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CALABRIO SUPPLIER AND PARTNER
CODE OF CONDUCT

Legal and Regulatory Compliance

Calabrio’s success and reputation are built on a foundation of fairness and ethical conduct. We are dependent on the trust of our customers and our business community and, as such, all suppliers, vendors, and business partners that work with Calabrio (collectively, “Partners”) are required to act in a manner that demonstrates a commitment to ethical and compliant business practices. It is our expectation that all Partners maintain a binding Code of Conduct that incorporates each of the principles described below.

Adherence to Laws, Regulations, and Agreements

All Partners must operate in full accordance with applicable laws, regulatory frameworks, and contractual obligations. This includes satisfying all required licenses and registrations relevant to their operational jurisdictions.

Trade Compliance

All international exchanges of products, services, and data must align with global trade laws. Partners are expected to comply with all export and trade sanctions, including those issued by U.S. regulatory bodies such as the Departments of State, Commerce, Treasury, Defense, and Energy.

Anti-Bribery and Anti-Corruption

Calabrio is committed to conducting all business with integrity and in full compliance with anti-corruption laws, including the U.S. Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act 2010. We strictly prohibit any form of bribery or corruption and expect our Partners to do the same. Partners may be required to complete due diligence assessments as part of our vetting process. No gifts may be given to or solicited from Calabrio personnel unless in compliance with Calabrio’s Code of Business Ethics and Conduct.

Information Protection and Data Privacy

Confidentiality and Intellectual Property

Partners must protect all confidential and proprietary information obtained through their relationship with Calabrio, in accordance with applicable agreements. Respect for intellectual property rights is essential and must align with contractual terms.

Data Security

Partners must maintain appropriate data security controls in line with industry standards and best practices and ensure that all information is secure. Partners may be asked to respond to annual security assessments. Partners are expected to notify Calabrio of any known or suspected security breach involving Calabrio data without undue delay.

Data Privacy

In cases where personal data of Calabrio’s customers or personnel is accessed, it must be handled in strict accordance with data protection laws. Partners must confirm that personal information will only be used for agreed contractual purposes and will not be sold or misused.

Business Integrity

Conflict of Interest

Partners are expected to avoid situations that could create actual or perceived conflicts of interest with respect to obligations between the Partner and Calabrio. Any such potential issues should be promptly disclosed to the appropriate Calabrio contact.

Financial Accuracy

All financial records must be maintained accurately, adhering to legal and regulatory standards, and following generally accepted accounting principles. These records must be retained according to applicable laws.

Fair and Safe Workplaces

Workplace Standards

Partners are expected to comply with all workplace laws, support diversity, and ensure a professional environment free from harassment and discrimination. Employees must be treated fairly regarding wages, working hours, and workplace conditions.

Human Rights, Anti-Trafficking and Modern Slavery

Calabrio has zero tolerance for forced labor, child labor, or human trafficking. All Partners must uphold basic human rights and adhere to employment laws. We will not knowingly partner with any organization failing to meet these standards.

Additionally, Calabrio expects all Partners to comply with applicable laws relating to anti-slavery and human trafficking, including, without limitation, the United Kingdom’s Modern Slavery Act 2025 and maintain and comply with the Partner’s own modern slavery policy that incorporates the principles described above.

Health, Safety, Environment, and Quality

Partners are responsible for maintaining safe, healthy, and environmentally conscious workplaces. Compliance with all applicable laws and contractual safety and environmental obligations is mandatory. All services and goods must meet or exceed expected quality levels.

Questions, Concerns, and Reporting Misconduct

Partners are encouraged to report any ethical or integrity-related concerns involving Calabrio. Where local laws permit, they must cooperate with Calabrio in any investigations. Retaliation against whistleblowers will not be tolerated.

To submit a report, use one of the following options:

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