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Supplier Code of Conduct

Effective Date: October 2024

Introduction

This Supplier Code of Conduct (the “Code”) outlines the basic principles and expectations for suppliers doing business with Perficient. Perficient wants to ensure that all suppliers adhere to ethical practices, legal requirements, and standards that promote a sustainable and responsible supply chain. Suppliers to Perficient are expected to conduct their business with integrity and transparency in compliance with all applicable local, state, and federal laws and regulations. This includes, but is not limited to, labor laws, environmental regulations, and anti-bribery/anti-corruption laws.

This Code is not intended to replace or supersede any specific contracts between Perficient and its suppliers. To the extent that a contract conflicts with any of the supplier requirements set forth herein, the contract controls or supplements this Code.

Suppliers can report ethics and compliance concerns related to Perficient’s colleagues, clients, or third parties to legal@perficient.com.

Labor, Human Rights, and Bribery/Corruption

Fair Treatment

Suppliers must treat all employees with dignity and respect. This includes providing a workplace free from harassment, discrimination, and any form of abuse in compliance with all applicable laws such as the U.S. Equal Employment Opportunity Commission laws and regulation.

Freedom of Association

Suppliers must respect the rights of employees to freely associate, join or not join labor unions, seek representation, and join workers' councils in accordance with local laws. Suppliers must not interfere with, obstruct, or prevent such legitimate activities.

Child Labor

The use of child labor is strictly prohibited. Suppliers must comply with all laws and UN conventions regarding the minimum working age and ensure that no child is employed in any stage of production.

Forced Labor

Suppliers must not engage in or support any form of forced or compulsory labor, and suppliers must comply with all applicable laws such as the UK Modern Slavery Act 2015. All work must be voluntary, and supplier employees should be free to leave their employment upon reasonable notice.

Wages and Benefits

Suppliers must ensure that employees receive fair wages and benefits that comply with the local laws and industry standards. This includes providing overtime pay and adhering to regulations on working hours.

Bribery and Corruption

Suppliers must not engage in, or support, any form of bribery or corruption in any aspect of their operations. This includes compliance with all applicable laws, including the U.S. Foreign Corrupt Practices Act (FCPA) and other anti-bribery and anti-corruption laws.

Health and Safety

Safe Working Conditions

Suppliers must provide a safe and healthy working environment. This includes adequate training, protective equipment, measures to prevent accidents and injuries, and OSHA compliance to the extent applicable to their businesses.

Emergency Preparedness

Suppliers must have emergency plans and procedures in place. This includes regular drills, clear evacuation routes, material data backups, and accessible emergency equipment.

Environmental Responsibility

Sustainability

Suppliers must strive to minimize their environmental impact. This includes the efficient use of resources, reducing waste, and implementing sustainable practices in their operations.

Compliance with Environmental Laws

Suppliers must comply with all applicable environmental laws and regulations. This includes obtaining necessary permits and adhering to applicable standards for emissions, waste disposal, and chemical management.

Data Security and Privacy

Suppliers must adhere to the following data security and privacy requirements to ensure the protection and privacy of Perficient’s and its clients’ confidential information, including Personal Data.  For purposes of this Code, Personal Data is defined as all personal, medical, and/or financial data pertaining to an identifiable individual, including data protected under applicable data privacy laws such the EU’s General Data Protection Regulation (GDPR), the Health Insurance Portability and Accountability Act (HIPAA), the Gramm-Leach-Bliley Act (GLBA), and the California Privacy Rights Act (CPRA).

Data Processing

Suppliers must ensure that any operation performed on Personal Data, such as collection, recording, organization, storage, adaptation, retrieval, use, disclosure, alignment, or destruction, complies with applicable data privacy laws.

Data Protection Policies

Suppliers must implement and maintain comprehensive data protection policies that comply with applicable data privacy laws.

Access Controls

Suppliers must enforce strict access controls to ensure that only authorized personnel have access to sensitive data.

Data Encryption

All sensitive data must be encrypted both in transit and at rest using at least industry-standard encryption methods.

Incident Response

Suppliers must have a written incident response plan in place to promptly address any data breaches or security incidents.

Disclosure and Use of AI

Suppliers must disclose the use of any artificial intelligence or machine learning (collectively “AI”) utilized in the performance of services and/or production goods to Perficient in writing. To the extent Perficient permits such use of AI, suppliers will ensure that this use is transparent and fair, and is performed with accountability, privacy, and safety in mind. Suppliers must continuously monitor and evaluate AI systems to ensure they operate as intended and address any issues that arise.

Regular Audits

Suppliers must conduct regular security audits and assessments to identify and mitigate potential vulnerabilities.

Employee Training

Suppliers must provide regular data security and privacy training to their employees to ensure they are aware of and comply with data protection and privacy laws and internal policies.

Publicity

The identities of Perficient’s clients and the nature of the services performed for Perficient’s clients are highly confidential.  Suppliers are not permitted to publicly identify Perficient clients with for whom they may perform services or disclose such information to a third party without Perficient’s prior written consent.

Monitoring and Enforcement

Audits and Inspections

Suppliers must allow Perficient or its designated agents to conduct audits and inspections of their facilities and operations in accordance with the terms of the contract between Perficient and the applicable supplier. This ensures compliance with the Code.

Corrective Actions

Suppliers must take corrective actions if any violations of this Code are identified. This includes timely implementation of remedial measures and continuous improvement of practices.

Updates

Perficient reserves the right to update and modify this Code at any time. It is the suppliers’ responsibility to stay informed and comply with the most current version of the Code. Any updates to this Code communicated through publication on Perficient’s website will be deemed to take effect immediately upon publication.

Questions?

For any questions or further information, please contact legal@perficient.com