Virgin Pulse Vendor Code of Conduct

EFFECTIVE DATE:  January 1, 2022

WHO IS VIRGIN PULSE?

Virgin Pulse is a software company that designs technology aimed at cultivating positive employee lifestyle habits. Our goal is to promote positive change in individuals’ lives, and through that, in work environments across the world. Our technology, and the overall wellbeing experience we deliver, drives superior outcomes for an organization’s contributors and its business.

WHO DOES THIS CODE APPLY TO?

Virgin Pulse is committed to respecting people and supporting universal human rights, adhering to local laws and regulations, contributing positively to our communities, and minimizing our impact on the environment. This Vendor Code (“Code”) applies to any entity (“Vendor”) that (1) contracts with Virgin Pulse to provide goods or services to Virgin Pulse, (2) provides services on behalf of Virgin Pulse, or (3) participates in our platform partner programs.

BUSINESS ETHICS

Virgin Pulse expects Vendor to conduct all its business in an ethical and fair manner. This includes but is not limited to the following:

Conflicts of Interest

Virgin Pulse is committed to conducting all business and operations with the utmost integrity and high standards of behavior so that no conflict of interest exists or can be reasonably implied or construed to exist. A conflict of interest is any personal or financial interest, any business or personal activity or relationship, prior or current employment, or any obligation that may interfere with the ability to objectively perform job duties and responsibilities or impair independence and objectivity. Vendor must disclose any actual or potential conflict of interest related to its activities with Virgin Pulse to the Virgin Pulse compliance department.

Bribes, Kickbacks, and Other Improper Payments

Vendor shall comply with all applicable national and international anti-corruption laws and regulations, including the United States Foreign Corrupt Practices Act of 1977, the United Kingdom Bribery Act 2010, and all other applicable anti-bribery or anti-corruption laws and regulations at a local level. Vendor shall not (neither directly nor indirectly) offer, provide, or accept anything of value to improperly influence an official act or to secure an improper advantage to obtain or retain business. This includes facilitation payments or other benefits provided to public officials for routine non-discretionary actions.

Entertainment and Gifts

We believe in fair competition among Vendors for Virgin Pulse’s business and that sound business decisions are based on objective criteria. To ensure that fair competition and objectivity are maintained, Virgin Pulse prohibits its employees from accepting material gifts from outside business associates or from participating in lavish meals or other entertainment paid for by Vendor. Employees cannot accept any gifts, meals, or entertainment, regardless of value, from Vendors that are actively engaged in contract negotiation with Virgin Pulse. Similarly, Virgin Pulse employees may not give gifts to Vendors in a way that might influence the nature of the relationship between Virgin Pulse and the Vendor.

Money Laundering and Financial Records

Vendor shall comply with applicable laws and regulations designed to combat money laundering activities. Vendor shall maintain financial records and reports according to applicable laws and regulations.

Antitrust

Vendor shall comply with applicable competition and anti-trust laws, which are designed to prevent one business from gaining an unfair advantage and forcing other businesses out of the marketplace, such as price fixing, market allocation, group boycotts, price discrimination, or monopolization.

Trade Regulations and Sanctions

Vendor shall comply with all applicable export control, sanctions and customs laws, regulations, and trade laws. Vendor must notify Virgin Pulse if it is listed on, or added to, any US or international sanctions lists. Vendor must cooperate with Virgin Pulse to avoid violating any international sanctions.

DATA PROTECTION AND INFORMATION SECURITY

When handling or processing personal data of any sort, it is important for Vendor to protect the confidentiality, integrity, and availability of the personal data. Vendor must adhere to applicable data protection laws, including security of personal data, as well as to respective regulation regarding personal data of Virgin Pulse members, clients, employees, and stakeholders.

At all times the required level of information security and control to be ensured by Vendor must be commensurate with the sensitivity, value, and criticality of the information being processed throughout the lifecycle of the information. Vendor must notify Virgin Pulse of any security incident that compromises the confidentiality integrity or availability of personal data. Vendor can send notices to PrivacyOfficer@virginpulse.com.

HUMAN RIGHTS AND FAIR LABOR PRACTICES

Vendor must operate in a fashion that supports human rights and adhere to fair labor practices at all of its locations worldwide. This includes but is not limited to the following topics.

Human Trafficking and Modern Slavery

As part of our commitment to eradicating human trafficking and modern slavery, Virgin Pulse is committed to ensuring that there is no modern slavery or human trafficking within its supply chain. 

Vendor must comply with applicable international and US federal, state, and local laws and regulations.

Child Labor

Vendor shall not employ individuals who are (1) under the legal age of employment in any country or local jurisdiction, or (2) under the minimum age established for developing countries by the International Labour Organization, whichever is higher. See https://www.ilo.org/global/standards/subjects-covered-by-international-labour-standards/child-labour/lang–en/index.htm.

Forced Labor

Vendor shall not use any form of forced, bonded, compulsory labor, or modern forms of slavery. All labor must be voluntary. Workers must be allowed to maintain control over their identification documents (e.g., passports, work permits or any other personal legal documents). Vendor shall ensure that workers do not pay fees or make any payment connected to obtaining employment throughout the hiring process and the employment period. Punishment, mental and/or physical coercion as well as any other form of human trafficking are prohibited. Disciplinary policies and procedures shall be clearly defined and communicated to the workers.

Compensation and Working Hours

Vendor shall comply with all applicable local laws and mandatory industry standards regarding working hours, including overtime, rest breaks, and paid vacation. Vendor shall compensate its workers in accordance with local minimum wage legislation and terms of applicable collective bargaining agreements as well as with industry standards.

Freedom of Association and Collective Bargaining

Vendor shall recognize and respect the right to collective bargaining in accordance with applicable local laws.

Diversity and Inclusion

Vendor shall promote an inclusive work environment that values the diversity of its employees. Vendor must not discriminate in employment, including hiring, compensation, advancement, discipline, termination, or retirement, on the grounds of race, caste, gender, gender identity, sexual orientation, color, national origin, age, mental or physical disability, health conditions or diseases, pregnancy, religion, union membership, marital status, veteran status, or political affiliation.

SAFE AND HEALTHY WORK ENVIRONMENTS

Safety is a priority for Virgin Pulse and we expect it from our Vendor. Virgin Pulse requires that the conditions within which the employees of our Vendor are working align with applicable US and international standards, and that the care of the local environment through waste management and similar initiatives sufficiently conforms with US and internationally recognized standards.

SUSTAINABILITY

Protecting the environment is an ongoing commitment. Vendor must comply with all applicable national, state, and local laws and regulations in their country of operation and meet or exceed international standards for environmental protection.

Vendor of manufactured goods to Virgin Pulse must maintain supply chain records and make them available as required. Records must include material sources and any environmental certifications as applicable.

REPORTING CONCERNS TO VIRGIN PULSE

Vendors are encouraged to report to Virgin Pulse any questions, concerns, or potential violations of this Vendor Code of Conduct. 

Primary Contact – Contact your relationship owner at Virgin Pulse or use one of the contacts listed below.

Privacy Reporting – PrivacyOfficer@virginpulse.com

Security Reporting – Security@virginpulse.com

Compliance and Ethics – compliance@virginpulse.com

Anonymously By Telephone –

USA / Canada: (844) 401-0009 
All other countries: (800) 603-2869

Anonymously Online – https://lighthouse-services.com/virginpulse