Introduction
This document outlines the ClimeCo LLC (“ClimeCo”) Code of Conduct (CoC) for Third Parties. Its primary purpose is to inform and raise awareness among Third Parties about the expectations ClimeCo has regarding Third Parties it engages in business with. Compliance with this CoC and all applicable laws is a prerequisite for acting on behalf of or in conjunction with ClimeCo.
Definition of “Third Parties”
Third parties include, but are not limited to, the following:
- Partners
- Suppliers
- Vendors
- Subcontractors
- Consultants
- Intermediaries
- Brokers or other Agents
- Sellers & Buyers
This definition encompasses any person or entity who needs access to ClimeCo systems or is engaged in business with or acting for or on behalf of ClimeCo.
Expectations for Compliance
All Third Parties are expected to:
- Conduct business in accordance with this Code of Conduct.
- Adhere to all applicable laws and regulations.
- Uphold ethical standards in all business dealings.
Scope
The CoC applies globally to all Third Parties associated with ClimeCo. By adhering to this CoC, Third Parties contribute to the integrity, reputation, and success of ClimeCo’s business operations worldwide by requiring thoughtful consideration of actions to ensure they align with stakeholder interests.
This CoC complements any existing commercial or contractual terms. While the CoC cannot address every scenario or replace individual accountability, it underscores the necessity of good judgment and proper business conduct. Non-conformance is taken seriously and may lead to corrective actions, including reduced or terminated business relationships.
Reporting Concerns: ClimeCo Third-Party Code of Conduct
ClimeCo expects Third Parties to report to ClimeCo any concerns related to their business, including potential non-conformance with this CoC, laws, regulations, or ethical standards. Reports should be made in good faith and can be submitted through the following channels:
- To those designated as the point of contact for the Third Party’s services with ClimeCo
- To the General Counsel of ClimeCo or other appropriate organizational representatives of ClimeCo.
Reports may be made anonymously. Third Parties must ensure that their personnel will not face retaliation for raising concerns in good faith. ClimeCo will review and investigate reported concerns and escalate them to the appropriate Third Party representatives for further management and investigation.
Part 1: Labor & Employment
Fair Hiring, Employment Practices & Diversity
Equal treatment of all employees is a fundamental principle of ClimeCo. Discriminatory treatment, whether conscious or unconscious, based on characteristics such as race, national origin, gender, age, physical characteristics, social origin, disability, union membership, religion, family status, pregnancy, sexual orientation, gender identity, gender expression, or any unlawful criterion under applicable law, should not be tolerated. Third Parties are expected to foster an inclusive and supportive working environment where diversity is valued. This includes making decisions that promote a sense of belonging for all persons.
ClimeCo is committed to fostering a work environment built on mutual trust, where employees are highly valued, and everyone who works or collaborates with ClimeCo is treated with dignity and respect. ClimeCo expects Third Parties to uphold these values by not discriminating against any individual in your employment or hiring practices. Selection, development, and advancement of individuals should be based on merit not any other protected status or characteristic unrelated to the individual’s merit or the inherent requirements of the position.
Working Hours, Wages, & Benefits
Third Parties are expected to ensure that working hours for their employees do not exceed the maximum set by applicable national laws, and that compensation for work meets national wage laws and is consistent with a living wage. Unless national laws dictate otherwise, deductions from basic wages as a disciplinary measure are not allowed. Third Parties are expected to offer fair and competitive compensation and benefits that support an adequate standard of living for employees and their families with prompt payment.
Harassment-free Workplace
ClimeCo believes in fair treatment, courtesy, and respect in the workplace. Third Parties are expected to ensure their employees work in an environment free from harsh and inhumane treatment, including sexual harassment, sexual abuse, corporal punishment, or torture, mental or physical coercion, or verbal abuse, as well as the threat of such treatment. Additionally, Third Parties are expected not to terminate any employment contract unfairly or under circumstances that are not permitted by law.
Freedom of Association
ClimeCo supports freedom of association. Third Parties are expected to engage in open and constructive dialogue with their employees, employee representatives and other stakeholders in ClimeCo business. Suppliers are expected to respect their employees’ rights to freely associate, join labor unions, seek representation, join works councils, and participate in collective bargaining in accordance with national laws. Third Parties are expected not to discriminate against employees who serve as workers’ representatives.
