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Supplier Code of Conduct

SBM Management Services, LP’s (“SBM”) Supplier Code of Conduct sets forth policies that SBM has adopted to promote ethical conduct in the workplace, safe working conditions, fair treatment of workers and environmentally responsible practices through both SBM’s and SBM’s strategic partners.

SBM embraces diversity and legal compliance as fundamental principles of its corporate strategy. It is our desire that all Supply/Service Partners to SBM and their agents similarly embrace diversity and equal opportunity to the fullest extent possible. All strategic Partners must operate in compliance with all federal and state regulations in which there said operations and subsidiaries do business. In all aspects of the working relationship, SBM’s strategic Partners and their agents shall support SBM’s core values by conducting business with integrity, by treating others with respect, by striving for performance excellence and by accepting accountability for their conduct. SBM reserves the right to review or audit Supply/Service Partner compliance with this Code.

The SBM Supplier Code of Conduct is not intended to create new or additional third-party rights or obligations to third parties, including any rights of, or obligations to, employees of suppliers. It supplements, but does not supersede, any rights maintained by SBM under any contract with any supplier.

The Code is comprised of five sections: 1) general standards of conduct for SBM’s Procurement chain (as outlined above), 2) standards for Labor, 3) Health and Safety, 4) the Environment, and 5) qualifying elements of an acceptable system to manage conformity to this Code as outlined below.

Ethics & Standard of Conduct

Supply/Service Partners to SBM and their agents are expected to conduct business with integrity, mutual respect, and to uphold the highest standards of ethics and behavior, including:

Business Integrity

Any and all forms of illegal or inappropriate activity, including, but not limited to, corruption, misrepresentation, extortion, embezzlement or bribery, are strictly prohibited and may result in termination of any or all Supply/Service Partner agreements with SBM and possible legal action. Records prepared for SBM, including records of work time and expenses, shall be accurate, truthful and complete, and shall meet applicable standards and requirements.

Company Information

Safeguarding SBM’s confidential and proprietary information concerning matters such as our business activities, strategies, plans, structure, technology, customers, financial situation and performance is critical to the company’s success, and such information cannot be disclosed or used, except in accordance with applicable regulations, contractual requirements and this Code. It is paramount that our business providers protect SBM’s information as if it were their own.

Supply/Service Partners must:

  • Understand any specific requirements for using SBM’s information and, when not sure, seek guidance from SBM Procurement.
  • Comply with applicable non-disclosure agreements and contractual confidentiality requirements regarding information belonging to or in the possession of SBM.
  • Immediately notify SBM Procurement of any request or demand by a third party for SBM information.
  • Never misuse or disclose confidential or proprietary information to unauthorized parties.
  • Use caution when discussing non-public information in public or any place where others may overhear.
  • Safeguard and appropriately handle SBM information and information regarding the SBM brand or logo.
  • Secure SBM’s written approval before using information about SBM, SBM’s name or brand identity publicly in any publicity, advertising or website.
  • Do not access, use, copy, manage, store or process SBM company information outside the United States without the prior written consent of SBM.

Competitor Disparagement & Obtaining Information

SBM competes based on the strength of its products, services, reputation, and fair and accurate comparisons with its competitors. Supply/Service Partners should not make unfair, misleading, or inaccurate comparisons with the products and services of SBM’s competitors. SBM acquires competitive and other information only using proper means and without misrepresentation, SBM’s Supply/Service Partners and their agents shall similarly do so.

Advertising & Marketing

Any use of, reference to or association of SBM, its name, logo or services, must be authorized with prior written consent. If an SBM Supply/Service Partner (with SBM’s prior written consent) is engaged in any advertising, marketing or promotional activities that reference or associate SBM, its name, logo or services in any manner; such materials must comply with all laws, rules and regulations, etc., and must be truthful and accurate. Materials must not be false, misleading or have a tendency to deceive and all claims must be substantiated. All Supply/Service Partners’ advertising must make clear and conspicuous disclosure of material terms and limitations of advertised offers.

Alcohol & Drugs

Supply/Service Partners and their respective suppliers (if applicable) must not report to work or engage in any work for or on behalf of SBM. At no time or in any fashion may a Supply/Service Partner or their respective suppliers represent, or make any representations on behalf of SBM while under the influence of illegal drugs or alcohol. Supply/Service Partners and their respective suppliers may not possess illegal drugs or controlled substances while on SBM or its customers’ premises, or while conducting business with or for SBM. This prohibition does not include legally obtained medications used as directed by a licensed medical practitioner that do not create a safety risk such as possible impairment in operating machinery.


