Code of Conduct - Partners
EFFECTIVE DATE 23 MAY 2022
Cention strives to be a company that lives its values every day.
Because we are committed to operating with greatest integrity and in compliance with all applicable laws, we also require our merchants, suppliers, distributors, agents, representatives, and other business partners, as well as their employees, agents, representatives, and subcontractors (collectively, “Partners”), to share in this commitment.
As such, Cention will require Partners to agree to abide by all applicable laws, including anti-bribery, anti-harassment, and anti-modern slavery laws, as well as this Partner Code of Conduct (the “Code”). Failure to comply with the Code or applicable laws will be considered a breach of the Partner’s contract with Cention and may result in immediate termination of our business relationship.
Labor and Employment Laws
Human Rights, Labor, and Safety Laws
Cention respects the protection of internationally proclaimed human rights. Cention is committed to upholding the fundamental human rights of our employees, and we require Partners to adhere to the same high standards. Cention expects Partners to reject all forms of child, forced, or involuntary labor. Partners must prohibit unlawful discrimination or harassment in its workplaces, which includes any behavior that creates an intimidating, unsafe, or hostile environment, and such prohibition extends to the behavior of Partners’ personnel towards any Cention personnel or Cention customer. Partners must further comply with local minimum wage and maximum working hours requirements.
Equal Opportunity Employment
It’s our belief that all people are entitled to equal employment opportunities. Partners must assure equal treatment in the administration of all personnel matters from recruitment to compensation and advancement without regard to race, color, creed, sex, gender, religion, marital status, registered domestic partner status, age, national origin or ancestry, physical or mental disability, medical condition, genetic information, sexual orientation, taking or requesting statutorily protected leave, or any other consideration made unlawful by local laws.
Health and Safety
Partners must strictly comply with all applicable health and safety laws and regulations applicable in all markets where they operate. This includes a commitment to environmentally sustainable practices and promoting the sustainable use of resources, as well as offering emergency training and resources as appropriate.
Anti Corruption Laws
Partners may not bribe anyone for any reason, whether in dealings with governments or the private sector. Anti bribery and similar laws prohibit offering or giving anything of value, directly or indirectly, to government officials or other individuals in order to obtain or retain business. Partners may not make illegal payments to government officials themselves or through a third party. Partners are further forbidden from promising, giving, or authorizing the provision of “facilitating payments” to expedite or secure the performance of a non-discretionary, routine governmental or commercial duties. Under no circumstances may Partners offer, promise, or give gifts, hospitality, and/or travel to government officials on Cention’s behalf or for the purpose of improperly obtaining or retaining business or securing an improper business advantage.
Conversely, Partners also may not request, agree to accept, or accept a thing of value as a reward or in exchange for improperly performing any activity related to Cention’s business or if doing so could create or appear to create actual or potential conflicts of interest between Partners and Cention.
Competition
Partners must comply with all applicable laws and regulations regarding fair competition and antitrust.
International Trade and Export Controls
Partners must comply with all applicable import, export, customs, sanctions, embargoes, boycott, and other trade compliance laws and regulations.
Recordkeeping, Financial Integrity, and Honest and Accurate Dealings
Partners’ books, records, accounts and financial statements related to business with Cention must be maintained accurately and with appropriate detail. Partners are required to cooperate fully with Cention in any government or regulatory audits to the extent relevant and applicable to Partner. Partners must not make any false representations related to any Cention transaction, including, but not limited to, written or oral misrepresentations of fact or the promotion or use of false documentation such as fraudulent or forged contracts, forged letters of destruction, or any other false or inaccurate records.
Intellectual Property and Confidential Information
Partners may only use Cention’s intellectual property, such as trade secret information, copyrights, patents, or trademarks, to the extent and in the manner permitted by Partners’ contract with Cention. Partners may not infringe the intellectual property rights of others, nor misuse any trade secrets or proprietary or confidential information of Cention or others for their own purposes or disclose such information to unauthorized third parties. Partners must notify Cention if they become aware of any unauthorized use of Cention’s intellectual property or of any unauthorized disclosure of Cention’s confidential information.
Raising Issues and Concerns
Cention encourages and expects Partners to immediately report any violations of laws, rules, regulations, or this Code in connection with Cention transactions or engagements by sending an email to legal@cention.com We also expect Partners not to retaliate against anyone who, in good faith, reports a violation or suspected violation or assists in an inquiry into such a report.
Certification and Application
Where Cention requires, Partners covered by this Code will have their authorized representatives certify that they have read and understood this Code and commit Partners to complying with the Code. Cention reserves the right to terminate its relationship with any Partners who do not comply with this Code, or upon discovery of noncompliance, do not work in good faith with Cention to achieve compliance.