Human Rights
ClimeCo is committed to upholding the highest standards of human rights in all aspects of its operations and expects the same from its Third Parties. Third Parties should strive to adhere to all internationally recognized human rights standards, including but not limited to the principles of the Universal Declaration of Human Rights, the International Labor Organization’s Declaration on Fundamental Principles and Rights at Work, and the United Nations Guiding Principles on Business and Human Rights.
Human Trafficking & Modern-day Slavery
ClimeCo is firmly against all forms of slavery and human trafficking, including holding individuals in positions of slavery, servitude, or forced labor, as well as facilitating their travel with the intent to exploit them. These crimes can occur both internationally and within one’s own country, and consent to be moved does not negate victimhood. Exploitation linked to human trafficking encompasses a broad range of activities, including sexual exploitation, forced labor, domestic servitude, organ harvesting, child-related crimes such as sexual exploitation, forced begging, illegal drug cultivation, organized theft, benefit fraud, forced marriage, and illegal adoption. ClimeCo expects Third Parties to never engage in or support human trafficking or modern slavery, including any form of forced, bonded, or involuntary labor. There should be no restriction of free travel by withholding passports or other documents of travel from workers, and Third Party employers should ensure that all workers retain possession of their personal documents at all times.
Child Labor
ClimeCo is dedicated to eliminating all forms of forced and compulsory labor and effectively abolishing child labor. ClimeCo expects Third Parties to employ only personnel who meet the applicable minimum legal age requirements in the countries where you operate.
Part 2: Ethical Business Practices
Conflict of Interest
ClimeCo is committed to identifying and addressing real and potential conflicts of interest in its business operations. ClimeCo expects Third Parties to notify ClimeCo if they become aware of any actual or potential conflict of interest that may impact work with or for ClimeCo and to implement appropriate measures to manage these conflicts.
Fair competition, Antitrust Laws, Corruption & Bribery
ClimeCo is committed to fair competition and adheres to antitrust laws. Third Parties are expected to conduct their business in accordance with fair competition and all applicable antitrust laws. Corruption, extortion, and embezzlement are strictly prohibited. Third Parties are expected to neither pay nor accept bribes or engage in any illegal inducements in business or government relationships, including any acts of non-conformance with the Foreign Corrupt Practices Act of 1977. Illegal inducements refer to any incentives offered, promised, or provided to influence the actions of a person in a position of power or authority. This includes, but is not limited to, bribes, kickbacks, gifts, hospitality, travel expenses, political contributions, charitable donations, and any other benefit or advantage provided with the intent to obtain or retain business or any improper advantage.
Third Parties are also expected to conduct business in accordance with relevant anti-bribery and corruption laws, fair competition and antitrust laws, and comprehensive global frameworks. This includes, but is not limited to, adherence to the UK Bribery Act 2010, the OECD Anti-Bribery Convention, the Corruption of Foreign Public Officials Act (CFPOA) in Canada, the Sherman Antitrust Act in the United States, the European Union Competition Law, the Competition Act in Canada, the Competition and Consumer Act 2010 in Australia, the United Nations Convention Against Corruption (UNCAC), and the guidelines set by the International Competition Network (ICN).
Third Parties are also required to exercise enhanced due diligence when dealing with Politically Exposed Persons (PEPs). PEPs are individuals who hold or have held prominent public functions, as well as their immediate family members and close associates.
Additionally, Third Parties are expected not to use ClimeCo’s name, or that of our affiliates or products, in any publicity or advertising without prior written consent.
These standards and regulations ensure that Third Parties maintain the highest levels of integrity, transparency, and ethical behavior in their business operations, fostering a competitive and fair market environment.
Anti-money laundering & Economic crimes
Money laundering is the process by which individuals or entities attempt to conceal illicit funds or make them appear legitimate. ClimeCo unequivocally condemns the facilitation or support of money laundering. ClimeCo expects Third Parties to conduct business in a manner that will avoid providing any service or entering into any arrangement that could involve ClimeCo directly or indirectly in economic crimes, including money laundering activities. Third Parties must ensure that no funds are channeled to or used to support illegal activities such as terrorism, tax evasion, or fraud. Additionally, it is essential to diligently assess the integrity of potential customers and other business relationships.
