Automai Partner Code of Conduct
- Purpose and Scope
At Automai, we are committed to conducting our business with integrity, fairness, and respect for human rights. We expect our business partners—including contractors, consultants, software developers, technology vendors, and service providers (“Partners”)—to share our commitment to lawful, ethical, and responsible business practices.This Code of Conduct outlines the minimum standards that all employees and Partners must adhere to when conducting business with or on behalf of Automai.
- Labor and Human Rights
Partners must uphold the fundamental rights of workers and adhere to all applicable labor and employment laws. This includes:
- Voluntary Employment: No use of forced labor, bonded labor, indentured labor, involuntary prison labor, or human trafficking.
- Child Labor: Partners must comply with the minimum age for employment as defined by local law or international standards, whichever is more stringent.
- Wages and Benefits: Partners must pay workers at least the minimum wage required by applicable law and provide legally mandated benefits.
- Working Hours: Partners must not permit their workers to exceed the maximum set by local law. Overtime must be voluntary and compensated as required by law.
- Non-Discrimination and Equal Opportunity: Partners must provide a workplace free from harassment and discrimination based on race, gender, religion, national origin, disability, age, sexual orientation, or any other protected status applicable to the United States or the jurisdiction where Partner is located.
- Freedom of Association: Partners must respect the rights of employees to freely associate, join labor unions, and engage in collective bargaining in accordance with local laws.
- Health, Safety, and Working Conditions
Partners are required to provide safe and healthy working conditions for their personnel in compliance with applicable occupational health and safety laws and standards. Partners shall provide its personnel with adequate training, equipment, and procedures to prevent accidents and injuries, and shall have procedures in place for identifying and addressing workplace hazards and emergency response.
- Anti-Corruption and Anti-Bribery
Automai prohibits actions or enticements that can be construed as either acts of bribery or corruption. Automai complies with laws that preclude such corporate behavior, including the U.S. Foreign Corrupt Practices Act (FCPA). Automai requires that its Partners also adhere to the FCPA and have programs in place to establish anti-bribery and anti-corruption controls. Similar laws in other countries strictly prohibit paying individuals within government or commercial entities to bias or favor the procurement of government and commercial contracts. Violations of the regulations, as well as such payments, may result in criminal charges, debarment, fines, and penalties. Specifically, Automai employees and Partners are prohibited from giving anything of value, directly or indirectly, to government officials, government contractors or subcontractors, commercial counterparts (including officers and employees of that entity), or politicians regardless of jurisdiction or country, in order to solicit business or gain an advantage in a bid for the procurement of products or services. Indirect payments to third parties to unduly influence bids and procurement are also strictly prohibited. Partners must comply with laws such as:
- U.S. Foreign Corrupt Practices Act (FCPA)
- UK Bribery Act
- Any applicable local anti-bribery laws in the countries where they operate
This includes offering or accepting anything of value to gain an improper business advantage, whether in dealings with public officials or private entities.
- Fair Competition
Partners must comply with applicable antitrust and competition laws, and only compete based on the merits of the goods and services offered. Specifically, Partners are prohibited from:
- Sharing pricing and other material factors related to an engagement or bid with competitors
- Providing confidential competitive information to competitors and/or their affiliates
- Manipulating the terms and conditions, including pricing and credit terms, related to Automai’s procurement of goods and services, such that Automai is precluded from competing fairly and based on the merits of Automai’s goods and services offered to the market
- Conflicts of Interest
Conflicts of interest occur when individuals and organizations have dual, competing interests that conflict with their fiduciary responsibilities to their employers and/or customers, resulting in business decisions that are not in the best interest of the customer or Automai. Conflicts of interest can pose significant ethical challenges and erode trust. Partners must disclose scenarios where conflicts of interest, or potential conflicts of interest, may arise.
- Environmental Responsibility
Partners are expected to minimize their environmental impact and must comply with all applicable environmental laws and regulations. If applicable, Partners must comply with environmental laws concerning emissions, waste disposal, energy usage, and pollution prevention, in line with international sustainability expectations.
Partners must reduce waste, emissions, and energy usage where possible, and handle hazardous substances responsibly and dispose waste according to all regulations.
- Labor and Employment
Partners must adhere to all local, national, and international labor laws, including regulations governing:
- Minimum wage and benefits
- Working hours, overtime, and rest periods
- Anti-discrimination and equal opportunity
- Freedom of association and collective bargaining
- Occupational health and safety
- Human Rights and Anti-Slavery
Human rights are global in nature, and even if Partner operates in jurisdictions or countries where human rights are not formally codified, Partners are expected to operate in accordance with international norms that ensure equal opportunity for employees regardless of their race, gender, national origin, sexual orientation, religion, or other characteristics. Partners must comply with all laws prohibiting modern slavery, human trafficking, forced labor, and child labor. Partners must also monitor their subcontractors and labor providers to ensure these standards are upheld throughout the supply chain. This includes
jurisdiction-specific legislation such as:
- UK Modern Slavery Act 2015
- Australia’s Modern Slavery Act 2018
- California Transparency in Supply Chains Act
- Germany’s Supply Chain Due Diligence Act (LkSG)
- Canada’s Fighting Against Forced Labour and Child Labour in Supply Chains Act
- Trade Compliance and Export Controls
Partners must follow all applicable international and federal regulations governing the importing or exporting of goods and technology. Partners are expected to maintain appropriate import and/or export documentation as required by trade laws and import/export regulations, which are used to calculate duties, tariffs, and other obligations, including the enforcement of trade restrictions and embargoes. Partners must ensure that their products, services, or software are not provided to restricted persons, entities, or jurisdictions. Partners must comply with all applicable export control laws, trade sanctions, and customs regulations, including:
- U.S. Export Administration Regulations (EAR)
- European Union Dual-Use Regulation
- United Nations and national sanctions regimes
- Intellectual Property and Confidentiality
Partners must respect and protect the intellectual property rights of Automai and third parties. Partners may only use software and content with proper licenses, and protect confidential information obtained during the course of business. Partners must also implement reasonable safeguards to prevent unauthorized use, disclosure, or duplication of proprietary materials.
- Insider Trading
As part of the goods and services provided to Automai, Partners may have access to confidential and sensitive information. Material, non-public information and other forms of confidential information must be properly governed and controlled, and used only for their intended purpose. Partners and their employees are prohibited from using confidential information for the Partners’ or their personnel’s benefit beyond the scope of their engagement with Automai and the purpose for which such confidential information was provided to them.
- Data Privacy and Cybersecurity
Partners are expected to maintain a reasonable security program to safeguard personal data, prevent unauthorized access, and report breaches in a timely and transparent manner to Automai. Such security programs should include administrative, technical, physical, and operational controls, have executive sponsorship, and should be modeled on recognized standards for security practices (e.g., NIST CSF, ISO 27001, or CIS CSC). Partners shall also have privacy programs that comply with state, federal, or international privacy regulations, as applicable, including:
- General Data Protection Regulation (GDPR)
- California Consumer Privacy Act (CCPA)
- Personal Information Protection and Electronic Documents Act
(PIPEDA)
- Monitoring and Enforcement
Automai reserves the right to assess compliance with this Code through audits, assessments, and third-party reviews. Non-compliance may result in corrective action, suspension, or termination of the business relationship.
Partners are encouraged to report concerns or suspected violations of this Code.
- Acknowledgment
By engaging in business with Automai, Partner acknowledges this Code of Conduct and agrees to adhere to its principles.