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Third Party Code of Conduct

Overview

Gain Compliance takes pride in doing the right thing – for our customers, for our employees, and for our partners. 

The strength of our reputation is based not only on our own actions, but also on the behavior of those with whom we do business. We recognize that Gain has a duty when interacting with partners, customers, and vendors (“Third Party Partners”) to conduct business ethically, professionally, and in a manner consistent with our company values.

Our Expectations

Gain expects our Third Party Partners to provide the highest total quality and:

  • Provide consistent, timely, and relevant feedback. 
  • Be proactive in suggesting and providing business solutions. 
  • Address customer needs and concerns promptly. 
  • Promote continuous improvement and innovation – both within their organizations and also at Gain through feedback and collaboration.
  • Engender a welcoming atmosphere for interaction.
Gain Compliance Values

Gain engages with Third Partner Partners who share our commitment to three core values:

Ethical Conduct: To conduct business activities in accordance with the Company’s high ethical standards and values of honesty, integrity, trustworthiness, and respect.

Professional Conduct: To provide and maintain a work environment that respects the rights of all employees, and that is free of harassment and hostile or offensive behavior. To avoid conduct that may reflect adversely on the integrity or reputation of Gain Compliance.

Safeguarding of Customer Data: To protect and maintain the confidentiality of personal and Company information and to use this information only for Gain’s business purposes.

Ethical Conduct

Conflicts of Interest: An actual conflict of interest exists when business decisions and actions are motivated by personal benefit, interests, or relationships, rather than by the best interest of Gain Compliance. An apparent conflict is when business decisions and actions appear to be motivated by personal benefit, interests, or relationships.

Third Party Partners must not engage in any act which would bring into question the reputation of Gain Compliance. Because it is impossible to describe every potential issue, Gain Compliance relies on its Third Party Partners’ commitment to exercise sound judgment, to seek advice when appropriate or when in question, and to adhere to the highest ethical standards when interacting with or representing Gain. Furthermore, each Third Party Partner must act with integrity in all of its dealings, whether directly involved with Gain Compliance or not.

Gifts and Gratuities: Third Party Partners may occasionally receive incidental gifts as gestures of goodwill in the course of establishing and maintaining normal, ethical business relationships. Gain expects all parties to exercise prudent and sound judgment to determine whether a gift or gratuity creates an apparent or real conflict of interest and to act accordingly.

Professional Conduct

Work Environment: As a core company principle, Gain provides and promotes a welcoming and accepting environment which promotes equal opportunities for all employees. We expect our Third Party Partners to support these efforts within their own companies and in shared interactions with both us and our customers. 

Health and Safety: The health and safety of our people is foundational to our commitment to a welcoming and productive work environment. Our Third Party Partners must provide a safe and healthy work environment for all employees working at their sites by maintaining a focus on health and safety and complying with all applicable laws, rules and regulations.

Harassment, Discrimination & Equal Opportunity: Gain is committed to providing a respectful and productive work environment that is free from harassment and discrimination. In keeping with this commitment, the Company maintains a strict policy prohibiting discrimination and/or harassment based on gender, race, color, religion, national origin, ancestry, age, physical or mental disability, medical condition, marital status, military or veteran status, sexual orientation, gender identity, gender expression, or any other characteristic protected by federal or state law. The Company also prohibits sexual harassment and retaliation. Third Party Partners are likewise expected to foster a discrimination-free environment, by seeking to eliminate all forms of workplace harassment and retaliation.

Workplace Violence: Any form of violent conduct or threatening, abusive, intimidating, or hostile behavior is strictly prohibited. Possession of weapons on Company property or at Company-sponsored events is prohibited.

Forced Labor, Child Labor and Human Trafficking: Third Party Partners must not participate in, or benefit from, any form of forced labor, including bonded labor, forced prison labor, slavery, involuntary servitude, or human trafficking. Third party associates involved in Gain Compliance engagements must have the freedom of movement during the course of their employment. Third Party Partners must not engage in, or benefit from, the use of child labor in any form. Child labor is defined as employing persons below the minimum age for employment in accordance with applicable national laws.

Safeguarding of Customer Data

Customer Information: Third Party Partners and their employees may come in contact with information about Gain Compliance and its customers. Third Party Partners have a responsibility to protect any and all such confidential information. 

Confidential and Proprietary Information: All non-public information can be used only for Gain’s business purposes. The use of this information for any reason not specified in the written agreement(s) with Gain is strictly prohibited.

Social Media and Emerging Technologies: Gain expects our Third Party Partners to assist us in protecting the interests of Gain, our current and potential products, associates, partners, customers, and competitors, whether at work, at home, in the community, or online. Third Party Partners must avoid posting items that would reflect adversely on the integrity or reputation of Gain such as statements, photographs, video or audio that reasonably could be viewed as malicious, obscene, threatening or intimidating, or that could disparage customers, co-workers, or business partners. Third Party Partners must avoid the appearance of acting on behalf of or representing the Company and respect the use of Gain’s brands, logos, and trademarks.

Compliance with Laws, Regulations, Policies, and Procedures

Gain’s Third Party Partners are required to comply with all applicable laws, rules, regulations and treaties, including, but not limited to laws related to anti-bribery, competition, business conduct, privacy and data protection, labor and employment, and any other laws described herein or that are otherwise applicable to the services you provide to Gain in all locations in which you conduct business operations.

Anti-Bribery: Bribes and other improper payments destroy the fairness that is fundamental to the unfettered operation of the marketplaces in which Gain and its peers conduct business. In addition to harming the markets and communities in which it occurs, bribery is illegal under federal and international law and carries with it substantial criminal sanctions as well as debilitating reputational harm to the companies and individuals involved. Third Party Partners are prohibited from offering, promising, authorizing, paying, giving, soliciting, or accepting anything of value to or from any government official or private person in order to improperly gain any regulatory, commercial, or contractual advantage.

Government bribery also includes the concept of “facilitating payments”: that is, small amounts that are paid to a government official to induce the official to expedite fulfillment of a routine duty, such as processing governmental paperwork and licenses. Such payments are illegal under certain international anti-bribery rules and are thus prohibited by this policy.

Insider Trading: During the course of an engagement, Third Party Partners may come into possession of inside information concerning Gain and the companies it does business with, such as vendors, customers, and other business partners. Third Party Partners must never engage in the following activities:

  • Trade in the securities of any publicly traded company while aware of inside information about that company.
  • Recommend or suggest that anyone buy, sell, or retain the stock or other securities of any company when we are in possession of inside information about that company.
  • Disclose inside information other than for the specific business purpose for which the information is intended to be used.
  • Disclose inside information if we have reason to believe that the information may be misused.

When in doubt, Third Party Partners must assume information is material and nonpublic, and must not act upon it. Third Party Partners and their associates must not take part in any trading that may appear improper.

Contact Information and Escalation Procedures

Third parties are required to contact Gain’s Corporate Compliance department to report any actual or suspected violations of business conduct. Gain will not retaliate against any party who reports a concern or participates in an investigation. Any sort of retaliation that accompanies a reported violation is against Gain Compliance  policy and our core value of Integrity.

Any questions regarding the Code of Conduct should also be directed to Gain’s Corporate Compliance department.

Phone: 515-865-3702

Email: corporatecompliance@gaincompliance.com