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Simon & Schuster Supplier Compliance Policy

Last Modified: 10/27/2023
 
Simon & Schuster, LLC strives to maintain throughout its global operations a work environment that reflects the highest standards of business ethics and workplace behavior and is committed to legal compliance and ethical business practices in all of its operations worldwide. In furtherance of these standards, S&S expects all of its suppliers to comply with all applicable laws and regulations in the places in which they do business, and to maintain the highest degree of ethics in every aspect of their business with S&S. S&S is firm in its resolve to do business only with those suppliers who share in its commitment to integrity. Simon & Schuster, LLC; Simon & Schuster Digital Sales LLC; Simon & Schuster Australia Pty; Simon & Schuster Canada ULC; Simon & Schuster Publishers India Private Limited; and Simon & Schuster (UK) Limited are referred to herein collectively as “S&S”.
 
All of S&S’s suppliers should be familiar with S&S’s Business Conduct Statement (“BCS”). Hard copies of the BCS are available upon written request via email to compliance@simonandschuster.com or from your business contact. All suppliers must maintain accurate financial reporting systems and records relating to their dealings with S&S and familiarize themselves with all of the BCS policies.
 
They should be particularly aware that S&S expects strict COMPLIANCE with all applicable laws, regulations and standards regarding:
  • Anti-corruption and anti-bribery, including for example, the United States Foreign Corrupt Practices Act and the Organization for Economic Cooperation and Development Convention on Combating Bribery of Foreign Public Officials in International Business Transactions;
  • Political contributions and payments;
  • Trade embargos and boycotts (particularly United States anti-boycott laws);
  • Government contracting;
  • Imports and exports generally, and on technology in particular;
  • Fair and ethical employment practices including those relating to improper discrimination, child and forced labor; wages; hours; overtime and benefits; and health, safety and the environment; and
  • Tax evasion and facilitating another to evade tax, including for example the UK Criminal Finances Act 2017.
 
S&S policy PROHIBITS all of the following conduct:
  • The offering or giving of direct or indirect, improper payments, gifts or other things of value, to any domestic or foreign government official or employee, as well as their representatives, agents or family members;
  • The offering or giving of money, discounts, entertainment, meals, transportation, gifts or other favors or personal benefits to S&S employees, other than as appropriate and necessary to fulfill the supplier’s contractual obligations;
  • Anti-competitive business practices and non-adherence to applicable local and international antitrust laws;
  • The incorporation into any products we may manufacture or contract to manufacture of “conflict minerals,” which are minerals smelted into tin, tantalum, tungsten and gold sourced from the Democratic Republic of Congo or adjoining countries, without prior written authorization;
  • Use of S&S’s name, assets (including, without limitation, intellectual property such as any S&S trademarks or logos), facilities or services without prior written authorization or for any improper purpose;
  • Disclosure of confidential and proprietary information to any third party (including, without limitation, the press) without prior written authorization;
  • Improper discrimination in the terms and conditions of employment;
  • Acts of sexual, physical, mental or any other form of harassment, abuse or improper behavior in the workplace and in any work-related setting outside the workplace, such as during business trips, business meetings and business-related social events; and
  • Acting in any way that could assist, or could be considered to assist, another person or entity to deliberately and dishonestly evade their obligations to pay tax and/or commit a tax evasion offence, or that would be contrary to any applicable local and international tax laws and regulations.
 
S&S cooperates with law enforcement authorities in the proper execution of their responsibilities.
 
If it is found that a supplier has committed one or more violations of this policy, S&S will take appropriate action to the extent enforceable under local law. Such action may range from working with the supplier to ensure that steps are taken to address the violations and prevent their reoccurrence, to canceling the affected contract, terminating the relationship with the supplier, making disclosures to law enforcement or regulatory authorities and commencing legal action against the supplier or other actions as warranted.
 
For any questions regarding S&S’s Supplier Compliance Policy, please write to compliance@simonandschuster.com or your business contact.