Supplier Code
of Conduct

Suppliers shall conduct their business using fair business practices, consistent with fair competition, truth in marketing, anti-trust laws and in compliance with all appliable laws, rules, and regulations that prohibit restriction of competition.

Suppliers shall have a means for employees to report grievances anonymously and shall encourage their workers to report concerns or illegal activities within their workplace without threat of retaliation, intimidation, or harassment. Suppliers shall monitor, investigate, and take corrective action where needed. Suppliers will document and maintain records of reported cases.

Suppliers will protect the personal information of everyone they do business with, including customers, suppliers, consumers, and employees.

Suppliers will avoid even the appearance of conflicts of interest in working with Sterling and shall not allow personal or family interests to influence them in any business dealings with us. Suppliers will have policies and financial controls in place to prevent conflicts of interest affecting procurement and financial decision-making.

Suppliers will not offer any form of bribery, corruption, extortion, kick back or embezzlement, will not make illegal payments directly or indirectly, and will have policies, monitoring and enforcement in place to ensure compliance with anti-corruption laws.

Suppliers shall not use any form of forced, bonded or involuntary labor and must comply with applicable laws combating modern slavery.

Suppliers shall not use child labor below the age of 16 or the applicable minimum legal age, whichever is higher.

Inhumane treatment and/or physical punishment of workers is prohibited. Suppliers shall not permit harassment or abuse of any kind.

Suppliers will not permit discrimination in screening, hiring, training, promotion, compensation, or any other employment practice based on race, color, age, sex, gender identity, gender expression, sexual orientation, ethnicity, national origin, genetic information, medical condition, pregnancy, disability, caste, religion, political affiliation, union membership, marital status, covered veteran status or any additional illegally discriminatory characteristic. Wages and fringe benefits – Work hours, minimum wages and overtime hours paid to employees as well as any fringe benefits, must be compliant with applicable regulations. Wages should be paid at regular intervals with reasonable frequency. Deductions from wages for disciplinary reasons are prohibited.

Suppliers should encourage their employees to communicate with their superiors concerning working conditions, compensation, etc. without fear of intimidation or harassment. Employees should be permitted to associate freely, bargain collectively, and seek representation in accordance with local laws.

Suppliers shall protect workers from unsafe working conditions such as exposure to physical or environmental hazards in the workplace.

Suppliers shall have programs in place to operate and maintain all operations in the safest manner possible. Suppliers shall identify, assess, and track possible emergency situations in the workplace and minimize their impact by implementing emergency response plans and procedures.

Suppliers using Sterling facilities will comply with all applicable policies and procedures applicable to those facilities.

Suppliers must keep confidential all Sterling proprietary and sensitive information. Supplies must take precautions to safeguard this information, including that Supplier’s personnel are adequately trained.

Suppliers must comply with all appliable data privacy and security laws and regulations. Suppliers must maintain appropriate procedures, safeguards, and controls to secure and protect the confidentiality, integrity, and availability of confidential information, including personal information, received from, processed on behalf of, or disclosed by Sterling.

Suppliers are expected to maintain adequate documentation and records to demonstrate they are in compliance with this code of conduct, as well as all applicable laws and regulations. Records prepared for Sterling or maintained on behalf of Sterling must be accurate, complete, and retained in accordance with applicable legal and regulatory record-keeping requirements, or as otherwise specified in a relevant agreement between the supplier and Sterling.