I. Symphony Talent’s Values Set Expectations for our Entire Supply Chain
Symphony Talent, LLC (“Symphony Talent”) conducts our global business with honesty and integrity, treats people with dignity and respect, and honors applicable laws, regulations, rulings, ordinances, and treatises (“laws”) of the countries where we operate. We provide safe and healthy workplaces and respect the environment. We select suppliers who embrace our values. This Supplier Code of Conduct (“Code”) outlines expectations for our suppliers, contractors, vendors, and consultants, their parent entities, subsidiaries, affiliates, employees, representatives, subcontractors, sub- suppliers (at any tier) and others within their supply chain (“Suppliers”). We require our Suppliers to use best efforts to ensure that their entire supply chain complies with this Code and these fundamental principles in a timely manner. Time is most definitely of the essence with respect to all of these requirements.
II. Global Compliance
Suppliers shall honor applicable laws of the countries where they operate. In addition, suppliers shall comply with the United States Foreign Corrupt Practices Act (“FCPA”), the United Kingdom Bribery Act, Money Laundering Prevention Laws, Export Control Laws, Anti-Boycott Laws, Anti-Dumping Laws, data privacy laws such as, but not limited to the EU General Data Protection Regulation (“GDPR”) and others, that apply to Symphony Talent’s global business. Suppliers shall uphold consistent global compliance and perform in an ethical manner at all times.
III. Business Conduct and Ethics
Illegal Payments, Corruption and Bribes. Suppliers shall not engage in any corrupt practices including without limitation extortion, false declarations, bribery, money laundering, supporting or being involved with terrorist or organized crime organizations or activities. Suppliers shall not offer bribes, kickbacks, illegal political contributions or other improper payments to any third parties, including without limitation our employees and government officials.
General Contracting Ethics and Fiscal Integrity. Suppliers shall meet their contractual obligations. Their representations must be accurate and truthful. They shall keep accurate records that comply with applicable law. Suppliers shall adopt records retention practices required by us, our customers, and the U.S. federal government.
Conflicts of Interest. Suppliers shall disclose any actual/potential conflicts of interest. Such conflicts include, without limitation, their employees’ relationships with our employees or customers and our employees’ interest in the Supplier’s business.
Securities and Insider Training. If a Supplier learns of material non-public information while working with us, the Supplier must not share this information with others or use it for market trading.
Antitrust and Competition Laws. Suppliers must not illegally limit trade or competition. They shall not offer any confidential information about our competitors to our employees.
Gift Giving and Political Contributions. Inappropriate, lavish or repeated gifts to our employees or customers are forbidden. Suppliers must never offer entertainment or gifts to any international, federal, state or local government officials or their agents, in any governmental branch. Suppliers shall not make direct or indirect political contributions on our behalf.
Intellectual Property and Data Privacy. Suppliers shall protect our intellectual property rights, trade secrets and proprietary information, as well as that of our customers. Suppliers must also protect Personal Data (formerly known as personally identifiable information) from unauthorized disclosure, and otherwise comply with Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (the “General Data Protection Regulation” or "GDPR"), the European Data Protection Directive 95/46/EC ("EU Data Protection Directive"), and other applicable authorities.
IV. Workplace, Labor and Human Rights
Respect and Dignity. Suppliers’ workplaces shall be free of harassment, harsh treatment, violence, intimidation, corporal punishment, mental or physical coercion, verbal abuse and discrimination.
Wages and Benefits. Suppliers shall honor applicable laws governing wages and working hours, including compensation, benefits and overtime.
Nondiscrimination and Diversity in Subcontracting. Suppliers shall make hiring and employment decisions, including those relating to compensation, benefits, promotion, training and development, and discipline and termination solely on the basis of a worker’s skill, ability and performance. Suppliers must not discriminate based on any classification protected under applicable laws. Suppliers shall make a concerted, documented effort to promote diversity in their second and third-tier subcontracting opportunities, and shall develop annual Diversity in Subcontracting plans to be submitted to Symphony Talent on each anniversary of our contract’s effective date, and honored during the life of its relationship with Symphony Talent.
Freedom of Association. Suppliers shall respect employees’ right to join or not to join any lawful association without fear of retaliation.
Child Labor and Forced Labor. Suppliers shall comply with applicable laws prohibiting human trafficking, slavery and forced labor. Suppliers must refrain from any conduct that uses threats, force or any form of coercion, abduction, intimidation, retaliation or abuse of power for the purpose of exploitation, forced labor or slavery of any individual. Suppliers shall respect applicable laws establishing a minimum age for employment. If no minimum age is established by the respective country or local jurisdiction, workers must not be younger than the age of compulsory education; or if no minimum age for compulsory education is established, workers should not be younger than age 14. Workers under 18 years of age shall not perform hazardous work.
V. Doing Business with the U.S. Government
We frequently act as a primary U.S. government contractor or subcontractor to other primary U.S. government contractors. Suppliers shall comply with all U.S. government contract specifications. Suppliers shall comply with all applicable requirements of the Federal Acquisition Regulation (“FAR”), including but not limited to those clauses referenced at FAR 52.212-5, the full text of which can be found at https://www.acquisition.gov/. Suppliers cannot be debarred, suspended or otherwise ineligible to do business with the U.S. Government. Suppliers are not allowed to offer, give or promise to give anything of value to government employees or their immediate family members. Suppliers must disclose any credible evidence of a violation of federal criminal law involving fraud, conflict of interest, bribery, illegal gratuities, government overpayments or violations of the False Claims Act.
VI. Health, Safety and the Environment
Workplace Health and Safety. Suppliers shall provide secure, safe and healthy workplaces. Suppliers shall maintain resources to reduce the risk of accidents, injuries and exposure, especially where hazardous materials are present.
Suppliers must have well-established safety procedures, preventive maintenance and protective equipment that complies with applicable law.
Respect the Environment. Suppliers must comply with all applicable environmental laws, including those relating to hazardous materials, wastewater, solid waste and air emissions. We encourage Suppliers to reduce the environmental impact of their operations and safeguard natural resources.
VII. Accountability, Compliance and Reporting
Suppliers shall monitor and document that their entire supply chains comply with this Code and applicable laws and regulations. Suppliers shall keep updated and accurate names, addresses, and contact information on their entire supply chain. We reserve the right to audit and investigate Suppliers’ and their supply chain’s compliance with this Code and applicable legal principles. We may void or terminate contractual obligations with a Supplier for non-compliance or imminent non-compliance.
Any reports of non-compliance with this Code shall be made immediately to Symphony Talent at legal@SymphonyTalent.com.