Partner Code of Conduct

Partner Code of Conduct

PARTNER CODE OF CONDUCT

Effective: February 19, 2019

INTRODUCTION

NextPakk is committed to operating with the highest degree of integrity and in compliance with all applicable laws. We 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.

NextPakk requires Partners to agree to abide by all applicable laws, including anti-bribery and anti-harassment laws, and this Partner Code of Conduct (the “Code”). Failure to comply with this Code will be considered a breach of the Partner’s contract with NextPakk and may result in NextPakk terminating the business relationship with the Partner immediately.

COMPLIANCE WITH LAWS

All NextPakk Partners must comply with all applicable laws and regulations, including, but not limited to, those set forth below:

Labor, Health, and Safety

Partners must strictly comply with all applicable labor, health, and safety laws and regulations in all markets in which they operate.

Partners must prohibit unlawful discrimination or harassment in the workplace, which includes any behavior that creates an intimidating, unsafe or hostile environment. They must comply with the local minimum wage and maximum working hours requirements, and may not use forced, involuntary, or child labor.

Partners must provide all employees with safe and healthy working conditions, including by offering emergency training and resources, practicing industrial hygiene, and enacting equipment safety initiatives, as appropriate.

Anti-Corruption

Partners are strictly prohibited from, directly or indirectly, promising, giving, or authorizing the provision of anything of value to secure an improper advantage, to induce anyone to improperly perform a function or duty, to reward anyone for the improper performance of a function or duty, or with the belief that the acceptance of the thing of value is improper. A thing of value includes, but is not limited to, money, gifts, favors, donations, meals, and entertainment, regardless of amount.

Partners must comply with all applicable anti-corruption laws, including the U.S. Foreign Corrupt Practices Act, the Canadian Corruption of Foreign Public Officials Act, as well as any other applicable laws and regulations prohibiting public or commercial bribery, extortion, kickbacks, or other unlawful or improper means of conducting business.

Partners are prohibited from promising, giving, or authorizing the provision of “facilitating payments” to expedite or secure the performance of non-discretionary, routine governmental duties, even if permitted by the FCPA or local laws. Partners may never offer, promise, or give, gifts, hospitality and/or travel to government officials on NextPakk’s behalf for the purpose of improperly obtaining or retaining business or securing an improper business advantage.

Partners 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 NextPakk’s business or if doing so reasonably could be viewed as compromising the Partner’s ability to make objective decisions on behalf of NextPakk.

Competition

Partners must comply with all applicable laws and regulations regarding fair competition and antitrust. Among other things, Partners may not discuss or enter into a formal or informal agreement with any competitor of Partner about any of the following: (a) price; (b) matters affecting price; (c) production levels; (d) inventory levels; (e) bids; or (f) division of sales territory, products, customers, or suppliers.

Data and Information Privacy

Partners must comply with all applicable data privacy laws and regulations when processing the personal or identifying information of anyone with whom they conduct business, including but not limited to, suppliers, customers, consumers, and employees. Partners must also strictly safeguard the data and information privacy of any NextPakk-related information. Partners agree to make reasonable efforts to keep data secure and confidential at all times.

Intellectual Property and Confidential Information

Partners may not share or disclose NextPakk’s intellectual property, confidential information, or any other proprietary information that the Partner acquires through its engagement with NextPakk to any person or Partner. This includes, but is not limited to, information developed by the Partner in connection with its engagement with NextPakk, and any information relating to products, consumers, pricing, costs, strategies, programs, processes, and practices.

International Trade and Export Controls

Partners must comply with all applicable import, export, customs, sanctions, embargoes, boycott and other trade compliance laws and regulations.

Environmental

Partners must conduct their operations in ways that are environmentally responsible and in compliance with all environmental laws, regulations, and standards. As part of this commitment, Partners should act to promote energy efficiency, reduce pollution, and conserve resources.

ACCURATE BOOKS AND RECORDS AND AUDIT RIGHTS

Partners must keep accurate books, accounts, and records for all transactions related to business with NextPakk. As part of its commitment to transparency, Partners are required to cooperate fully in any government audits.

Partners are prohibited from using fictitious, inaccurate, or misleading documents to support transactions related to business with NextPakk, and are prohibited from engaging in false or misleading accounting practices, such as using undisclosed or unrecorded payments.

CONFLICTS OF INTEREST

A conflict of interest arises when personal or professional interests or activities conflict with, or appear to conflict with, the best interests of NextPakk or the Partner. Partners must disclose to NextPakk any apparent or actual conflict of interest regarding its relationship with NextPakk.

REPORTING CONCERNS

It is the obligation of every Partner to immediately report any known or suspected violations by their employees or representatives, as well as by NextPakk’s employees and representatives, of this Partner Code of Conduct. Reports can be made at https://help.nextpakk.com/consumers-contactsupport.