Third Parties are also expected to conduct business in accordance with all relevant anti-money laundering (AML) laws and regulations, including not limited to:
- United States: Compliance with the Bank Secrecy Act (BSA) and USA PATRIOT Act, which mandate robust record-keeping, reporting of suspicious activities, and customer identification procedures as enforced by the Financial Crimes Enforcement Network (FinCEN).
- European Union: Adherence to the 5th and 6th Anti-Money Laundering Directives (5AMLD and 6AMLD), which enhance transparency on beneficial ownership, expand AML rules to include virtual currencies, and ensure comprehensive due diligence to prevent money laundering and terrorist financing.
- United Kingdom: Implementation of the Money Laundering Regulations 2017 (MLR 2017) and Proceeds of Crime Act 2002 (POCA), which enforce stringent measures for customer due diligence, risk assessment, and reporting suspicious activities.
- Canada: Compliance with the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA), which mandates detailed reporting, customer verification, and record-keeping to identify and prevent money laundering activities.
- Global Standards: Adherence to the Financial Action Task Force (FATF) Recommendations, which set international best practices for combating money laundering, terrorist financing, and other related threats to the integrity of the international financial system.
Accuracy of Business Records
Third Parties are expected to keep all financial books and records in accordance with generally accepted accounting principles. These records are expected to be accurate in all material respects, legible, transparent, and reflect actual transactions and payments.
Confidentiality & Data Protection
ClimeCo is dedicated to respecting the confidentiality of information belonging to its business units, employees, and Third Parties. ClimeCo expects Third Parties to understand and conduct business in accordance with relevant data protection and privacy laws, including the General Data Protection Regulations of the European Union, California Consumer Privacy Act, Personal Information Protection and Electronic Documents Act of Canada), and Personal Data Protection Act of Singapore. Additionally, Third Parties are expected to ensure appropriate technical and organizational measures are in place to safeguard ClimeCo’s confidential information from unauthorized access, accidental loss, or destruction, and to avoid transferring any of ClimeCo’s information to outside entities without ClimeCo’s prior written consent.
Part 3: Environment, Health & Safety
Environmental Protection and Stewardship
ClimeCo is committed to sustainability, environmental conservation and restoration, and adherence to all related laws and best practices with respect to environment, health and safety (EH&S). ClimeCo expects Third Parties to follow internationally-recognized best practices regarding EH&S, manage environmental impacts within their value chain, and comply with regulations on water, energy, hazardous materials, air quality, and waste. Third Parties should seek to reduce greenhouse gas emissions, promote resource efficiency, and support our sustainability efforts by going beyond regulatory requirements. Through collaboration and education, ClimeCo is committed to a sustainable future, minimizing our environmental footprint and leading by example.
Worker Health & Safety
ClimeCo expects Third Parties to protect workers from overexposure to chemical, biological, and physical hazards, as well as from physically demanding tasks, both in the workplace and in any company-provided living environment. Safety information regarding hazardous materials should be made available to educate, train and protect workers from potential hazards.
Emergency Preparedness & Response
ClimeCo expects Third Parties to identify and assess emergency situations in the workplace as well as any company-provided living environments. These plans and procedures should be reviewed and updated annually or more frequently, if needed. Third Parties should be prepared to provide exfiltration and medical support, including healthcare services that can be provided on-site or nearby, to safely withdraw individuals from remote or dangerous environments.
Process Safety
ClimeCo expects Third Parties to prevent or mitigate incidents related to operations and processes that could have a catastrophic impact on people or the environment, both on and off site. The actions taken by Third Parties should be proportionate to the risks associated with the potential impact.
Acknowledgement
Third Parties who work for or with ClimeCo and its clients, and who receive this CoC, acknowledge that:
- they have read and understand the requirements and expectations of the CoC;
- they agree to adhere to its requirements and expectations, and report complete and accurate information to ClimeCo as appropriate hereunder; and
- they will conduct business in accordance with applicable laws and regulations in the countries where they conduct business with or on behalf of ClimeCo.
Contact Us
If you have any questions about this Code of Conduct for Third Parties, please contact us at:
Mail (US):
1 East Philadelphia Ave.
Boyertown, PA 19512
United States of America
Phone: 484.415.0501
E-mail: legal@climeco.com
