PARTNER CODE OF CONDUCT

1. Overview
   1. The Company (i.e., Continuous Compliance, LLC dba FutureFeed, the publisher of the Services) aspires to be more than just a good company – we want to be a great company. We are committed to our mission of securing our nation’s supply chain from our adversaries. Achieving our mission isn’t just about building innovative technology. Our mission reflects who we are as a company, how we manage our business internally, and how we work externally with customers, partners, governments, and suppliers.
2. Changes to Policy
   1. The Company may change this Policy by linking to an updated version of the Policy at www.futurefeed.co/legal and such updates will be effective upon posting.
   2. Click here to contact us if you have a question about this Partner Code of Conduct.
3. Values and Expectations
   1. The Company’s partners and their employees, agents, and subcontractors (collectively referred to as “Partners”), in collaboration with the Company, serve our customers. It is important to the Company that Partners embrace and continually improve on the Company’s values. While conducting business with the Company and the Company‘s employees, agents, subcontractors, and customers, the Company expects its Partners to commit to operating in full compliance with all applicable laws and regulations, and to adhere to the principles outlined in this Partner Code of Conduct.
   2. The Company’s values are the foundation of our success and reflect our continued commitment to ethical and responsible business practices. Our internal policies establish our standards which help the Company live our values and apply to all the Company’s employees, directors, and officers. Our values include:
      1. Respect: We recognize that the thoughts, feelings, and backgrounds of others are as important as our own. It starts with our belief that every person has intrinsic worth. We invite in perspectives that are different from our own and then we really listen. We treat each other with decency, and when we disagree, we do so without diminishing each other.
      2. Integrity: We are honest, ethical, and trustworthy. Trust is built when we keep our word and do what we know is right. Even when it’s hard, when we’re under stress, and when no one is looking. We’re transparent, while respecting confidentiality. We tell others the truth with care.
      3. Accountability: We accept full responsibility for our decisions, actions, and results. Credibility is created when we take ownership for what we say and do and for the outcomes we create and how they’re delivered. We make our intentions and goals clear and invite input from others on how we’re doing.
   3. This Partner Code of Conduct is not intended to replace, supersede, or conflict with any applicable law, regulation or contractual obligation with the Company.
   4. Partners may report any issue related to this Partner Code of Conduct, including any request by a representative of the Company for Partners to act in a manner that conflicts with this Partner Code of Conduct, by using any of the resources listed below. The Company’s employees, agents, subcontractors, and customers may use similar resources to report a Partner’s actions that conflict with this Partner Code of Conduct. The Company may enforce violations of this Partner Code of Conduct by taking such action(s) as it deems appropriate, including, without limitation, suspension or termination of the Partner’s relationship with the Company in the manner described in the applicable agreement(s) between the Company and Partner.
4. Business Practices, Ethics and Compliance
   1. Law Abiding: While conducting business with the Company’s customers, the Company’s Partners will conduct their business practices and activities in accordance with applicable law, with integrity, fairness, respect and in an ethical manner.
   2. Anti-Corruption: The Company’s Partners will comply with all applicable anti-corruption and anti- money laundering laws. All forms of bribery, kickbacks and other corruption are prohibited. No Partner will improperly influence any act or decision of any governmental official, employee or political candidate, including, without limitation, through the provision of any improper or unlawful gifts, meals, travel or entertainment.
   3. Fair Competition and Antitrust laws: Partners will conduct their business in full compliance with all applicable fair competition and antitrust laws.
   4. Public Sector Procurements: When selling to public sector entities, Partners will support fair and open competition by complying with all laws and regulations related to government procurement, tenders, and bids. Partners will not conspire with other partners, including but not limited to bid rigging, placing orders prior to tender finalization, price fixing, or other forms of collusion.
   5. Business Records and Accounting: The business records of Partners will conform with applicable legal, accounting, and regulatory requirements.
   6. Technology Fraud: Partners are prohibited from engaging in false or deceptive business practices, including any activities which may mislead customers or consumers. These prohibited practices include engaging in technology fraud and activities which may mislead seniors, children, or other vulnerable consumers to purchase or subscribe for unneeded technical support or services. To better protect these vulnerable consumers, Partners should also not engage in the “cold-calling” of such consumers for the purpose of engaging in any of those prohibited practices.
   7. Conflicts of Interest: Where a Partner is advising a customer, especially a governmental customer, on the selection of products and/or services and has a fiduciary or contractual obligation to that customer, the Partner will avoid engaging in business activities that constitutes or could create the appearance of a conflict of interest.
   8. Disclosure of Fees to Governmental and State-Owned Entities: If required by law or under a contract, Partners will disclose to the applicable governmental entity customer or state-owned entity customer, the potential fees, Commissions, or other compensation that Partner will receive from the Company in connection with the products or services being procured.