Gambling, including games of chance, is not allowed while working for or on behalf of SBM or on SBM premises.

Conflicts of Interest

Supply/Service Partners must avoid engaging in any business activity that would conflict or interfere with their provision of products and services to SBM.

Company Property, Funds, & Information

Suppliers must use all SBM property, including but not limited to, equipment, funds, documents, electronic and written information and communications systems, with care and adherence to acceptable standards, applicable laws, and SBM’s rules and procedures. Supply/Service Partners are required to report any suspected or actual misuse, theft, vulnerability, improper exploitation or sabotage of SBM property.

Business Courtesies

SBM’s Supply/Service Partners, like SBM, are expected to compete based on the merit of their products and services, not through gifts, entertainment, or other business courtesies. Although business courtesies can promote successful working relationships and good will, SBM expects its Supply/Service Partners to follow all applicable laws and SBM’s rules and procedures with respect to gifts, entertainment, and other business courtesies when working with or representing SBM.

Working with the U.S. Government

When interacting with U.S. federal, state and local government bodies and agencies, and their representatives, SBM’s Supply/Service Partners must conduct themselves with honesty and integrity, and comply with all applicable laws and regulations, including, but not limited to, laws and regulations relating to government ethics, lobbying and the handling of confidential, classified or other government information. Supply/Service Partners whose work with SBM relates to U.S. federal government contracts may be subject to additional requirements as specified in their contracts with SBM.

International Business

SBM conducts business around the world in compliance with applicable law and in consideration of both U.S. and local standards and customs, and in a manner that fosters SBM’s reputation as a good company with which to do business. Among other practices, we (a) only lawfully transfer SBM products, services, equipment, information or knowledge across borders, (b) only make proper and permissible payments to parties outside the U.S., and (c) only exchange business courtesies according to SBM standards and local law. The foregoing includes, but is not limited to, compliance with the U.S. Export Administration Act, the Export Administration Regulations, and the Foreign Corrupt Practices Act. Suppliers to SBM, when representing SBM or performing SBM work, must similarly comply with these requirements.

Customer and Employee Privacy and Personal Information

As an SBM Supply/Service Partner, you have an important role in helping SBM to sustain our customers’ and employees’ confidence in the company and its products and services. To meet these concerns, you must use care in working with all

Reporting Concerns or Misconduct

Supply/Service Partners must report concerns and potential or actual misconduct that violates this Code of Conduct. Supply/Service Partners shall, consistent with any applicable law and privilege, provide reasonable assistance to any investigation by SBM of a violation or violations of the Code of Conduct. When reporting suspected or actual misconduct, Supply/Service Partners should report concerns pertaining to SBM Management Services, LP to the Procurement Department via email, procurement@sbmcorp.com. Supply/Service Partners and their agents must protect anyone who works for them, either as an employee or a consultant, from any form of retaliation for reporting suspected or actual misconduct.

Labor & Human Rights

Supply/Service Partners of products or services produced in or provided from the United States shall comply with all applicable federal, state and/or local laws and regulations. Supply/Service Partners of products or services produced or provided from outside the United States shall comply with applicable laws and regulations of relevant countries. However, regardless of applicable laws and regulations, Supply/Service Partners must uphold the human rights of workers by treating them with dignity and respect.

Supply/Service Partners retained by SBM and their agents are fully responsible for the quality, performance, behavior, supervision and protection of their personnel. SBM retains the right in its absolute discretion to require the removal of any personnel of a Supply/Service Partner from an SBM job site in appropriate circumstances, for example: (a) if there is reasonable cause to believe a person is under the influence of alcohol, drugs, or other substances that adversely affect that person’s work or creates a safety risk, (b) for commission of an illegal act, (c) for threatening or harassing the public or an SBM employee, or otherwise engaging in abusive or disruptive conduct, (d) for violation of an SBM policy, or (e) for performing an unsafe act.

SBM is committed to upholding the human rights of workers and treating them with dignity and respect. This applies to all workers, including temporary, migrant, student, contract, direct employee, and any other type of worker. As a result, suppliers must manage their own workforce in order to achieve the following results:

Freely Chosen Employment and Combating Modern Slavery. Suppliers will not use or permit any form of forced, bonded, or indentured labor. All work must be voluntary, and all workers must be free to terminate their employment at any time. Suppliers will not hold workers’ identity, immigration, or work permit documents longer than reasonably necessary for administrative processing. Suppliers are expected not to require workers to pay recruitment fees or other fees for their employment, either directly or through third parties, and are expected to repay any worker that has paid such fees. Suppliers will not unreasonably restrict workers’ freedom to move into, out of, or at working facilities. As part of the hiring process, suppliers are expected to give each worker a written agreement describing the worker’s terms of employment in a language understood by the worker, and, if internationally relocating, the written agreement will be provided before they leave their country of origin.

