Routeget Partner Code of Conduct

Routeget aspires to be more than just a good company – we want to be a great company. We are committed to our mission of empowering every person and every organization on the planet to achieve more. Achieving our mission isn’t just about building innovative technology. Our mission reflects who we are as a company, how we manage our business internally, and how we work externally with customers, partners, governments, and suppliers.

Routeget Values & Expectations

Routeget partners and their employees, agents, and subcontractors (collectively referred to as “Partners”), in collaboration with Routeget, serve our customers. It is important for Routeget that Partners embrace and continually improve on Routeget’s values. While conducting business with Routeget and Routeget’s employees, agents, subcontractors, and customers, Routeget expects its Partners to commit to operating in full compliance with all applicable laws and regulations, and to adhere to the principles outlined in this Partner Code of Conduct.

Routeget’s values are the foundation of our success and reflect our continued commitment to ethical and responsible business practices. Our values include:

• Respect: We recognize that the thoughts, feelings, and backgrounds of others are as important as our own. It starts with our belief that every person has intrinsic worth. We invite in perspectives that are different from our own and then we really listen. We treat each other with decency, and when we disagree, we do so without diminishing each other.
  
• Integrity: We are honest, ethical, and trustworthy. Trust is built when we keep our word and do what we know is right. Even when it’s hard, when we’re under stress, and when no one is looking. We’re transparent, while respecting confidentiality. We tell others the truth with care.
  
• Accountability: We accept full responsibility for our decisions, actions, and results. Credibility is created when we take ownership for what we say and do and for the outcomes we create and how they’re delivered. We make our intentions and goals clear and invite input from others on how we’re doing.
  

This Partner Code of Conduct is not intended to replace, supersede or conflict with any applicable law, regulation or contractual obligation with Routeget.

Partners may report any issue related to this Partner Code of Conduct, including any request by a Routeget representative for Partners to act in a manner that conflicts with this Partner Code of Conduct, by using any of the resources listed in Page 4. Routeget employees, agents, subcontractors and customers may use similar resources to report a Partner’s actions that conflict with this Partner Code of Conduct. Routeget may enforce violations of this Partner Code of Conduct by taking such action(s) as it deems appropriate, including suspension or termination of the Partner’s relationship with Routeget in the manner described in the applicable agreement(s) between Routeget and Partner.

Business Practices, Ethics and Compliance

While conducting business with Routeget customers, Routeget Partners will conduct their business practices and activities in accordance with applicable law, with integrity, fairness, respect and in an ethical manner.

• Anti-Corruption: Routeget Partners will comply with all applicable anti-corruption and anti
  

  money laundering laws. All forms of bribery, kickbacks and other corruption are prohibited. No Routeget Partner will improperly influence any act or decision of any governmental official, employee or political candidate, including, without limitation, through the provision of any improper or unlawful gifts, meals, travel or entertainment.
  

  • Fair Competition and Antitrust laws: Routeget Partners will conduct their business in full compliance with all applicable fair competition and antitrust laws.
    
  • Public Sector Procurements: When selling to public sector entities, Routeget Partners will support fair and open competition by complying with all laws and regulations related to government procurement, tenders, and bids. Routeget Partners will not conspire with other partners, including but not limited to, bid rigging, placing orders prior to tender finalization, price fixing, or other forms of collusion.
    
  • Business Records and Accounting: The business records of Routeget Partners will conform with applicable legal, accounting and regulatory requirements. Routeget Partners will not place any orders for Routeget technologies, products, support or services without the existence of a corresponding customer order or agreement.
    
  • Technology Fraud: Routeget Partners are prohibited from engaging in false or deceptive business practices, including any activities which may mislead customers or consumers. These prohibited practices include engaging in technology fraud and activities which may mislead seniors, children or other vulnerable consumers to purchase or subscribe for unneeded technical support or services. In order to better protect these vulnerable consumers, Routeget Partners should also not engage in the “cold-calling” of such consumers for the purpose of engaging in any of those prohibited practices.
    
  • Conflicts of Interest: Where a Routeget Partner is advising a customer, especially a governmental customer, on the selection of products and/or services and has a fiduciary or contractual obligation to that customer, the Routeget Partner will avoid engaging in business activities that constitutes or could create the appearance of a conflict of interest.
    
  • Disclosure of Fees to Governmental and State Owned Entities: If required by law or under a contract, Routeget Partners will disclose to the applicable governmental entity customer or state-owned entity customer, the potential fees, commissions or other compensation that Partner will receive from Routeget in connection with the products or services being procured.
    
  • Advertising and Marketing: Routeget Partners’ advertising and marketing activities will be conducted truthfully, accurately and in accordance with applicable law, rules and regulations. Routeget Partners must ensure that all communications to its customers be truthful, accurate, and not misleading.
    

