Contentsquare Group Supplier Business Code of Conduct
Introduction
To empower businesses to create a world where everybody gets the experience they love, seek and deserve — an experience that is accessible, inclusive, trustworthy and sustainable.
— Contentsquare’s Mission Statement
This Supplier Business Code of Conduct is central to Contentsquare SAS, its affiliates and subsidiaries (together, “Contentsquare”) values and to setting clear guidelines for our Suppliers (as defined hereinafter). In alignment with our Sustainable Procurement Policy, our Supplier Business Code of Conduct seeks to promote ethical standards and sustainability across our supply chain outlining the expectations and requirements that all Contentsquare Suppliers must continuously meet in order to maintain a collaborative and ethical business relationship with us.
In 2023, Contentsquare officially became a purpose-driven company under French Law. As proud signatories of the UN Global Compact, we are deeply committed to harmonizing our business practices and upholding the highest standards of social and environmental responsibility.
All Contentsquare Suppliers must recognize the importance of adhering to the commitments presented in this Supplier Business Code of Conduct, and commit to cooperate with Contentsquare in order to apply these in the best way. For more information on the above and Contentsquare’s commitment to ethical business practices, please read the Contentsquare Group Codes of Business Conduct and Ethics.
Contentsquare reserves the right to update or change these requirements at any time.
Compliance with this Supplier Business Code of Conduct
Suppliers and their employees, personnel, agents, subcontractors, and sub-tier suppliers (collectively referred to as “Suppliers”) shall adhere to this Supplier Business Code of Conduct while conducting business with or on behalf of Contentsquare. Suppliers shall require their subcontractors, and sub-tier suppliers to comply with the Supplier Business Code of Conduct in their operations and across their supply chains for work that is directly related to a Contentsquare contract. All Contentsquare Suppliers must promptly report any actual or potential conflicts of interest, unethical behavior, or violations of these Codes to Contentsquare to compliance@contentsquare.com.
Suppliers are responsible for implementing and monitoring internal improvement programs designed to achieve conformance with the Supplier Code of Conduct. Contentsquare reserves the right to audit and assess Supplier facilities, processes, and documentation to ensure compliance with these Codes.
All Contentsquare Suppliers will be subject to ongoing monitoring and evaluation of their compliance with the Supplier Code of Conduct. Non-compliance may result in corrective actions, termination of the business relationship, or other appropriate measures.
Commitments
1. Ethical Business Relationships
All Contentsquare Suppliers must operate with integrity, honesty, and transparency, avoiding any form of corruption, bribery, or unethical practices.
Compliance with Laws and Regulations
All Contentsquare Suppliers must comply with all applicable laws, rules, regulations, and ethical standards in their respective countries of operation. Any stricter legal, regulatory and contractual requirements shall at all times supersede these Supplier Business Code of Conduct. Where applicable legal or regulatory requirements conflict with this Supplier Business Code of Conduct, Suppliers should follow the law while seeking to meet the underlying principles of the Supplier Code of Conduct.
Anti-Corruption, Bribery and Kickbacks
All Contentsquare Suppliers must have a zero-tolerance policy towards bribery, corruption, and unethical business practices. Any form of gift-giving or hospitality (whether direct or implied) that could influence business decisions, or be perceived as such, is strictly prohibited. Compliance with applicable anti-corruption laws is mandatory. Suppliers must fully comply with all anti-corruption laws of the countries in which they operate. These include but are not limited to:
The U.S. Foreign Corrupt Practices Act (1977);
The French Anti-Corruption Act;
The OECD Anti-Bribery Convention;
The U.K. Bribery Act (2010).
Suppliers should work against corruption in all its forms, including extortion, bribery, kickbacks or any form of unethical and illegal practice. This includes offering or receiving anything of value to obtain or retain business, an improper advantage, or favored treatment from any third party (including Government Officials), or any other person with whom Contentsquare or such Supplier does or anticipates doing business. Our Suppliers are required to keep accurate and transparent records that reflect actual transactions and payments.
Anti-Money Laundering
Suppliers must comply with applicable anti-money laundering laws, including:
The USA Patriot Act (2001);
The Domestic and International Money Laundering Statutes (18 U.S.C. § 1956);
The Money Laundering Control Act (1986);
The UK Sanctions and Anti-Money Laundering Act (2018);
The French Monetary and Financial Code.
Suppliers are asked to conduct due diligence to prevent money laundering activities. Our Suppliers must immediately alert Contentsquare of any suspicious activity related or affecting Interactions with Contentsquare, and cooperate fully with legal and regulatory authorities charged with enforcing anti-money laundering laws.
Trade Compliance
All Contentsquare Suppliers must comply with all export laws and regulations, trade sanctions and import obligations applicable in the country(ies) where the transaction(s) occur(s), such as, but not limited to:
U.S. Export Administration Regulations (EAR);
U.S. sanctions regulations administered by the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC);
EU Dual-use Regulation (EU) 2021/821.
