Fill’s Supplier Code of Conduct outlines the behavioural and business standards that Fill expects from its Supplier Partners. In addition to implementing and maintaining their own internal procedures to ensure compliance with these standards, suppliers should have appropriate processes in place to allow their employees to gain an appropriate level of knowledge and understanding of the contents of this code, the applicable laws and regulations, as well as any other generally recognized and applicable standards.

Suppliers who fail to comply with Fill’s Supplier Code of Conduct will result in action, up to and including termination of contracts.

Fill reserves the right to require Suppliers to certify their compliance with this Code from time-to-time and to disqualify, or decline to do business with, any Supplier that is not in compliance with, or fails to provide a certification.

This Code of Conduct applies to all officers, directors, internal employees, consultants and contract employees of Fill.. Additionally, we expect that our suppliers, vendors, sub-vendors and business partners follow these principles and adhere to all of the principles outlined below.

Ethics‍

Fill looks to engage with Suppliers who treat others with respect, conduct their business in a fair and equitable manner, and act with integrity. Our suppliers must comply with all federal and local regulations, standards, and laws that are in place applying ethical principles across all levels of the company. This includes but is not limited to: opposing discrimination of employment, forced or compulsory labor or child labor, and modern slavery.

It is the responsibility of suppliers to avoid all conflicts of interest or situations that could appear to give rise to a conflict of interest. When a conflict of interest is identified, suppliers are expected to notify all affected parties.

Anti-Bribery & Corruption

Suppliers must comply with all laws, rules, and regulations applicable to the country or countries in which they operate, and where they deliver products and services to Fill and our client. Fill will not tolerate the offering, promising, giving, or facilitating any type of bribe. Nor do we tolerate requesting, accepting, agreeing to accept, or receiving a bribe.

Supplier Gift Acceptance Policy

Building business relationships and giving or receiving gifts can sometimes seem to go hand in hand. Fill discourages gifts from current or potential suppliers. Under no circumstance may a Fill employee accept cash or a cash equivalent as a business gift from a supplier. Our vendor neutrality is key to the success of our programs and the perception that Fill is giving preferential treatment to any supplier is detrimental.

Data Privacy / Cyber Security / Infosec

Fill Suppliers must protect all information and data received from Fill or any of our clients while doing business with Fill and in accordance with industry-recognized good security practices, legislation, regulation, and contractual obligations. Such information and data must be always kept confidential and not used for any purposes other than the business purpose for which it was provided or made available.

All such information and data must be kept confidential and protected from any unauthorized access, destruction, use, modification, and disclosure, through appropriate organizational and technical controls, in accordance with Fill policies and procedures.

Fill aims for the highest standards concerning the protection of any personal data that may be processed by suppliers on behalf of Fill and our clients. Fill always expects that its suppliers comply with applicable data protection legislation and implement industry-accepted security standards (whether appointed as a sub-processor by Fill or appointed as a processor by a Fill client).

Wherever suppliers are aware of a security and/or data privacy incident that affects or has the potential to affect Fill or its customers or their customers, they must inform Fill immediately.

Sanctions

Suppliers have a responsibility to ensure that they, and those within their supply chain, fully comply with applicable sanctions regimes (for example, United Nations, EU, UK and OFAC sanctions) and that they do not transact with any sanctions targets whether they are countries, entities or individuals.

We expect all our Suppliers to adopt and maintain appropriate processes to ensure compliance with applicable sanctions regimes.

Supplier Diversity

Fill DE&I is the only comprehensive Diversity, Equity & Inclusion (DE&I) solution for the contingent workforce. Fill’s best-in-class consulting capabilities and industry-leading technology help provide clients with actionable insights to further drive cultural inclusion and promote hiring and supplier diversity.

Fill’s vendor-neutral model allows us to coach and lead our diverse supplier businesses to maximize their market share, prioritizing suppliers that model DE&I best practices.

Worker Diversity

At Fill, we believe that truly fundamental and measurable change in contingent workforce diversity can only be brought about by focusing on the representation of individuals from sourcing, and candidacy, to hiring.

Fill’s Equal Opportunity Policy

Fill does not engage in any discriminatory practice or preferential treatment for applicants, employees, vendors, workers, suppliers, or clients. We firmly believe that our focus should be on sound business decisions and individuals’ merits and understand that our company will thrive only through an environment of inclusiveness.

Fill expects our Suppliers to also adopt appropriate practices and procedures that support a zero-tolerance approach to discrimination and comply with local laws.

Human Rights and Labor Standards

Our suppliers shall follow all applicable wage and hour laws, health and safety laws, family and medical leave laws, military leave laws, and employment discrimination laws. Suppliers must maintain a work environment free of harassment, hostility, and discrimination.

Suppliers should have in place a policy that they maintain/follow that recognizes and protects the human rights of their employees and any suppliers, partners or anyone connected to their business operations.

Health and Safety

Our suppliers must comply with all applicable health and safety laws to create a safe working environment for their employees and anyone else affected by their businesses.

Fill is committed to sustainable development through supporting economic prosperity, improving social well-being, and acknowledging our environmental responsibility. Our suppliers should possess the same commitment. Suppliers should strive to improve the communities within which they operate.

Sustainability

Fill requires that our suppliers comply with all applicable environmental laws, regulations and standards. Fill’s Environmental, Social and Governance policy is available on request.