Ingram Content Group (“Ingram”) 1 is part of a family-owned group of companies long known for their commitment to honesty and integrity. Ingram is committed to conducting our business in an ethical manner, in compliance with all applicable laws, and in furtherance of our values of respect for all people and for the communities in which we live and operate. As a supplier of products and services, our customers expect us, and we agree, to follow the principles herein. Likewise, we expect and require our global business partners who in any way provide Ingram with goods or services for our use or resale (“Supplier(s)”) to follow these principles.
To that end, we have developed this Supplier Code of Conduct (“Code”) to clearly set forth our expectations for Ingram Suppliers. This Code is consistent with the Ingram Compliance & Ethics Code by which all Ingram associates are bound and sets forth the minimum expectations Ingram has of its Suppliers. If a contractual term between Ingram and a Supplier is stricter than this Code, the stricter term will apply.
We expect Suppliers to comply with the requirements of this Code to the extent they are applicable to our business relationships with them, and to require any of their representatives, agents, contractors, subcontractors, suppliers, vendors and anyone else whose work with the Suppliers is related, directly or indirectly, to our business relationships with the Suppliers, to adhere to this Code or a substantially similar code.
Suppliers are required to comply with all domestic and foreign statutes, laws (including common and civil law), treaties, codes, ordinances, rules, regulations, restrictions or by-laws (zoning or otherwise) (“Laws”) applicable to the Supplier’s operations and the products and services they supply to Ingram. Below is a non-exhaustive list of Laws and practices that Suppliers must comply with where applicable.
Labor and Employment Laws. Suppliers will comply with all applicable employment, labor, wage, hour and benefits Laws, including without limitation, Title VII of the Civil Rights Act, the Fair Labor Standards Act, the National Labor Relations Act, the Age Discrimination in Employment Act, Title I of the Americans with Disabilities Act 1990, the Immigration and Nationality Act, and the Occupational Safety and Health Act.
Suppliers will:
Consumer Product Safety Laws. Suppliers will ensure that products manufactured or supplied by them for use, resale or distribution by Ingram, and all related packaging, labels and warnings, and all written materials, comply with all applicable product safety Laws, including without limitation:
Intellectual Property Laws. Suppliers will comply with all applicable Laws regarding the protection, use and publication of the intellectual property of others and will not provide Ingram with any products, services or information that in any way violate the copyrights, trademarks or any other rights of third parties.
Environmental and Sustainability Laws. Suppliers will carry out their operations with care for the environment, in compliance with all applicable environmental Laws, and consider opportunities for conservation of natural resources, waste reduction, recycling, and pollution control.
Paper product Suppliers will ensure such paper products comply with all applicable Laws, including without limitation, the Lacy Act and the EU Timber Regulation.
Fair Competition Laws. Suppliers will not engage in anti-competitive conduct that violates applicable anti-trust and competition Laws including but not limited to the Sherman Act, the Federal Trade Commission Act and the Clayton Act.
Anti-Bribery / Anti-Corruption Laws. Suppliers will comply with all applicable anti-bribery and anticorruption Laws, including without limitation the U.S. Foreign Corrupt Practices Act and the UK Bribery Act 2010. Suppliers will not directly or indirectly offer, pay, authorize to pay, or promise money, gifts or anything of value, including but not limited to entertainment, kickbacks and any benefit to any entity or person, whether a public official or an employee of a private company, to secure or retain business or to obtain, retain, or secure an improper advantage in the conduct of business for Ingram, or solicit or accept any payment or other benefit described above while performing any service or other activity on behalf of Ingram.
Data Privacy Laws. Suppliers will comply with all applicable data protection and data privacy laws when providing data to Ingram as well as handling or processing data from Ingram, including without limitation the individual state data privacy laws in the U.S., the UK’s Data Protection Act 2018, and the EU’s General Data Protection Regulation.
Honesty and Accuracy. All of Suppliers’ communications with Ingram and its business records on all matters related to its business with Ingram will be truthful, accurate and complete.
Confidentiality. Suppliers who receive confidential or proprietary information about Ingram, its customers, business partners or employees will take all due care to protect and prevent the misuse, theft or improper disclosure of such information.
Conflicts of Interest. Suppliers will avoid any situation that creates a conflict of interest or an appearance of a conflict of interest in its business dealings with Ingram and will promptly disclose to Ingram any conflicts of interest or appearances of conflicts of interest that do occur.
Gifts. Ingram associates may not give or accept gifts or other benefits that could influence, or appear to influence, their business decisions. Suppliers will not offer inappropriate or luxury gifts to Ingram associates, regardless of local customs.
Reporting Misconduct
Suppliers who become aware of any conduct (its own or others) in its business dealings with Ingram that do not comply with this Code will immediately report such misconduct to Ingram Compliance at legal@ingramcontent.com. Supplier’s noncompliance with this Code may be grounds for Ingram to void or terminate its relationship or contract with Supplier.
