Vendor's Code of Conduct

Date of last update: June 6, 2024

Founded in 2016, SplitMetrics Inc. (“SplitMetrics”) is a software company with a global presence, providing a comprehensive range of products and services designed to assist mobile-oriented enterprises and brands across the globe in streamlining their path to achieving business success.

 

As a company, our objective is to establish an environment that enables and encourages the adoption of proper actions and decisions in different spheres when doing business.

 

We believe that the conduct of our vendors (companies or individual entrepreneurs that provide goods or services to us) reflects SplitMetrics’ reputation. That is why SplitMetrics requires vendors to act in accordance with this Vendor’s Code of Conduct (“Code”) and with all applicable laws and regulations within the areas in which vendors operate, and to be open and cooperative with regulators that enforce such laws.

If you act as a vendor when cooperating with SplitMetrics, you acknowledge and agree this Code and shall comply with it. In the event of non-compliance with the Code, you shall not provide SplitMetrics with any services or products.

Business ethics

Fair Business Practices

Vendors shall abide by fair business practices (including truthful and accurate advertising), deal fairly in all relationships, and avoid taking unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts or other unfair-dealing practices.

Laws and regulations

Compliance with laws is a fundamental tenet of ethical business conduct. Vendors shall comply with all applicable laws and regulations in all locations in which vendors operate. Vendors must establish clear policies and procedures that outline expectations for employee behavior and ensure that all employees are aware of and understand these requirements.

Corruption prevention

Vendors adhere to a strict anti-bribery policy, refraining from engaging in bribery or accepting bribes in any form. This applies not only to interactions with public officials but also to their overall business dealings. Decisions of vendors are based on objective and transparent reasons.

Vendors shall maintain a fair, ethical, and transparent approach when engaging with partners and business contacts. They do not accept gifts or other benefits, including invitations, that may inappropriately influence their decision-making process. Similarly, vendors do not offer benefits or advantages with the intention of inappropriately influencing their partners or other contacts in their own favor.

Foreign trade law and money laundering

Vendors strictly adhere to all applicable economic sanctions and comply with foreign trade restrictions and maintain a strong commitment to conducting their business in compliance with these regulations. Vendors shall not engage in any transactions or dealings with individuals, companies, or organizations associated with terrorism, drug trafficking, or deriving funds from criminal activities.

Antitrust law

SplitMetrics prioritizes the promotion of fair and unrestricted competition as a fundamental principle. Vendors shall fully comply with antitrust laws and regulations.

Specifically, vendors shall not engage in agreements related to prices, market division (such as sales territories, customers, or products), or any other market practices that could hinder fair competition.

Data protection, security and confidentiality

Personal Data protection

Vendors shall comply with all applicable laws and regulations relating to the protection of personal data including any local data protection laws.

Vendors shall only collect, use, store, and process personal data in accordance with the instructions provided by SplitMetrics and for the purposes specified in the contract.

Vendors shall implement and maintain appropriate technical and organizational measures to protect personal data from unauthorized access, use, disclosure, alteration, or destruction.

Vendors shall not transfer personal data to any third party without the prior written consent of SplitMetrics.

Vendors shall promptly notify SplitMetrics of any security breaches or suspected breaches involving personal data.

Vendors shall assist SplitMetrics in responding to data subject requests, including requests for access, rectification, erasure, and restriction of processing.

Vendors shall retain personal data only for the period necessary to fulfill the purposes for which it was collected and processed.

Vendors shall destroy or securely dispose of personal data when it is no longer required.

Vendors shall cooperate with SplitMetrics in any audits or investigations related to personal data protection.

Vendors shall ensure that their employees and subcontractors are aware of and comply with these personal data protection obligations.

Information security

Ensuring reliable information security is of paramount importance for the trust SplitMetrics places in its vendors. The data SplitMetrics may share and process carries significant value. To effectively safeguard this data against cyber risks, including destruction, theft, unauthorized access, unauthorized disclosure, or any other form of misuse, each of our vendors shall implement appropriate security measures. In the event of a cyber attack, vendors shall promptly notify the affected parties.

Confidentiality

Vendors shall prioritize the strict confidentiality of information and documents that are not intended or suitable for disclosure to third parties. Vendors shall take comprehensive measures to safeguard such confidential information against unauthorized access and misuse. These measures may include implementing secure storage systems, using encryption technology, restricting access to authorized personnel only, and implementing robust data security protocols.

