Supplier Code of Conduct
/Overview
Nixon Peabody’s Supplier Code of Conduct (“Code”) sets forth the firm’s commitment to promoting integrity and compliance throughout its supply chain. Suppliers are required to adhere to the commitments in this Code and to require the same of their own suppliers. Violations of the principles of the Code may be grounds for termination of our business relationship. Violations of law will be referred to appropriate authorities.
Compliance with Law. NP Suppliers are required to comply with all applicable laws and regulations in the jurisdictions in which they operate, including labor and employment, workplace health and safety, human rights, and anti-money laundering laws and regulations.
/Labor and Human Rights
Workplace Health and Safety: Suppliers shall maintain a supportive, safe, and healthy work environment free from recognized hazards and shall comply with applicable workplace and public health and safety obligations.
Equal Employment Opportunities: Suppliers shall maintain a workplace free from unlawful harassment and discrimination.. Suppliers are required to comply with laws and implement policies that prohibit discrimination based on gender, gender identity, race, ethnicity, sexual orientation, age, disability, or any other legally protected status.
Diversity: Suppliers shall promote diversity and inclusion in the workplace to the fullest extent permitted by law and to adopt business practices which reflect those commitments. The firm takes a demonstrated commitment to diversity into consideration in its purchasing decisions.
Human Trafficking and Child Labor: Suppliers will not engage in any practice that results, whether directly or indirectly, in human trafficking, child labor, or any form of forced, coercive, bonded, indentured, or other involuntary labor. As part of its commitment to preventing human trafficking, Suppliers may not withhold or refuse to pay wages, destroy, conceal, or confiscate identity or immigration documents, use fraudulent recruiting tactics, or engage in exploitative lending or housing practices.
/Business Integrity and Compliance
Conflicts of Interest: Conflicts of interest, whether potential, actual, or perceived, must be disclosed to your Nixon Peabody contact as soon as possible so that they can be properly addressed.
Anti-Corruption: Suppliers shall not provide any item of value (a gift, favor, or cash or cash equivalent) if it could be viewed as an attempt to improperly influence any decision or action relating to its business, products or services. Gifts and entertainment may, at times, be customary business courtesies, but giving or receiving a gift is not appropriate if it is extravagant, creates a sense of obligation, or is done with the intent to influence a business decision.
Money Laundering, Trade Sanctions: Suppliers shall maintain anti–money laundering (AML), counter-terrorist financing (CTF), and sanctions compliance programs appropriate to its risk profile and consistent with applicable laws and regulations in all jurisdictions where it operates. Suppliers shall not engage in, facilitate, or otherwise be involved in transactions that conceal or disguise the origins, nature, location, ownership, or control of funds or assets, or that involve persons, entities, or jurisdictions subject to trade or economic sanctions.
Fair Competition: Suppliers shall not engage in unfair, deceptive, and anti-competitive business practices and must comply with all applicable antitrust laws and regulations. Suppliers must not directly or indirectly engage in illegal or illicit collaboration with competitors or agree to restrain trade or reduce competition.
Intellectual Property: Suppliers shall not engage in any activity that would infringe or violate the intellectual property rights of the firm, its clients, or other third-parties.
/Confidentiality and Data Protection
Confidentiality: Suppliers must use appropriate organizational and technical measures to protect information received from (or on behalf of) the firm or its clients against accidental, unauthorized, or unlawful destruction, loss, alteration, disclosure, access, or use. Suppliers must ensure that no confidential information is disclosed to third parties, or the supplier’s subcontractors, unless disclosure is permitted by the supplier’s written agreement with the firm or otherwise required by law.
Data Protection: Suppliers must comply with all applicable data protection, data privacy, and cybersecurity laws and regulations. Suppliers shall use appropriate technical and organizational measures to safeguard data subject to legal protections relating to collection, use and other processing (“Regulated Data”), including regulated personal information or personal data (as defined under appliable law), and otherwise respect and protect the privacy rights of individuals. Any supplier processing Regulated Data must agree in writing to process such data pursuant to Nixon Peabody’s data processing requirements.
Notification of Actual or Suspected Data Breach: Suppliers must immediately notify Nixon Peabody at Compliance@nixonpeabody.com as soon as it becomes aware of any actual or reasonably suspected accidental, unauthorized, or unlawful destruction, access, loss, alteration, or use of any data processed on behalf of Nixon Peabody or its clients.
Prohibition Against Use of NP Data: Supplier is prohibited from using or otherwise processing any data processed in connection with the goods or services provided to Nixon Peabody (including prompts, queries, and output) except to directly provide the goods or services to Nixon Peabody. This prohibition includes any use or processing of data for Supplier’s own purposes, including to improve Supplier’s goods or services or train or improve any AI or AI features.
/Environment
Suppliers shall comply with all environmental laws and regulations applicable to their operations. Nixon Peabody expects Suppliers to measure their carbon footprint and be aware of and understand the environmental risks and impacts of their operations and supply chains.
The firm encourages all suppliers to take active measures to reduce their carbon footprint, to ameliorate any other adverse environmental impacts, and to consider environmental sustainability when developing business strategies, purchasing products and services, performing due diligence on their own service providers, and reviewing or changing their operations. The firm takes a demonstrated commitment to sustainability into consideration in its purchasing decisions.
/Questions or Concerns
For questions or concerns about this Code, or to report a possible violation of this Code, contact Compliance@NixonPeabody.com. Please note that if you become aware of a situation that may involve a violation of this Code, you have a responsibility to report it.