Conflict of Interest
All Contentsquare Suppliers are required to avoid, identify and disclose any potential or actual situations of conflict of interest.
Suppliers should avoid any actions that could lead to, create or appear to create a conflict of interest. A conflict of interest is any action or relationship that may influence the outcome of a business where Contentsquare is directly or indirectly concerned or involved. This includes offering, providing, or reimbursing personal gifts, favors, personal travel expenses, lodging or other housing, services of any kind, excessive meals or entertainment, or any other thing of value to Contentsquare employees and personnel. Additionally, if a Supplier has a personal relationship with a Contentsquare employee that could influence business decisions, this must be explicitly disclosed. While such relationships are not necessarily a barrier to doing business, transparency is required.
Suppliers should disclose any potential or actual conflicts of interest to Contentsquare and seek guidance on how to manage or mitigate them by sending an email to compliance@contentsquare.com
Honesty and Fair Dealings
Suppliers must uphold standards for fair business practices, including accurate and truthful advertising and fair competition. Suppliers must not engage in deceptive practices including manipulation, concealment, abuse of privileged information or misrepresentation of material facts.
Intellectual Property
All Contentsquare Suppliers must respect intellectual property rights and ensure that any products or services provided do not infringe on the intellectual property rights of others.
Suppliers must respect Contentsquare's intellectual property rights. Any transfer of technology or know-how must protect these rights in accordance with applicable intellectual property laws.
Confidentiality and Insider Trading
All information about Contentsquare, including our operations, products, and personnel, obtained through a relationship with Contentsquare, and that is not publicly known, or which Contentsquare seeks to protect as confidential or proprietary, must be treated with the utmost confidentiality and not disclosed to any third party.
We expect our Suppliers to comply with applicable security and privacy laws, regulations and retention requirements, and to ensure that they have appropriate technical and security controls in place to protect our information. Any non-public information obtained as part of the relationship with Contentsquare must not be used for the personal benefit of the Supplier or any other individuals.
2. Labor and Human Rights
We are committed to supporting and respecting the protection of internationally proclaimed human rights and ensure we are not complicit with human rights abuses. We expect our Suppliers to do the same. Our Suppliers directly or indirectly engaged in providing Contentsquare goods or services, must respect the human rights of all their employees and contractors, ensuring fair treatment, non-discrimination, and equal opportunity for all and ensure compliance with all applicable labor laws and internationally recognized labor standards, including those outlined by the United Nations Guiding Principles on Business and Human Rights, as well as the International Labour Organization (“ILO”)’s Declaration of Fundamental Principles & Rights at Work and ILO’s International Labor standards.
No Child Labor
Suppliers must ensure there is no direct or indirect child labor of any form in their operations, especially within their subcontractors, in accordance with ILO Convention No. 138 and No. 182.
No Forced Labor
Suppliers must not engage in any form of slavery or human trafficking, nor procure commercial sex acts. They must ensure the elimination of all forms of forced, bonded, compulsory or involuntary labor. Work must be undertaken voluntarily and all workers must be free to terminate their employment at any time.
Safe Working Conditions
All Contentsquare Suppliers must provide safe, healthy, and hygienic working conditions, in compliance with local and international applicable laws and regulations. This includes ensuring reasonable working hours, fair wages, adequate rest periods in compliance with local labor laws and demonstrating a commitment to providing mental health support to their employees.
Freedom of Association
Suppliers must respect the rights of employees to freely associate and engage in collective bargaining, in accordance with applicable local laws. Suppliers must allow their workers to openly raise grievances with their managers about working conditions without fear of reprisal or harassment.
No Harassment
Suppliers (including their subcontractors) must treat all their employees and other personnel with dignity and respect. They must not treat or threaten to treat an individual harshly or inhumanely, and maintain a workplace free from harassment, including bullying. In particular, Suppliers must not tolerate behavior—including gestures, language, and physical contact—that is sexual, coercive, threatening, abusive, or exploitative in nature
Equal Opportunity and Non Discrimination
At Contentsquare we believe everyone deserves an equal chance to succeed and contribute. Our Suppliers must never discriminate or deny equal opportunity. Suppliers should uphold fair employment practices, ensuring equal opportunity and treatment in hiring, advancement, and compensation, providing equal pay for equal work. All decisions must be based on merit, qualifications and performance and never on characteristics such as gender identity or expression, race, color, ethnicity, medical condition or disability, religion, age, sexual orientation, marital status, pregnancy, national origin, caste, political affiliation, union membership, protected veteran status, or any other characteristics that are protected by law. Any discrimination should be reported immediately to the appropriate designated authority, pursuant to applicable laws.
Diversity & Inclusion
Our commitment to diversity and inclusion is core to our mission and values, and we expect the same commitment from our Suppliers. Suppliers are encouraged to establish policies and practices to identify, measure and establish a culture of diversity and inclusion within the workplace.
