Supplier Code of Conduct

GWI Supplier Code of Conduct

GWI’s mission is to provide vital 21st century infrastructure to communities that depend on it to conduct their lives and grow their economy. Every day we measure our performance not just on profit but on the positive impact our network has on the communities we passionately serve. This impact expands beyond GWI and the community to the supply chain. This code of conduct describes the minimum standard all suppliers must adhere to. These are in addition to any terms, conditions and provisions of legal agreement or contracts.
These standards are aligned with the GWI Company policies, the Ten Principles of the UN Global Compact, UN Universal Declaration of Human Rights, and the International Labor Organization (ILO) International Labor Standards.
By its acceptance of any purchase order from GWI, the Supplier acknowledges its acceptance of the Supplier Code and intention to comply with its requirements.

Labor
Child Labor
GWI does not tolerate any form of child labor in our supply chain. We are committed to the elimination of the “worst forms of child labor,” as defined by ILO Convention 138 & 182. GWI expects our Suppliers to prevent child labor in their operations and encourages our Suppliers to participate in industry efforts aimed at the elimination of such practices wherever they exist in the supply chain.
No individuals are hired under 15 years of age, or 14 years of age where local law allows, and such exception is consistent with ILO Convention No. 138 & 182, or under the legal minimum age for employment in the country, whichever is greatest.
Any employment of workers under the age of 18 does not interfere with schooling or vocational education or expose children to risks that can harm physical, mental or emotional development

Forced Labor
Suppliers shall not use forced, bonded (including debt bondage) or indentured labor or involuntary prison labor or exploitative prison labor, slavery or trafficking of persons. All work will be voluntary, and workers should be free to leave work or terminate employment upon reasonable notice. Prohibited actions include transporting, harboring, recruiting, transferring or receiving persons by means of threat, force, coercion, abduction or fraud for labor or services. As part of the hiring process, Suppliers should provide workers with a written employment agreement in their native language that contains a description of terms and conditions of employment prior to the worker departing from his or her country of origin and there shall be no substitution or changes allowed in the employment agreement upon arrival in the receiving country unless these changes are made to meet local law and provide equal or better terms. All work must be voluntary, and workers shall be free to leave work at any time or terminate their employment. Employers and agents may not hold or otherwise destroy, conceal, confiscate or deny access by employees to their identity or immigration documents, such as government-issued identification, passports or work permits, unless such holdings are required by law. Workers should not be required to pay employers’ or agents’ recruitment fees or other related fees for employment. If such fees are found, then these fees should be repaid to the worker.

Wages & Hours
GWI is committed to upholding applicable laws and collective bargaining agreements regarding working hours, wages and benefits for individuals employed throughout the supply chain. We encourage our Suppliers to work toward paying a wage that is sufficient for workers to meet their basic needs and provide some discretionary income.
Wages and benefits are paid on time and at least equal to the applicable legal minimum wage and any associated statutory benefits.
Working hours reflect applicable legal norms and overtime hours are paid at the legally mandated premium or in line with the guidance provided by ILO Convention 1 (the rate of pay for overtime shall not be less than one-and-one-quarter times the regular rate) if there is no mandated premium.
Suppliers shall ensure that work schedules and rest periods are consistent with applicable local legal requirements. Work hours and schedules should not be excessive and negatively impact employees’ health or safety.

Freedom of Association & Right to Collective Bargaining
In conformance with local law, Suppliers shall respect the right of all workers to form and join trade unions of their own choosing, to bargain collectively and to engage in peaceful assembly as well as respect the right of workers to refrain from such activities. Workers and/or their representative shall be able to openly communicate and share ideas and concerns with management regarding working conditions and management practices without fear of discrimination, reprisal, intimidation or harassment.

Discrimination
Suppliers shall be committed to a workforce free of harassment and unlawful discrimination. Suppliers shall not engage in or permit discrimination or harassment based on race, color, age, gender, sexual orientation, gender identity or expression, ethnicity, national origin, disability, pregnancy, religion, political affiliation, union membership, covered veteran status, protected genetic information, or marital status in its workforce, including but not limited to in hiring and employment practices such as promotions, rewards, and access to training. Suppliers shall ensure equal opportunities throughout all levels of employment and shall establish measures to eliminate health and safety concerns that are especially prevalent among women workers (for example, physical security and sexual harassment). There shall be no discrimination or retaliation against workers, including migrant workers, who raise grievances in good faith. Workers shall be provided with reasonable accommodation for religious practices. In addition, workers or potential workers should not be subjected to medical tests or physical exams that could be used in a discriminatory way.

Human Rights
Internationally proclaimed human rights are to be respected and supported universally. GWI does not tolerate any disparate treatment, or acts (including complicity) of human rights abuses.

Discrimination & Harrasment
All workers will be treated with dignity and respect and will not be subject to any form of unethical treatment, threats of violence, or other forms of physical, mental, or sexual harassment.
Disciplinary policies and procedures in support of these requirements are clearly defined and communicated to all workers.

