TRACFONE WIRELESS, INC.’S VENDOR CODE OF CONDUCT
TRACFONE Wireless, Inc. seeks, at all times, to conduct business in a professional, lawful, and ethical manner in every aspect of our business and in all of our day to day operations. We value our customers, employees, and business partners as true assets of our Company recognizing that they are key to the success we have achieved. The reputation of our Company depends upon the standards to which we hold these team members, both internally and externally. We expect our Vendors to share this perspective, and we, therefore, ask them to subscribe to certain business ethics and values, employment practices and legal and compliance requirements. This Code sets forth the minimum requirements all Vendors, as well as their employees, agents and subcontractors, must meet and adhere to in doing business with TRACFONE.
Business Ethics and Values
Legal and Compliance Requirements
COMPLIANCE WITH TRACFONE’S VENDOR CODE OF CONDUCT
We request that every vendor comply with this Code of Conduct as a condition of doing business with TRACFONE. Vendors are expected to self-monitor their compliance with this Code of Conduct. A vendor’s failure to comply with these policies is sufficient cause for TRACFONE to exercise its right to terminate its business relationship with that vendor. Alternatively, if TRACFONE discovers a vendor’s noncompliance with this Code, TRACFONE may require the vendor to implement a Corrective Action Plan. Vendors are responsible for ensuring that their employees and representatives understand and comply with this Code of Conduct. Vendors have a duty under this Code of Conduct to inform TRACFONE’s General Counsel of any violations of these requirements.
California Transparency in Supply Chains Act Disclosure
TracFone makes this disclosure pursuant to the California Transparency in Supply Chains Act of 2010, a law which is designed to increase the amount of information manufacturers and retailers make public regarding their efforts to address the issue of slavery and human trafficking in their supply chains.
At TracFone, we are committed to conducting our business in a lawful and ethical manner, and we expect the same from our suppliers. As part of this commitment, we have no tolerance for slavery or human trafficking in our supply chain.
TracFone has taken the following steps to eradicate slavery and human trafficking from its supply chain:
Supplier Agreements. TracFone does not require its suppliers to certify that materials incorporated into their products comply with the slavery and human trafficking laws of the countries in which they are doing business. However, TracFone's standard purchasing agreement requires suppliers to comply with all applicable laws, including laws that govern slavery, human trafficking and other exploitative labor practices.
Company Responsibility. TracFone strives to establish and maintain close working relationships with its suppliers. TracFone does not rely upon third parties to verify its product supply chains in order to evaluate and address risks of slavery and human trafficking.
Audits. TracFone does not conduct, or engage third parties to conduct, onsite audits of its suppliers; however, many of those suppliers have their own codes of conduct and auditing programs which assist them in complying with TracFone's requirement that they operate their factories in accordance with all applicable laws.
Employee Training and Accountability. At this time, TracFone does not provide employees with training on slavery and human trafficking. However, employees who interact with suppliers are expected to report any potentially unlawful or unethical conduct that comes to their attention, including the presence of slavery or human trafficking in TracFone’s supply chain. Under TracFone’s Whistleblower Policy, any such report will be promptly and appropriately investigated.
TRACFONE is deeply committed to conducting business in accordance with the highest standards of honesty, ethics and integrity. By requiring adherence to the letter and spirit of this Code of Conduct, TRACFONE hopes to instill those same values in its vendors and foster strong, long-term and mutually beneficial relations.