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University Supplier Code of Conduct
The University of Pennsylvania is committed to conducting its procurement
business in an ethical, legal and socially responsible manner. The University
expects its suppliers to share this commitment and, therefore, has established
this Supplier Code of Conduct. All University suppliers must
meet the following minimum requirements in order to do business with the University.
Compliance with Laws, Regulations and Published Standards
All suppliers to the University of Pennsylvania must comply with all applicable
laws, codes or regulations of the countries, states and localities in which they
operate. This includes, but is not limited to, laws and regulations relating to
environmental, occupational health and safety, and labor practices. In addition,
University suppliers must require their suppliers (including temporary labor agencies)
to do the same.
Environmental Practices
All suppliers to the University of Pennsylvania shall comply with all environmental
laws and regulations applicable to their operations worldwide. Such compliance shall
include, among other things, the following items:
- Obtaining and maintaining environmental permits and timely filing of required
reports
- Proper handling and disposition of hazardous materials
- Monitoring, controlling and treating discharges generated from operations
Occupational Health and Safety Practices
All suppliers to the University of Pennsylvania are expected to provide their
employees with a safe and healthy working environment in order to prevent accidents
and injury to health arising out of, linked with, or occurring in the course of work
or as a result of the operation of the supplier. Suppliers shall, among other things,
provide:
- Occupational health and safety training
- A system for injury and illness reporting
- Medical treatment and/or compensation to injured/ill workers arising as a
result of working for supplier
- Machine safeguarding and other protective measures to prevent
injuries/illnesses to workers
- Clean and safe facilities
Labor Practices
All suppliers to the University of Pennsylvania are expected to adopt sound labor
practices and treat their workers fairly in accordance with local laws and regulations.
In addition, suppliers must comply with the following standards:
- Freely Chosen Employment - Suppliers shall not use any forced labor, whether
in the form of prison labor, indentured labor, bonded labor or otherwise.
- No Child Labor - Suppliers shall comply with local minimum working age laws
and requirements and not employ child labor.
- Minimum Wages - Suppliers shall provide wages for regular and overtime work
and benefits that meet or exceed legal requirements.
- Working Hours - Suppliers shall not require workers to work more than the
maximum hours of daily labor set by local laws.
- No Harsh, Inhumane Treatment or Abuse - Suppliers shall treat each employee
with dignity and respect. In no event shall Supplier's workers be subject to
threats of violence, physical punishment, confinement or other form of physical,
sexual, psychological or verbal harassment or abuse.
- No Discrimination - Suppliers shall not discriminate in its employment
practices on the basis of race, color, religion, sex, age, physical disability,
national origin, creed or any other basis prohibited by law.
- Freedom of Association - Suppliers shall recognize and respect the rights
of its workers to organize in labor unions in accordance with local labor laws
and established practices.
Ethical Business Practices
All suppliers to the University of Pennsylvania are expected to conduct their
businesses in accordance with the highest standards of ethical behavior and in
accordance with applicable laws and regulations. Suppliers are expected to conform
to these requirements in each of the following areas:
- Fair Trade Practices - Suppliers shall not engage in collusive bidding,
price fixing, price discrimination or other unfair trade practices in violation
of antitrust laws.
- Bribery, Kickbacks and Fraud - No funds or assets of the supplier shall be
paid, loaned or otherwise disbursed as bribes, "kickbacks", or other payments
designed to influence or compromise the conduct of the University.
- Foreign Corrupt Practices Act - While laws and customs vary throughout the
world, all suppliers must comply with foreign legal requirements and United
States laws that apply to foreign operations, including the Foreign Corrupt
Practices Act. The Foreign Corrupt Practices Act generally makes it unlawful
to give anything of value to foreign government officials, foreign political
parties, party officials, or candidates for public office for the purposes of
obtaining or retaining business.
- University Policies and Procedures - Suppliers must comply with the
University's published policies
and procedures, including, but not limited to, the University's
Conflict of
Interest and Procurement Code of Ethics
policies.
- Intellectual Property Rights - Suppliers shall respect the intellectual
property rights of others, especially the University, its affiliates and business
partners. Suppliers shall take appropriate steps to safeguard and maintain
confidential and proprietary information of the University and shall use such
information only for the purposes specified for use by the University.
Suppliers shall observe and respect all University patents, trademarks and
copyrights and comply with all requirements as to their use as established by
the University. Suppliers shall not transmit confidential or proprietary
information of the University via the internet unless such information is
encrypted in accordance with minimum standards established by the University.
Export Sanctions and Terrorism Activities
All suppliers to the University of Pennsylvania must abide by all economic
sanctions or trade embargoes that the United States has adopted, whether they apply
to foreign countries, political organizations or particular foreign individuals
and entities. Suppliers should not directly or indirectly engage in or support
any terrorist activity. Neither suppliers nor any of their affiliates, nor any
officer or director of the supplier or any of its affiliates, should be included
on any lists of terrorists or terrorist organizations compiled by the United States
government or any other national or international body, including but not limited
to: (i) the U.S. Treasury Department's Specially Designated Nationals List,
(ii) the U.S. State Department's Terrorist Exclusion List, (iii) the United Nations
List Pursuant to Security Council Resolution 1390 (2002) and Paragraphs 4(B)
or Resolution 1267(1999) and 8(C) of Resolution 1333 (2000), and (iv) the European
Union List Implementing Article (2)(3) of Regulation (EC) No. 2580/2001 on Specific
Restrictive Measures Directed Against Certain Persons and Entities with a View to
Combating Terrorism.
Unauthorized Solicitations
All suppliers to the University of Pennsylvania must comply with all guidelines
issued by the University relating to access to University facilities, offices and
departments, and employees. No Supplier shall use the University's computer system,
including its electronic mail system and internet site, for the purpose of sending
unsolicited electronic mail messages to the University community. Suppliers are
not permitted to use the University's intramural mail system for unauthorized
solicitation to employees. Suppliers must receive prior written authorization
from the University's Chief Procurement Office to hold on-campus trade shows,
exhibits, or product demonstrations.
Monitoring and Compliance
All suppliers to the University of Pennsylvania must conduct audits and inspections
to insure their compliance with this Supplier Code of Conduct and applicable legal
requirements. If a supplier identifies areas of non-compliance, the supplier agrees
to notify the Purchasing Services Department as to its plans to remedy any such
non-compliance.
The University or its representatives may engage in monitoring activities to confirm
Supplier's compliance to this Supplier Code of Conduct, including on-site inspections
of facilities, use of questionnaires, review of publicly available information, or
other measures necessary to assess supplier's performance. Any University supplier
or University employee that becomes aware of violations of this policy is obligated
to notify the Purchasing Services Department. Based on the assessment of information
made available to the University, the University of Pennsylvania reserves the right
(in addition to all other legal and contractual rights) to disqualify any potential
supplier or terminate any relationship with any current supplier found to be in
violation of this Supplier Code of Conduct without liability to the University.
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