Safety
Working, and living (if applicable), conditions must meet, at a minimum, standards set by local law. Workers must not face any undue health or safety risks from working or living conditions. The foregoing requirements shall be applicable to any lodging provided to workers as part of or in connection with their employment.
Transportation provided by a supplier or agent on supplier’s behalf must be safe and in compliance with legal requirements.

Environment
GWI is committed to reducing our environmental impact across our supply chain and to supporting sustainable operational and production practices. We work with our Suppliers who are critical partners in our efforts to responsibly and sustainably source our goods and services in a way that will help reduce our impact on air, land and water.
Suppliers are encouraged to actively measure, manage and disclose environmental impacts in areas such as Greenhouse Gas (GHG) emissions, water and waste as well as to set targets and implement action plans for reducing environmental impacts. Public reporting on annual environmental performance is encouraged.
Operations fully comply with all federal and local environmental laws and regulations including those related to waste disposal, hazardous waste, greenhouse gas emissions, wastewater and toxic substances.
Air emissions, wastewater and solid waste generated from operations are to be characterized, monitored, controlled and treated as required prior to discharge or disposal.
Operations and work across supply chains do not contribute to deforestation or loss of biodiversity. Suppliers are encouraged to implement their own No Deforestation Policy and commitments to protecting High Conservation Value and High Carbon Stock areas.
All required environmental permits (e.g. discharge and effluent monitoring records) are obtained, maintained and kept current and any operational, registration and reporting requirements shall be followed.

Ethics
Business Integrity
Supplier shall maintain the highest standards of integrity in all interactions with GWI. Suppliers shall have a zero-tolerance policy that strictly prohibits any and all forms of corruption, extortion and embezzlement. Supplier shall not take unfair advantage of GWI or anyone else through abuse of privileged or proprietary information, misrepresentation of material facts or any other unfair or dishonest practices. Any violation of this standard may result in immediate termination and legal actions.

No Improper Advantage Gifts
Bribes or other means of obtaining undue or improper advantage shall not be promised, offered, authorized, given, or accepted. This prohibition covers promising, offering, authorizing, giving or accepting anything of value, either directly or indirectly through a third party, in order to obtain or retain business, direct business to any person, or otherwise gain an improper advantage. Monitoring and enforcement procedures shall be implemented to ensure compliance with anti-corruption laws. Supplier shall not offer any GWI employee any gifts, payments, fees, services, discounts, valued privileges or other favors where these would, or might appear to, improperly influence the employee in performing his or her duties for GWI. GWI employees can be offered common courtesies normally associated with accepted business practices, so long as these are offered openly and not in a form that could be construed as a bribe, payoff or secret compensation.Regardless of value, items deemed not acceptable include gifts or raffles or tickets to sporting events, discounts on personal purchases, gift certificates, payment for travel, or other expensive gifts. Business lunches or dinners are acceptable if not excessive and if GWI and the Supplier take turns paying for such events. In all cases, the use of bribes, secret compensation (including monetary gifts or their equivalent) or kickbacks is improper and may result in immediate termination and legal actions.

Charitable Contributions
GWI’s business choices of its Suppliers are based solely upon bid prices, quality and ability and availability to do the work and previous Supplier performance in servicing GWI’s needs. These choices are not influenced by a Supplier’s giving or not giving to any particular charity. GWI does not solicit charitable donations from other companies or suppliers. GWI employees are prohibited from requesting that Suppliers make charitable donations by implying that such donations may affect their business or future with GWI

Disclosure of Information
All business dealings should be transparently performed and accurately reflected on Suppliers’ business books and records. Information regarding labor, health and safety, environmental practices, business activities, structure, financial situation and performance is to be disclosed in accordance with applicable regulations and prevailing industry practices. Falsification of records or misrepresentation of conditions or practices in the supply chain are unacceptable. The privacy of data regarding Supplier and GWI employees will be respected in accordance with applicable laws.

Privacy & Intellectual Property
Suppliers shall be responsible for ensuring the reasonable protection of personal information of everyone they do business with, including suppliers, customers, consumers and employees. Suppliers shall comply with privacy and information security laws and regulations in connection with the collection, storage, processing, transmission, and sharing of personal information.
Intellectual property rights are to be respected; transfer of technology and know-how is to be done in a manner that protects intellectual property rights; and customer and supplier information is to be safeguarded. Supplier shall maintain procedures that reasonably ensure that GWI confidential information will not be improperly used or disclosed.

*Our significant suppliers: Used to provide network and customer services: Consolidated Communications, FirstLight, Spectrum, Hawkeye Connections, ICON Connections, Vardata, Walker & Associates, CDW. Used to help communicate to the world: Blaze Partners, and to help provide employee benefits: Harvard Pilgrim Health Care.

*GWI reserves the right to change our policies at any time. For questions, concerns or clarification about this policy or the administration of this policy, please contact the Controller or CFO.