Supplier Code of Conduct

FATCO Holdings, LLC.  (“FATCO”) is committed to the highest standards of integrity.  It is FATCO’s intention to select and retain suppliers (“Suppliers”) that share and embrace the letter and spirit of our commitment to integrity.  We understand that Suppliers are independent entities; however, the business practices and actions of a supplier may impact and/or reflect on FATCO.  Because of this, FATCO expects all Suppliers and their employees, agents, and subcontractors (Supplier’s employees, agents, and subcontractors shall hereinafter be referred to collectively as “Representatives”) to adhere to standards of business conduct and compliance while they are conducting business with and/or on behalf of FATCO, that are similar to what FATCO expects from its own employees.

FATCO Suppliers will be expected to educate and, when appropriate, train their Representatives to ensure they understand and comply with FATCO’s Supplier Code of Conduct, which is posted on Supplier Information page.

The practices summarized below are not all-inclusive, and there may be other conduct not specifically listed that will be considered unacceptable for a Supplier and/or its Representatives.  FATCO requires that Suppliers and their Representatives conduct themselves in a professional manner at all times while on FATCO property or while conducting business with and/or on behalf of FATCO.

Legal and Regulatory Compliance Practices

FATCO Suppliers shall conduct their business activities in full compliance with applicable laws and regulations while conducting business with and/or on behalf of FATCO and shall require that their Representatives do the same.  There are no circumstances that would allow for the disregard of any applicable law or regulatory requirement in the conduct of a Supplier’s business activities and none will be tolerated by FATCO.

Business Practices

FATCO Suppliers and their Representatives shall conduct their business interactions and activities with integrity and in accordance with their obligations under specific agreements with FATCO.  While many FATCO Suppliers may have their own compliance requirements, business practice standards, and/or codes of business conduct, it is essential that all FATCO Suppliers and Representatives understand and uphold the requirements for acceptable business conduct at FATCO when doing business with and/or on behalf of FATCO.  In addition to specific obligations under Supplier’s agreement with FATCO, all FATCO Suppliers are expected to:

  • Honestly and accurately record and report all business information and comply with all applicable laws regarding their completion and accuracy.
  • Use FATCO provided information technology and systems (including e-mail) only for authorized FATCO business-related purposes.  FATCO strictly prohibits Suppliers and Representatives from using FATCO technology and systems to create, access, store, print, solicit, or send any material that is intimidating, harassing, threatening, abusive, sexually explicit or otherwise offensive or inappropriate and/or send any false, derogatory, or malicious communications using FATCO provided information assets and systems.
  • Comply with all FATCO requirements for maintenance of passwords, confidentiality, security, and privacy procedures as a condition of receiving access to FATCO’s internal corporate network, all systems and buildings.  All data stored or transmitted on FATCO owned or leased equipment is to be considered private and is the property of FATCO.  FATCO may monitor all use of the corporate networks and all systems (including e-mail) and/or access all data stored or transmitted using the FATCO network.
  • Comply with the intellectual property ownership rights of FATCO and other including but not limited to copyrights, trademarks, and trade secrets.  Use software, hardware and content only in accordance with their associated license or terms of use.
  • Not distribute or cause to be distributed, any form of literature, materials or other information on FATCO owned or leased property (such as brochures, publications, advertisements, surveys, announcements, or flyers) unrelated to FATCO business in FATCO work areas (such as offices, cubicles, copy rooms, and/or conference rooms) at any time.  Distribution of such materials using the FATCO network or e-mail system is also strictly prohibited.
  • Speak to the press on FATCO’s behalf only if Supplier and/or Representative(s) is expressly authorized in writing to do so by FATCO.
  • Not deal directly with any FATCO employee who holds a significant financial interest (greater than 5% ownership) in the Supplier or whose spouse, domestic partner, or other family member or relative holds a significant financial interest in the Supplier.
  • Avoid the appearance of or actual improprieties and/or conflict of interests.  Suppliers may not accept from or give to an FATCO employee, directly or indirectly, gifts, contributions, or prizes with an aggregate value of greater than $100 in any given calendar year.  Suppliers are encouraged to strictly adhere to this policy, especially at year end during the Holiday Season.

Employment Practices

FATCO expects its Suppliers to share its commitment to diversity, equal employment opportunity, and a safe and harassment free workplace.  FATCO Suppliers shall conduct their employment practices in full compliance with all applicable laws, and regulations in all of their operations.

Compliance with the FATCO Supplier Code of Conduct

It is the responsibility of the Supplier to ensure that its Representatives understand and comply with the FATCO Supplier Code of Conduct and to inform its FATCO contact (or a member of FATCO management) if and when any situation develops that requires the Supplier to operate in violation of the code set forth in this document.

Enforcement of and Compliance Verification with the FATCO Supplier Code of Conduct

FATCO intends to enforce the terms of the Supplier Code of Conduct in accordance with the terms of Supplier’s agreement with FATCO and will not tolerate any departure from its standards.  FATCO Suppliers are expected to self-monitor their compliance with this Supplier Code of Conduct.  

In addition to any other rights FATCO may have under its agreement with Supplier, FATCO may request the immediate removal of any supplier representative who behaves in a manner that is unlawful or inconsistent with this Code, any FATCO policy, or that is otherwise deemed unacceptable to FATCO.

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