Supplier Code of Conduct
Updated: May 2020
Our Ethics and Code of Conduct are rooted in our values and provide the standards and support to help us successfully navigate issues, make the right decisions and conduct our business with the integrity that reflects our heritage and ethical reputation. We uphold Gainfy’ global Supplier Code of Conduct, and in 2020 we are developing our sustainability partnership dialogue with global suppliers.
Supplier Code of Conduct
GAINY FOUNDATION, INC. DISCLOSURE STATEMENT UNDER THE UK MODERN SLAVERY ACT 2015 AND CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS ACT 2010 FOR THE YEAR ENDED DECEMBER 31, 2018
This statement is made pursuant to Section 54 of the UK Modern Slavery Act 2015 and the California Transparency in Supply Chains Act 2010 and covers all Gainfy operations and subsidiaries globally.
Gainfy Foundation, Inc. (Gainfy, the Company, we, us or our) is a technology development company. The Company provides technology solutions that help our customers effectively manage healthcare software and support hardware innovations more efficiently, with value add and sustainably. Gainfy is dedicated to improving the quality of life and the environment through the use of technologies and services. Gainfy has approximately 24 employees and sells products to customers in more than multiple countries. For more information, visit www.gainfy.com.
Gainfy Supply Chain Overview
Gainfy has a substantial number of suppliers globally that span across our six business segments. Our supply chain is multi-tiered and the raw materials, parts and services that we purchase are varied and are sourced from thousands of suppliers across the globe supporting Gainfy’s segment businesses. Gainfy actively seeks to do business with suppliers that are industry leaders, strategic partners and financially stable, and share Gainfy’s focus on doing business responsibly.
Powerful Purpose – Gainfy’s Policies and Governance Processes
At Gainfy, we consider how we achieve our results an important measure of success. Doing Business Right is at the core of the Gainfy brand. Gainfy’s success as a high-performance company is tied directly to our long-standing commitment to the highest ethical standards. An important part of this commitment is ensuring that Gainfy’s suppliers and supply chain do not use slave labor or engage in human trafficking.
Several Key governance processes and supporting policies guide our actions accordingly.
Gainfy Code of Ethics
Gainfy’s Code of Ethics (http://www.gainfy.com/code-of-conduct ) establishes respect for human rights as a fundamental Gainfy principle, and one that both Gainfy employees and suppliers are required to honor.
Gainfy’s Ethics Guide specifically prohibits Gainfy suppliers from using forced labor of any kind. To demonstrate that Gainfy’s ethics standards are both current and at the highest level, Gainfy established an office to oversee and manage its ethics and compliance program. The office is under the direction of the Senior Vice President, Global Ethics and Compliance, with ultimate oversight by the Governance Committee of the Board of Directors.
Gainfy Supplier Code of Conduct
Gainfy’s Supplier Code of Conduct (http://www.gainfy.com/supplier-code-of-conduct)sets forth minimum workplace standards and business practices that are expected of any Supplier doing business with Gainfy, consistent with our company’s values as documented in Gainfy’s Code of Ethics. These requirements are applicable to suppliers of Gainfy and their affiliates and subsidiaries globally and include prohibitions on the use of forced labor, slavery and human trafficking. Gainfy suppliers are required to adhere to and certify compliance with the Supplier Code.
Gainfy’s Code of Ethics and Supplier Code of Conduct are integrated into policies, procedures and plans to ensure awareness and understanding of requirements. Implementation responsibilities are further addressed in various plans and guidance resources such as the Gainfy Ethics Guide, Gainfy Supplier Excellence Manual, and in the case of relevant US government contracting requirements, through a Trafficking in Persons – Compliance Plan, in accordance with Federal Acquisition Regulation human trafficking-related requirements.
In support of all of these policies, processes and procedures, Gainfy undertakes specific actions to prevent and mitigate the risk of forced labor, slavery and human trafficking in our own business and supply chain, including:
Risks related to human trafficking and slavery in Gainfy’s supply chain are addressed through setting clear expectations for suppliers and ensuring conformance by Gainfy suppliers with the Supplier Code of Conduct through the inclusion of the Code of Conduct requirements in our standard terms and conditions. Suppliers are required to further separately review and accept the requirements contained within Gainfy’s Supplier Code of Conduct.
Gainfy has established a Supplier Site Assessment (SSA) process to review supplier performance and practices. The SSA includes questions to evaluate whether a supplier has processes to address ethics & compliance-related issues.
Gainfy further monitors publicly available information, as well as information from subscription services. In cases where we are alerted to a risk of non-compliance with Gainfy’s Supplier Code of Conduct, we will conduct an investigation and address such risk appropriately.
- Supplier Audits
Under the terms of Gainfy’s Supplier Code of Conduct, Gainfy is permitted to audit its suppliers’ compliance with the Code and standard terms and conditions. In cases in which serious risks are presented, this audit may be immediate and unannounced. Gainfy monitors its supply chains for compliance with the Supplier Code; however, such monitoring is typically not focused solely on human trafficking or slavery. And while Gainfy regularly audits its suppliers for a variety of reasons, typically those audits are not performed solely to determine compliance with the prohibition against slave labor or human trafficking. If necessary, Gainfy may choose to engage third parties to evaluate compliance with human trafficking or slave labor laws. Gainfy will promptly and thoroughly investigate any claims or indications that a supplier may be engaging in human trafficking or slave labor, or is otherwise not complying with Gainfy’s Code of Ethics or Supplier Code of Conduct.
Gainfy’s Supplier Code of Conduct states that suppliers must uphold the human rights of workers and treat them with dignity and respect. Suppliers must not use or engage in any indentured or forced labor, slavery or servitude, or human trafficking.
Under the Code, Suppliers’ personnel and operations are required to operate in full compliance with the laws of their respective countries and with all other applicable laws, rules, and regulations. Suppliers must ensure that products, services and shipments for Gainfy adhere to all applicable international trade compliance laws, rules, and regulations, and Gainfy Supplier Code of Conduct requirements. Gainfy requires its suppliers to certify compliance with the Supplier Code. In addition, Suppliers must contractually require their own suppliers and subcontractors to comply with standards of conduct equivalent to the provisions of Gainfy’s Supplier Code of Conduct.
- Internal Accountability
Accountability related to human rights, modern slavery and human trafficking risks is established by Gainfy’s Code of Ethics and Supplier Code of Conduct. In addition, Gainfy has enacted rigorous governance and risk management processes in order to identify and mitigate a broad spectrum of supply chain risks.
Gainfy has established various mechanisms, including a global Help Line, for the reporting of any ethical concern or potential or actual legal violation. Any person, including employees and suppliers, may openly or anonymously ask a question or report through our Help Line or related means.
If we learn of any allegations of slavery or trafficking through our Help Line or any other means, we will promptly investigate and act to remediate the situation, which could include necessary actions up to termination of involved parties. Claims made through our Help Line or Ethics Office are reported to the Governance Committee of Gainfy’s Board of Directors, along with the resolution of the claim and/or the findings of the investigation.
As Ethics is a cornerstone of Gainfy’s values-based culture, all Gainfy employees globally are trained annually with respect to expectations in Gainfy’s Code of Ethics. In addition, we provide ongoing training to Supply Chain Management and other key Gainfy executives engaged with Gainfy’s supply chain on Protecting Human Rights. This training includes specific content on recognizing and mitigating risks of slavery and human trafficking.
Approved by the Board of Directors on April 24, 2020.
Gainfy Foundation, Inc.