppliers shall not engage in any action to take advantage of that information, including buying or selling Montreal Associates’ or that company’s securities or sharing that information with others.

 

Gifts, travel and entertainment

Suppliers shall not directly or indirectly provide any gift, travel, entertainment, political contribution, or charitable donation of any value to a MA employee or any third party on behalf of MA. Suppliers may offer a MA employee a gift, travel, or entertainment only if it is: (a) appropriate (no cash or cash equivalents or other excluded gift type), does not create an actual impropriety or a perception of impropriety, and complies with all laws, regulations, and policies for all parties), (b) of reasonable value, and (c) with full transparency of its value.


Conflicts of interest

A conflict of interest arises when an MA employee’s personal interest interferes with the best interests of MA. It may occur when an employee or a family member or friend receives a personal benefit as a result of the employee’s position with MA. Supplier shall disclose to the MA Ethics Officer (ethics@montrealassociates.com) all relationships that have the potential to create a conflict of interest or the appearance of a conflict of interest. Supplier shall correct any actual or perceived conflict of interest as directed by MA.

 

Unfair business practices

MA is committed to competing fairly and in compliance with the antitrust and competition laws in every country where it does business. Suppliers shall comply with all applicable fair business, advertising, and antitrust competition laws; Suppliers shall not fix prices, rig bids, allocate customers or markets, or exchange current, recent, or future pricing information with the supplier’s competitors.

 

Anti-corruption

MA is committed to doing business with integrity and in compliance with the highest anti-corruption standards. Corruption violates the public’s trust, threatens economic and social development, and hurts fair trade. Supplier shall comply with the Criminal Finances Act 2017, and all similar anti-corruption and bribery laws in other countries as appropriate. Suppliers shall not engage or attempt to engage in bribery, extortion, or embezzlement. Suppliers shall conduct themselves with honesty, fairness, and high ethical standards, avoiding even the appearance of impropriety in all its business interactions worldwide.

 

Unauthorized lobbying on Montreal Associates’ behalf and speaking to the press

Supplier shall not undertake any type of lobbying or other similar representative efforts on MA’s behalf before any kind of government entity, official, body, or representative without the express written consent of MA. Suppliers shall make no statements to the press about or on behalf of MA unless expressly authorized to do so by MA.

 

Intellectual property rights, privacy, and data protection

Suppliers shall comply with all applicable intellectual property rights and laws. Suppliers shall only use information technology and software that it has acquired or licensed legitimately and shall use them only in accordance with the terms of such licenses. Suppliers shall not transfer any of MA's technology, proprietary information, or trade secrets without prior written consent from MA’s legal department. Suppliers shall respect the reasonable privacy and confidentiality expectations of everyone with whom it does business and shall appropriately protect all data that may come into its possession because of its relationship with MA, including data relating to MA and MA's employees, customers, and partners. Suppliers shall comply with MA's instructions and with applicable privacy, data protection, and security laws and regulations when personal, confidential, proprietary or other sensitive information is collected, stored, processed, transmitted, or shared. Suppliers shall use MA's provided information technology and systems only for business-related purposes authorized by MA.

 

Notice of ethical concerns

MA expects all employees, customers, partners, suppliers, shareholders, and stakeholders to speak up promptly about any conduct or circumstances they believe may constitute a violation of this supplier Ethics Policy or any other MA policy. Suppliers shall promptly notify the MA Ethics Officer at ethics@montrealassociates.com regarding any known or suspected illegal or improper behaviour relating to dealings with or on behalf of MA, including behaviour by MA's employees or agents