   9. Advertising and Marketing: Partners’ advertising and marketing activities will be conducted truthfully, accurately and in accordance with applicable law, rules, and regulations. Partners must ensure that all communications to customers be truthful, accurate, and not misleading.
5. Human Rights and Fair Labor Practices
   1. Safe Work Environment: Partners will provide a safe and healthy work environment, fully compliant with all employment, health, and safety laws.
   2. No Forced Labor; No Child Labor: Partners will abide by local minimum wage and maximum working hour requirements, are not to use forced labor or to use labor contacts that impose unreasonable limitations on a worker’s ability to leave Partner’s employment. The use of child labor is prohibited.
   3. Non-Discrimination: Partners will not illegally discriminate in hiring, compensation, access to training, promotion, termination and/or retirement decisions based on race, sex, national origin, religion, age, disability, gender identity or expression, marital status, medical condition, physical or mental disability, pregnancy, sexual orientation, political affiliation, union membership, veteran status or other protected characteristic or status.
6. Professional Conduct
   1. Professionalism: Partners will conduct themselves in a professional manner at all times. This helps the Company to create an inclusive, productive, respectful and professional environment, free from any forms of discrimination or harassment.
   2. Inappropriate Language: Partners will not use any form of language which may be considered discriminatory, intimidating, harassing, threatening, abusive, sexually explicit, or otherwise offensive or inappropriate.
   3. Treat Others with Fairness, Dignity and Respect: The Company will not tolerate, and Partners must not engage in, any form of sexual or other harassment. Sexual harassment is unwelcome verbal or physical behavior based on sex and includes gender-based harassment of a person of the same gender. Examples include unwelcome sexual advances or physical contact, sexual comments, or inappropriate gender-based jokes, unwelcome romantic attention, offering a benefit or preferential treatment in exchange for sexual favors, sharing or displaying sexually explicit content and using sexually degrading words. Other examples of harassment include comments, jokes or degrading words based on race, sex, national origin, religion, age, disability, gender identity or expression, marital status, medical condition, physical or mental disability, pregnancy, sexual orientation, political affiliation, union membership, veteran status or other protected characteristics or status.
   4. Event Behavior: In any event sponsored or hosted by the Company or during which Partners may interact with any of the Company’s employees, agents, subcontractors, or customers, regardless of location, Partners must behave in a professional manner including responsible alcohol use and continued adherence to this Partner Code of Conduct.
7. Environmental Regulations and Protections
   1. The Company expects Partners to share the Company’s commitment to the environment.
   2. Registrations; Permits: Partners will comply with all applicable environmental laws and regulations, keep current all required environmental registrations and permits relevant to its businesses and implement appropriate conservation measures.
8. Intellectual Property and Protection of Information
   1. Partners will respect intellectual property rights, protect confidential information, and comply with privacy rules and regulations.
   2. Legitimately Acquired Software: Partners will only use information technology and software that has been legitimately acquired and licensed.
   3. Comply with Ownership Rights: Partners will respect the intellectual property ownership rights of all third parties. Partners will only use lawful methods of gathering competitive intelligence about products or manufacturers that compete with the Company’s technologies.
9. Governance
   1. Partners are expected to develop a culture of compliance with view for continuous improvement.
   2. Risk Management: Partners will have applicable business controls to detect and prevent unlawful and malicious conduct by their employees and counterparties. These business controls should be adequately resourced and be periodically reviewed and updated to take into account the current risk environment.
   3. Training: Partners will ensure that they have an adequate training program that achieves the appropriate levels of knowledge and skills to maintain compliance with applicable laws, regulations, and standards.
   4. Assistance: Partners will provide reasonable assistance to the Company in connection with any investigation of a violation of this Partner Code of Conduct or applicable law. Partners will, upon request, permit the Company reasonable access to all records and other applicable documentation concerning Partners’ compliance with this Partner Code of Conduct and applicable law.
10. Raising Concerns and Reporting Questionable Behavior
    1. Partners are encouraged to work with their primary contact at the Company in resolving a business practice or compliance concerns. However, the Company recognizes that there may be times when this is not possible or appropriate. In such instances, Partners should report any concerns about violation of this policy or applicable laws to their legal department and/or their ethics and compliance officer. Partners should also report to the Company through the following alternatives:
       1. By email: [email protected]
       2. By postal mail: Director of Compliance, FutureFeed, 936 Fell Street, Baltimore, MD 21231

Version: 22.06a

Change Log:

22.06a – 16-JUN-2022 – Updated to refer to Services rather than individual products

22.04a – 18-APR-2022 – Clerical updates

22.01a – 15-JAN-2022 – Initial Online Version Publication