Young Workers and Student Interns. Suppliers will not use child labor. “Child” means any person under age 15, under the age for completing compulsory education, or under the minimum age for employment in the country, whichever is greatest. Workers under the age of 18 will not perform work that is likely to jeopardize their health or safety, including night shifts and overtime. Suppliers may use legitimate, properly-managed apprenticeship programs, such as student internships. Unless otherwise addressed by local law, suppliers are expected to pay student workers, interns, and apprentices at least the same wage rates as other entry-level workers performing equal or similar tasks.

Wages. Suppliers will pay legally-mandated wages and benefits, will comply with the law regarding wage deductions, and will provide workers with the basis on which workers are paid via pay stub or similar documentation. Suppliers are expected not to deduct from wages as a disciplinary measure.

Working Hours. Except in emergency or unusual situations, for suppliers’ workers paid hourly, workweeks are expected not to exceed 60 hours per week (including overtime) or, if less, the maximum set by local law. Workers should be allowed at least one day off every seven days.

Fair Treatment, Non-Discrimination, Diversity and Inclusion. Suppliers will not permit harassment, abuse, corporal punishment, or inhumane treatment. Suppliers will not subject workers or potential workers to unlawful medical tests or physical exams.

Suppliers will not discriminate in screening, hiring, or employment practices based on race, color, age, sex, gender, gender identity, gender expression, sexual orientation, marital status, ethnicity, national origin, caste, disability, genetic information, medical condition, pregnancy, religion, political affiliation, union membership, covered veteran status, or body art. Workers’ religious practices will be reasonably accommodated. Suppliers will not inquire about potential workers’ criminal histories on employment applications or before initial interviews, or, if no interview is conducted, before making conditional offers of employment. In addition, suppliers will demonstrate a commitment to identify, measure, and improve a culture of diversity and inclusion through all aspects of workplace management.

Health and Safety

Supply/Service Partners to SBM must conform to all applicable health, safety and environmental laws and regulations. Ongoing worker input and education is the key to identifying and resolving health and safety issues in the workplace, and these are critical to the overall success of a safety and health program. Accordingly, suppliers retained by SBM should address the following:

Occupational Safety

Every Supply/Service Partner shall be committed to the safety and health of its employees, and shall ensure that required training of personnel has been completed prior to initiating any work activity. The Supply/Service Partner should have or subscribe to a written safety and health program. Supply/Service Partners are responsible for addressing and controlling worker exposure to potential safety hazards in conformance with all applicable standards and/or regulations and by utilizing suitable means, e.g., design, engineering and administrative controls, preventative maintenance, training, work procedures, and appropriate Personal Protective Equipment (PPE).

Occupational Injury and Illness

Supply/Service Partners to SBM shall have procedures and systems to manage, track and report: motor vehicle incidents, occupational injuries and illnesses, and exposure of workers to chemical, biological and physical agents. Such procedures and systems shall implement all applicable laws and regulations, and include provisions to: a) encourage worker reporting; b) classify and record injury and illness cases; and c) investigate cases and implement corrective actions.


Adverse effects on the community, environment and natural resources are to be minimized while safeguarding the health and safety of the public. Supply/Service Partners must comply with all applicable health, safety and environmental laws and regulations when conducting business with SBM. By way of example and not limitation, SBM’s Supply/Service Partners must:

  • Obtain and keep current all required environmental permits and registrations;
  • Reduce, control and/or eliminate wastewater, waste and pollution at the source;
  • Reduce, control and/or eliminate air emissions of volatile chemicals, corrosives, particulates, aerosols and combustion products;
  • Conform to applicable labeling and warning requirements;
  • Identify, manage, store, move and handle hazardous substances in accordance with law.

Management System

Supply/Service Partners must manifest their commitment to implementation of the principles of this Code by having or establishing an appropriate management system to address compliance with these principles and detection and correction of any non-compliance. An appropriate management system should contain the following elements:

  • Management Accountability Executive responsibility for ensuring implementation and periodic review of the status of the management systems.
  • Legal and Customer Requirements Identification, monitoring and understanding of applicable laws, regulations and customer requirements, and procedures for reviewing compliance and correcting any deficiencies.
  • Communication Process for communicating clear and accurate information about Supply/Service Partner’s performance, practices and expectations to workers, suppliers, services, and customers.