Artificial Intelligence
Suppliers must ensure any use of artificial intelligence (AI) in the provision of services to Contentsquare is in compliance with applicable laws and regulations and adheres to ethical AI practices which are consistent with Contentsquare’s values. We expect our Suppliers to commit to using and developing AI systems which are designed to be secure, transparent and explainable as well as incorporating appropriate safeguards to prevent unfair outcomes, harm, bias or discrimination.
3. Impact
Environmental Sustainability
Contentsquare is committed to minimizing its negative impact on the environment and has embedded this commitment in its bylaws. We thus seek Suppliers who share our dedication to environmental responsibility.
Our Suppliers must operate in compliance with all applicable environmental laws. In addition, they are encouraged to adopt, promote and implement environmentally sustainable practices in their operations. This includes energy-efficient manufacturing processes, recycling programs, and waste reduction initiatives.
We favor Suppliers who proactively assess the environmental risks of their activities and establish programs to mitigate their impact on the climate, natural environments, resource consumption and air quality.
As Contentsquare is engaged in a GreenHouseGaz (GHG) emission reduction trajectory aligned with the Paris agreement, we prioritize Suppliers who contribute to our efforts to reduce our Scope 3 emissions. Therefore, Contentsquare Suppliers will be asked to share their GHG reporting on an annual basis to sustainability.desk@contentsquare.com.
Digital Accessibility
Contentsquare is committed to enabling a digital world which is accessible and inclusive to all. Digital accessibility is a core value in our operations, and we expect our Suppliers to demonstrate a commitment to accessibility in their digital activities.
At a minimum, our Suppliers must comply with all applicable local and international accessibility laws, such as the Americans with Disabilities Act (ADA) in the USA or the European Directives answering the European Accessibility Act, to ensure their products and services are accessible to everyone.
Suppliers are encouraged to adhere to recognized accessibility standards, such as the Web Content Accessibility Guidelines (WCAG) 2.2 level AA or higher, to ensure their offerings are usable by people with disabilities.
Compliance to accessibility laws is taken into consideration in our choice of suppliers, and is mentioned in our requirement specifications and contracts.
ESG Performance
Suppliers are encouraged to regularly measure and report their environmental, social, and governance (ESG) performance, using common frameworks like Global Reporting Initiative (GRI) standards. Contentsquare Suppliers may be asked to share their ESG performance (such as Ecovadis scorecards, sustainability reports or other ratings) on a yearly basis, and to comply with assessment requests issued by Contentsquare.
4. Data Security, Confidentiality, Privacy and Data Protection
Data Security
Suppliers must implement Contentsquare’s security requirements in their systems, processes and policies, and ensure the applicability of these security requirements upon any of their third party providers. For more details, please refer to Contentsquare’s General Security Policy and Supplier Security Standards.
Data Protection and Privacy
Contentsquare expects Suppliers to protect Contentsquare’s employees, customers and other individuals whose personal data they process on behalf of or provided by Contentsquare.
Suppliers must comply with applicable data protection laws and regulations in the respective countries where they provide services to Contentsquare, as well as Contentsquare’s privacy standards, including processing personal data lawfully, only for the purposes set forth in the agreement with Contentsquare and retaining it for the time necessary for those purposes.
5. Compliance with the Supplier Business Code of Conduct
Whistleblowing and Reporting
Suppliers must allow and encourage their employees to report any unethical behavior or violations of this Supplier Business Code of Conduct. Contentsquare expects the Suppliers to establish and maintain a mechanism for confidential reporting, to protect whistleblowers from retaliation and to ensure confidentiality during investigations.
The confidentiality of the identity of any person providing to Contentsquare information regarding actual or alleged illegal conduct will be maintained to the extent possible, without impeding the investigation and resolution of the matter.
Our Suppliers commit that no employee will punish or retaliate against anyone who refuses to participate in misconduct, anyone who cooperates with an investigating agency, or anyone who engages in good faith reporting of information.
Monitoring & Investigating
Contentsquare reserves the right to monitor and assess Suppliers' adherence to this Supplier Business Code of Conduct, including conducting audits and on-site assessments, requiring existing or prospective Suppliers to complete ESG questionnaires, reviewing available information on sustainability practices, or using any other measures necessary to evaluate Supplier performance, as specified hereinabove.
Violation and Enforcement
Contentsquare may disqualify any potential supplier or terminate any relationship with a current Supplier that has failed to conform to this Supplier Business Code of Conduct.
We value our Suppliers as partners in achieving our mission to empower businesses to create accessible, inclusive, trustworthy, and sustainable experiences. By adhering to this Supplier Business Code of Conduct, our Suppliers help us uphold these standards and contribute to a positive global impact.
For any questions or concerns, please contact procurement@contentsquare.com.