Vendors shall not at any time disclose to others and will not take or use for its own purposes or the purpose of others, any trade secrets, confidential information, knowledge, data, know how, or any other information of SplitMetrics considered logically as “confidential”. To the extent vendors and SplitMetrics have entered into a separate non-disclosure agreement, that agreement shall govern with respect to confidentiality obligations.

Human rights, employment and working conditions

Human rights

SplitMetrics is committed to respecting human rights in SplitMetrics’ internal operations and requires the same from all vendors. SplitMetrics does not tolerate human rights violations in any form at any stage of its supply chain. SplitMetrics requires vendors to not tolerate physical violence, threats, corporal punishment, mental coercion, verbal abuse, disrespectful behavior, bullying, or harassment of any kind.

Equality and non-discrimination

Our vendors shall not tolerate any kind of discrimination. Vendors shall comply with all applicable laws and regulations relating to discrimination in hiring, employment practices, and harassment. Vendors shall operate workplaces free of unequal treatment in employment, discrimination, harassment, victimization, and any other abuse on any grounds including but not limited to age, health status, disability, ethnic or social origin, gender, gender identity, nationality, race, sexual orientation, marital status, parental status, pregnancy, political convictions, religion or beliefs, union affiliation, or veteran status.

Protection of children and vulnerable adults

SplitMetrics has a zero-tolerance policy of exploitation of children and vulnerable adults. Vendors may not employ anyone under the age of 15, the minimum age for employment in the applicable jurisdication, or the age for completing compulsory education in that location, whichever is higher. Vendors shall comply with all age-related working restrictions as set by local and federal law and adhere to international standards as defined by the International Labor Organization (ILO) regarding age-appropriate work when applicable.

Fair working conditions

Vendors adhere to the law and uphold appropriate social and legal standards when establisihing working conditions for its employes. Wages, salaries, and social benefits provided by our vendors are set at a minimum level that meets or exceeds the national legal requirements. Additionally, working hours shall comply with applicable laws, industry standards, or the core labor standards established by the International Labor Organization.

Vendors are committed to ensuring equal treatment among employees, specifically by avoiding unequal pay for work of equal value. Vendors respect the rights of employees to form or join employee representative bodies and participate actively without facing discrimination or retaliation.

Vendors categorically reject any form of forced labor, which involves compelling individuals to work against their will under the threat of punishment and don’t involve in modern slavery and human trafficking.

Freedom of Association and Collective Bargaining

Vendors shall respect workers’ rights to freedom of association, peacefully demonstrate and collective bargaining in accordance with applicable local laws and regulations. SplitMetrics expects vendors to respect the rights of workers to freely associate, collectively bargain and join or not join trade unions and other legitimate associations. SplitMetrics encourages vendors to cultivate open communications and direct engagement between workers and management to facilitate an effective resolution of workplace issues.

Health, Safety and Respect for Environment

Health and safety

Vendors shall provide employees including temporary staff with a safe and healthy workplace in compliance with all applicable laws and regulations.

Vendors shall implement procedures to prevent, manage, track, and report workplace injuries and illnesses, such as encouraging employees’ reporting, classifying and recording cases, providing medical treatment, investigating cases, implementing corrective actions, and facilitating employees’ return to work.

Environment

Vendors are encouraged to conserve natural resources, to reuse, and recycle and to avoid use of hazardous materials where possible.

Vendors shall have systems to ensure the safe and lawful handling, movement, storage, recycling/reuse or management of waste, air emissions and wastewater discharges. Vendors shall endeavor to reduce or eliminate waste of all types, including water and energy, by implementing appropriate conservation measures in their facilities, through their maintenance and production processes and by recycling, re-using, or substituting materials.

Vendors shall have appropriate processes in place to identify, prevent and mitigate any risk of a chemical spill or other event that would pose a threat to worker safety and/or to the environment. These processes include emergency plans in the case of an unsafe event and response procedures should such an event occur.

Complying with the principles indicated above does not exempt vendors from compliance with all applicable laws and regulations.

Reporting and dealing with compliance violations

Vendors are required to promptly report to SplitMetrics’ legal department at legal@splitmetrics.com any legal violations or violations of this Code or suspicions of such violations.

Possible responses to identified violations (not an exhaustive list) include requesting remedial action, pursuing claims for damages. Also SplitMetrics reserves the right to terminate the business relationship in accordance with contractual or legal provisions in cases of violations of this Code by vendors.