  Human Rights and Fair Labor Practices
  

  Routeget Partners will provide a safe and healthy work environment, fully compliant with all employment, health and safety laws.
  

  • No Forced Labor; No Child Labor: Routeget Partners will abide by local minimum wage and maximum working hour requirements, are not to use forced labor or to use labor contacts that impose unreasonable limitations on a worker’s ability to leave Partner’s employment. The use of child labor is prohibited.
    
  • Non-Discrimination: Routeget Partners will not illegally discriminate in hiring, compensation, access to training, promotion, termination and/or retirement decisions based on race, sex, national origin, religion, age, disability, gender identity or expression, marital status, medical condition, physical or mental disability, pregnancy, sexual orientation, political affiliation, union membership, veteran status or other protected characteristic or status.
    

  Professional Conduct
  

  Routeget Partners will conduct themselves in a professional manner at all times, helping Routeget to create an inclusive, productive, respectful and professional environment, free from any forms of discrimination or harassment.
  

  • Inappropriate Language: Routeget Partners will not use any form of language which may be considered discriminatory, intimidating, harassing, threatening, abusive, sexually explicit, or otherwise offensive or inappropriate.
    
  • Treat Others with Fairness, Dignity and Respect: Routeget will not tolerate, and Routeget Partners must not engage in, any form of sexual or other harassment. Sexual harassment is unwelcome verbal or physical behavior based on sex and includes gender-based harassment of a person of the same gender. Examples include unwelcome sexual advances or physical contact, sexual comments or inappropriate gender-based jokes, unwelcome romantic attention, offering a benefit or preferential treatment in exchange for sexual favors, sharing or displaying sexually explicit content and using sexually degrading words. Other examples of harassment include comments, jokes or degrading words based on race, sex, national origin, religion, age, disability, gender identity or expression, marital status, medical condition, physical or mental disability, pregnancy, sexual orientation, political affiliation, union membership, veteran status or other protected characteristics or status.
    
  • Event Behavior: In any event sponsored or hosted by Routeget or during which Routeget Partners may interact with any Routeget employees, agents, subcontractors or customers, regardless of location, Routeget Partners must behave in a professional manner including responsible alcohol use and continued adherence to this Partner Code of Conduct.
    

  Environmental Regulations and Protections
  

  Routeget expects Routeget’s Partners to share Routeget’s commitment to the environment.
  

  • Registrations; Permits: Routeget Partners will comply with all applicable environmental laws and regulations, keep current all required environmental registrations and permits relevant to its businesses and implement appropriate conservation measures.
    

  Intellectual Property and Protection of Information
  

  Routeget Partners will respect intellectual property rights, protect confidential information and comply with privacy rules and regulations.
  

  • Legitimately Acquired Software: Routeget Partners will only use information technology and software that has been legitimately acquired and licensed.
    
  • Comply with Ownership Rights: Routeget Partners will respect the intellectual property ownership rights of all third parties. Routeget Partners will only use lawful methods of gathering competitive intelligence about products or manufacturers that compete with Routeget technologies.
    

  Governance
  

  Routeget Partners are expected to develop a culture of compliance with view for continuous improvement.
  

  • Risk Management: Routeget Partners will have applicable business controls to detect and prevent unlawful conduct by their employees and counterparties. These business controls should be adequately resourced and be periodically reviewed and updated to take into account the current risk environment.
    
  • Training: Routeget Partners will ensure that they have an adequate training program that achieves the appropriate levels of knowledge and skills to maintain compliance with applicable laws, regulations and standards.
    
  • Assistance: Routeget Partners will provide reasonable assistance to Routeget in connection with any investigation of a violation of this Partner Code of Conduct or applicable law. Routeget Partners will permit Routeget reasonable access to all records and other applicable documentation concerning Partners’ compliance with this Partner Code of Conduct and applicable law.
    

  Raising Concerns and Reporting Questionable Behavior
  

  Partners are encouraged to work with their primary Routeget contact in resolving a business practice or compliance concerns. However, Routeget recognizes that there may be times when this is not possible or appropriate. In such instances, Routeget Partners should report any concerns about violation of this policy or applicable laws to their legal department and/or their ethics and compliance officer. Routeget Partners should also report to Routeget through the following alternatives:
  

  By Routeget’s Business Conduct Hotline:
  

  • +1 315 355 0060 within the U.S.; or if calling from outside the United States, you may make a collect call to the Hotline by accessing an international operator and asking to place a collect call to +1 315 355 0060.
    
  • The Business Conduct Line is a dedicated, toll-free phone line that is available to you 24 hours a day, 7 days a week, and 365 days a year.
    

  By Routeget email or web allegation tool:
  

• codeofconduct@routeget.com