This Vendor Code of Conduct (“Code”) comprises the minimum standards ON24, Inc. and our subsidiaries (collectively, “ON24”) expect from suppliers of goods and services (“Vendors”). ON24 values honesty, transparency, fair treatment and respect for law and expects Vendors to reinforce our values by operating in compliance with the principles outlined in this Code.
This Code does not reduce, replace or limit any other legal or contractual obligations that Vendors have to ON24. The provisions of this Code are in addition to those specified in any agreement between a Vendor and ON24 and are incorporated into any such agreement. Vendors will comply with the laws and regulations of the countries in which they operate. ON24 has the right to conduct supply chain audits to review Vendors’ compliance with this Code. References to “Vendor” include affiliates, subsidiaries, employees, agents, suppliers, subcontractors and other representatives of suppliers of goods or services to ON24 or our affiliates. Vendors will educate such entities about this Code and ensure that subcontractors implement equivalent standards of conduct.
- Human Rights: Vendors must (i) treat all of their workers fairly and with dignity, (ii) adopt an approach to human rights consistent with the United Nations Universal Declaration of Human Rights and the International Labor Organization Core Conventions, (iii) support and respect the protection of internationally proclaimed human rights, and (iv) ensure that they are not complicit in human rights abuses.
- Collective Bargaining: Where legally authorized, Vendors shall respect their employees’ rights to join or form trade unions and to bargain collectively, or to conduct similar activities.
- Employment Practices: Vendors must not (i) use any form of slave, forced, bonded, indentured or involuntary labor, and shall fully comply with all laws that prohibit the use thereof, as and when applicable, (ii) engage in human trafficking or exploitation, (iii) import goods tainted by slavery or human trafficking, (iv) retain employees’ government-issued identification, passports or work permits as a condition of employment, or (v) violate applicable employment laws. Please see our Modern Slavery Statement for additional detail.
- Anti-discrimination, Diversity: ON24 respects individual and cultural differences and will not tolerate discrimination of any kind and expects our Vendors to share that commitment. Vendors must provide a workplace free of harassment and discrimination in which their employees are treated fairly and respectfully. ON24 is committed to dealing with all Vendors with integrity and in an ethical manner and to supporting and encouraging the aspirations of diverse groups. In the United States, Vendors must make good faith efforts to identify and, where available and qualified, use suppliers certified as minority, women, disabled person, lesbian, gay, bi-sexual, transgender, U.S. veteran-owned, and/or classified as a small business. ON24 makes the same good faith efforts.
- Underage Labor: Vendors must not use underage labor as defined by applicable law regulating minimum legal age to work. Workers below the age of 18 shall not be employed in jobs that are likely to jeopardize the health and safety of young workers.
- Pay and Hours: Vendors must provide all workers with accurate information about their wages, mandated benefits and any other basis of their compensation. Vendors must comply with applicable labor laws governing working hours and employee compensation in all locations in which they operate. Vendors will compensate their employees (including augmented/temporary staff) for hours worked in a globally known currency, such as the United States Dollar, British Pound, Japanese Yen, Indian Rupee, etc. Other forms of compensation such as stock, equity and employer-sponsored unqualified plans are also acceptable. Excluding standard employer-provided healthcare and retirement plans, Vendors will not deduct workers’ pay for employer-provided services such as living quarters, apartment utilities, food, hygiene products or any other basic human services.
- Safety: Vendors must: (i) treat their employees with dignity and respect and provide their employees with a safe and healthy workplace, (ii) employ reasonable procedures to detect, prevent and handle potential risks to the health, safety and security of employees, (iii) follow all applicable laws relating to health and safety in the workplace, and (iv) provide workers with appropriate workplace health and safety information and training.
- Whistleblower Protection and Anonymous Complaints: Vendors must protect the confidentiality of their whistleblower employees, prohibit retaliation, and, where legally permitted, provide an anonymous complaint mechanism for their employees to report grievances
2. Honesty and Integrity
Vendors must observe high standards of integrity in their business interactions and all of their business dealings shall be accurately reflected in their books and records in accordance with applicable laws. Vendors must follow and implement procedures to comply with all laws and regulations regarding bribery, corruption, money laundering, terrorist financing, kickbacks, embezzlement and other prohibited business practices, including but not limited to those described in the Foreign Corrupt Practices Act of 1977 (FCPA), the 2010 United Kingdom Bribery Act (UK Bribery Act), the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions, and other anti-corruption laws. Vendors must not make any false representations in connection with any ON24-related transaction, including, without limitation, in connection with the utilization of false documentation.
Vendors must not provide any gift, meal or entertainment to an ON24 employee in any situation which might improperly influence, or appear to improperly influence, such employee’s decision in relation to an ON24 supplier relationship, regardless of the norms of local custom.
4. Responsible Sourcing
Vendors must comply with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict Affected and High-Risk Areas and any domestic laws related to such guidance.
Vendors must operate in an environmentally responsible manner, strive to minimize adverse impact on the environment, reduce waste whenever practicable, and comply with all applicable environmental laws, rules and regulations where they operate.
6. Fair Competition
Vendors must comply with all applicable antitrust and fair competition laws and regulations.
7. Conflicts of Interest
Vendors must avoid any activity that may adversely impact ON24’s reputation or create actual, potential or perceived conflicts of interest in their dealings with ON24. Vendors must disclose any relationships with an ON24-affiliated person that may create actual, potential, or perceived conflicts of interest, including any family relationships between any Vendor and ON24-affiliated persons, and any known investment or ownership interest in ON24 or an ON24 affiliate by persons affiliated with Vendors (other than the ownership of less than 1% of any publicly traded, outstanding stock). Such disclosures should be made as described in “Reporting,” below.
8. Sanctions & Export Control
Vendors must have appropriate policies governing all applicable import and export controls, sanctions, and other applicable trade compliance laws. Vendor will not conduct business with individuals, companies, organizations or government entities from or located in a U.S.-sanctioned country or region.
9. Insider Trading
Applicable law and ON24 prohibit trading on the basis of material non-public information and “tipping” others by providing material non-public information to them. Material non-public information is information that has not been released to the public and which a reasonable investor would find useful in determining whether to buy or sell stock, e.g., financial results, sales results, acquisitions, customer wins or losses, or changes in senior management. Vendors must not buy or sell stocks (including ON24’s stock) or other equities on the basis of material non-public information, or pass such information to any others, including close acquaintances.
10. Data Security
Vendors will handle and process data only for the purposes it was collected or otherwise made available. Vendors will at all times use appropriate industry-standard and best practices data security controls to ensure that all information is protected and secure from damage and unauthorized use. Vendors must respect and maintain the confidentiality of all non-public information about ON24 and our activities, employees, contractors, customers, clients or applicable third parties.
If a Vendor becomes aware of or suspects any violation of this Code, then the Vendor should submit a report (anonymously, if so desired and where legally permitted) to ON24 by:
- Sending a letter to ON24’s Compliance Officer at 50 Beale Street, 8th Floor, San Francisco, CA 94105;
- Calling ON24’s whistleblower hotline (anonymously or not) by phone at 1-800-916-7037; or
- Completing a report online (anonymously or not) at https://irdirect.net/oninc/whistleblower_iframe?language=english.
Vendor will not retailiate against any employee who has, in good faith, reported violations or questionable behavior, or who has sought advice regarding this Code.