Vendor of Code of Conduct

SSVEC operates under an established set of standards within its Code of Conduct and compliance guidelines.  These guidelines reflect our values and commitments to ethical behavior and business practices, regulatory compliance and the safety of our employees and members.  SSVEC expects its vendors to share and embrace these same values.

While vendors are independent entities from SSVEC, the business practices and actions of a vendor, when conducting business with or on behalf of SSVEC, may significantly impact and reflect upon SSVEC.  Because of this, we expect all vendors and their employees, agents, and subcontractors (“representatives”) to follow our ethical standards as set forth in the guidelines below, while they are conducting business with us or on our behalf.

It is the responsibility of our vendors and representatives to understand and adhere to these expectations. Vendors should notify SSVEC’s Compliance Officer or another member of senior management if and when any situation develops that causes the vendor or representative to operate in a way that may be in conflict with SSVEC’s expectations.  SSVEC may request the removal of any vendor or representative who behaves in a manner that we consider to be acting inconsistent with these guidelines or any SSVEC policy.

All vendors and representatives are required to acknowledge annually their obligation to comply with the Vendor Code of Conduct

Expected Conduct of Vendors and Representatives

While conducting business with or on behalf of SSVEC, all vendors and representatives are expected to act with integrity and in compliance with all applicable laws and regulations. SSVEC expects its vendors and representatives to share its commitment to human rights and equal opportunity in the workplace.  In addition to the obligations specifically identified in the vendor’s agreement with SSVEC, all vendors and their representatives are required to follow our Code of Conduct and compliance guidelines, which include expected conduct in the areas of regulatory compliance, business practices, and employment.  A summary of these expectations is noted below.
1. Expected Regulatory Compliance Practices
Vendors and their representatives are expected to:

2. Expected Business Practices
Vendors and their representatives are expected to:

Use SSVEC provided information technology and systems, including email, for legitimate business related purposes and only when authorized;

SSVEC strictly prohibits vendors from using SSVEC Information Technology resources to create, access, store, print, solicit, or send any material that is intimidating, harassing, discriminating, threatening violence, abusive, sexually explicit or otherwise inappropriate or illegal;

In general, vendors and representatives should refrain from giving SSVEC employees an individual gifts with a value greater than $50 USD or a combination of gifts with a value greater than $125 USD in a 12-month look back period;

Vendors and representatives should never offer a bribe, kickback, or barter arrangement for goods or services or any other incentive to an SSVEC employee in order to obtain or retain SSVEC business;

Any gifts or entertainment given or received must be in compliance with the law, and must not violate SSVEC policy;

Vendors or representatives should not deal directly during negotiation or otherwise with any SSVEC employee whose spouse or family member or close relation is an employee of or has a financial interest in the vendor or the vendor’s business; and,

3. Expected Employment Practices
Vendors and their representatives are expected to:

Reporting Concerns, Violations or Requesting Assistance

If a vendor or representative has a question about a particular situation, or needs to report a problem or concern, they are encouraged to work with their primary SSVEC contact in resolving a business practice or compliance concern.  SSVEC recognizes, however, that there may be times when this is not possible or appropriate.  In such instances, a vendor or representative should contact SSVEC’s Compliance Officer at ethics@ssvec.com

SSVEC does not tolerate retaliation against another person.  No one who reports any suspected legal or policy violation in good faith will be subject to retaliation for making such a report.  Good faith means that the individual coming forward with all of the information believes he or she is giving a sincere, truthful, and complete report.