USAA SUPPLIER CODE OF CONDUCT

Transcription

1 USAA SUPPLIER CODE OF CONDUCT

2 At USAA, we live our core values of service, loyalty, honesty, and integrity. These simple yet essential values ensure that we conduct ourselves with the utmost integrity, delivering high quality products while following all applicable laws, regulations, and standards of business conduct, and avoiding even the appearance of impropriety. It s what our members expect. We are committed to meeting those expectations, and we in turn hold our suppliers to the highest standards of ethical conduct. This Supplier Code of Conduct expresses the expectations we hold for our suppliers, and mirrors the standards we set for our own employees in our USAA Code of Business Ethics and Conduct. Suppliers, vendors, contractors, consultants, agents, and other providers of goods and services who do business with USAA are expected to follow this Code. Nothing in this Code is meant to supersede any more specific provision in a particular contract. Conflicts of Interest Suppliers and contractors are expected to avoid both actual and potential conflicts of interest those circumstances in which their personal interests influence or appear to influence their ability to act in the best interest of USAA and its members. We expect our suppliers to report to USAA any situations of potential or apparent conflicts between their personal interests and the interests of USAA. Ethical Business Practices Suppliers are expected to refrain from any and all forms of illegal or improper activity, including corruption, misrepresentation, extortion, embezzlement, bribery, insider trading, or utilization of Conflict Minerals. Suppliers must perform in compliance with all applicable local, state, federal, and international laws and regulations, such as without limitation, the U.S. Foreign Corrupt Practices Act and the U.K. Bribery Act. Confidential Information Suppliers must take proper care to protect all sensitive information, including confidential, proprietary, and personal information of USAA and its members in accordance with applicable laws, prevailing industry practices, and contract terms. Suppliers are expected to safeguard the confidential information of third parties and not use confidential third-party information to benefit USAA.

3 Financial Integrity Suppliers are expected to accurately record, maintain, and report business documentation, including but not limited to, financial accounts, time entry, expense reports, payroll records, resumes and submissions to USAA, the member or regulatory authorities. Fair Competition and Anti-Trust Suppliers are expected to conduct business in accordance with all applicable anti-trust or anti-competition laws and regulations. Entertainment, Favors, and Gifts In any business relationship, suppliers are expected to ensure that the offering or receipt of any gift or business courtesy is permitted by law and regulation; does not violate the rules and standards of the recipient s organization; is consistent with reasonable marketplace customs; and will not adversely impact the reputation of USAA. USAA employees are not allowed to accept gifts, favors, or entertainment intended to improperly influence, or could be perceived to improperly influence, their judgment or performance as a USAA employee. USAA employees are also not allowed to accept gifts valued over $100, and may not be in the form of cash, gift cards, or alcohol. USAA procurement personnel may not accept gifts or any other form of consideration from any individual or entity doing business or seeking to do business with USAA. Suppliers are expected to not offer gifts, favors, or entertainment to USAA employees that would violate this policy Discrimination and Harassment Suppliers are expected to comply with all applicable laws concerning discrimination in hiring and employment practices. Suppliers are encouraged to provide an inclusive and supportive working environment, free of harassment and discrimination, in which all employees are valued and empowered to succeed. Human Rights in the Workplace Suppliers are expected to maintain and promote fundamental human rights. Supplier employees should not be forced, bonded, indentured, or subjected to involuntary prison labor. Suppliers are expected to adhere to the minimum employment age limit defined by national law or regulation, and in no instance shall engage in child labor.

4 Workplace Safety Suppliers are expected to comply with applicable safety and health laws, regulations, policies, and procedures. Suppliers should provide for the health, safety, and welfare of their people, visitors, and others who may be affected by their activities. Compensation, Working Hours, and Conditions Suppliers are expected to provide compensation in compliance with all applicable wage laws, including those relating to minimum wages, overtime hours, and legally mandated benefits. Employees should be able to earn fair wages, as determined by applicable local law. Work weeks should not exceed the maximum set by local law. Suppliers should provide adequate and safe working conditions and comply with applicable health and safety policies and laws. Export/Import Control Suppliers must ensure that their business practices are in accordance with all applicable laws and regulations governing the export and import of domestic and foreign origin parts and components and related technical data. Environment Suppliers are encouraged to implement systems designed to reduce greenhouse gas emissions, increase energy efficiency, reduce water consumption, and increase waste diversion from landfills. Reporting and Accountability Suppliers are expected to provide their employees with access to an adequate avenue of raising issues or concerns without fear of retaliation. USAA reserves the right at any time to review a supplier s adherence to this code and to investigate any complaints or violation of policy.

5 The mission of USAA is to facilitate the financial security of its members, associates, and their families through the provision of a full range of highly competitive financial products and services. USAA is committed to the highest standards of ethics and professional conduct with members, employees, the communities in which we live and work, governments, and businesses with which we are affiliated. Corporate business activities and individual conduct must reflect good judgment and be consistent with USAA s core values of service, loyalty, honesty, and integrity. We expect our suppliers, contractors, and others who do business on our behalf, to conduct USAA-related business activities in compliance with the applicable laws and regulations and the standards set forth in our USAA Code of Business Ethics and Conduct. We encourage our suppliers to implement their own written code of conduct, and to flow down the principles of a code of conduct to the entities that furnish goods and services to them. Report misconduct to USAA s Office of Ethics: Mail: USAA Office of Ethics PO Box San Antonio, TX ethics@usaa.com 24-hour Anonymous Reporting Helpline: Inside the U.S.: (855) For Helpline numbers outside the U.S. go to: