Arena Supplier Code of Conduct

Introduction

Arena takes pride in our reputation for integrity and the business success that our reputation has enabled. This reputation has taken years to build and maintaining it is vital to our success. The Code has been developed to convey to all Suppliers Arenas’s expectation for all of its suppliers to adhere to the highest ethical standards when conducting business.
Suppliers are required to take reasonable steps to ensure that the Code is communicated throughout their organizations and to make the Code available to their employees. Arena values its business relationships with its Suppliers and requires its Suppliers to share our commitment to, at a minimum, compliance with the following standards:

Anti-Corruption ComplianceSuppliers may not act in any way, in their business relationship with Arena or otherwise, that violates the U.K. Bribery Act, the U.S. Foreign Corrupt Practices Act or any other anti-corruption law around the world. Arena entities use Suppliers that do not violate our ethical standards through bribes, kickbacks, or other similar improper or unlawful payments.
Suppliers shall comply with all national and international anti-bribery regulations as well as applicable anticorruption laws, regulations and standards. The Suppliers shall not (either directly or indirectly) offer or promise to provide anything of value to improperly influence an official act or to secure an improper advantage in order to obtain or retain business.
Compliance with LawsSupplier’s personnel and operations shall operate in full compliance with the laws of their respective countries and with all other applicable laws, all statutory, regulatory and other legal requirements, including but not limited to antitrust, trade controls and sanction regimes. Additionally, Suppliers will ensure that products and services for Arena adhere to all applicable international trade compliance laws, all statutory, regulatory and other legal requirements.
Arena has as its core policy a commitment to comply with the sanctions regimes of the United Nations, the United States of America, the European Union, United Kingdom, United Arab Emirates, and requires its Suppliers to comply with these and any other sanctions rules which may be applicable to their activities in and from the territories in which they operate. When providing services to Arena or its customers, Suppliers may not deal with any entities, organizations or persons which are under any applicable sanctions.
Confidential/Proprietary InformationSuppliers must respect Arena’s intellectual property, trade secrets and other confidential, proprietary or sensitive information and may not use or disclose any such information except in accordance with their contract with Arena and for the benefit of Arena. Any information or data regarding Arena operations shall always be treated by Suppliers as confidential unless that information enters the public domain through no fault of the Suppliers.
Data Protection and Privacy LawsSupplier will undertake necessary measures to ensure that personal data it handles on behalf of Arena will be protected against unauthorized disclosure, access, use and modification and that it will be used only for purposes of rendering the relevant services or as in compliance with applicable data privacy and data protection laws.
Ethical DealingsHonest dealing with customers and Suppliers is essential to sound business relationships. Arena seeks to give all Suppliers fair consideration. Decisions are based on objective criteria such as price, quality, and service capability as well as Suppliers’ reliability and integrity. Invoices, financial settlements and reports should correctly reflect the business transactions between us. Our Suppliers are required to demonstrate these same high ethical standards and to conduct all business transactions with integrity and fairness and shall encourage its own suppliers to adhere to this Code of Conduct as part of fulfilling their contractual obligations. Suppliers shall equally disclose any potential conflict of interests where individuals have private or personal interests that could influence their decisions.
Money Laundering and Financial RecordsSuppliers shall comply with applicable laws and regulations designed to combat money laundering activities. Supplier shall maintain financial records and reports according to international laws and regulations.
Health and SafetySuppliers who do business with Arena are encouraged to maintain a focus on health and safety that is consistent with Arena and must provide a safe and healthy work environment for all employees working at their sites. In addition, any Supplier representative providing on-site services in an Arena or third-party facility is required to adhere to Arena safety standards. It is our expectation is that Suppliers have and enforce a written policy on drugs, alcohol and other prohibited items.
Business Continuity PlanningSupplier shall be prepared for potential disruptions of its business through natural disasters, illness, pandemics, criminal acts, etc. This should include emergency plans to protect both employees and their wellbeing as well as to minimize the effects of such events on the delivery of products and services.
Diversity and InclusionSupplier shall encourage an inclusive work environment, valuing the diversity of its employees and contractors and avoiding discrimination with respect to gender, race, religion, age, disability, sexual orientation, origin or any other differentiating characteristics.
Modern SlaverySuppliers shall not use any form of forced, bonded or involuntary labor. All labor must be voluntary. Workers must be allowed to maintain control over their identification documents (e.g. passports, work permits or any other personal legal documents). Suppliers shall ensure that workers do not pay fees or make any payment connected to obtaining employment throughout the hiring process and the employment period. Suppliers shall pay workers in a timely manner and clearly convey the basis on which workers are being paid. Punishments, mental and/or physical coercion are prohibited. Disciplinary policies and procedures shall be clearly defined and communicated to the workers. Suppliers shall also not employ children under the legal age of employment in any country or local jurisdiction.
Environmental ResponsibilitySuppliers shall comply with all applicable environmental laws, regulations and standards as well as implement an effective system to identify and eliminate potential hazards to the environment. We expect our business partners to strive to support global climate protection goals through the products and services they deliver and to operate sustainably and conscious of the environmental impact.

Adherence & Violations

Suppliers must immediately notify Arena in writing upon becoming aware of any negative or other adverse publicity concerning the Suppliers or any product and services being provided to Arena by the Supplier, or any event or circumstance related to the Supplier that could be expected to cause negative or other adverse publicity concerning Arena. It is the responsibility of each Supplier to ensure that its employees and representatives understand and comply with the Code. Failure to adhere to the Code may be grounds for terminating the Supplier relationship depending on the seriousness of the violation and the circumstances.
Definitions “Arena” means Arena Group and its Affiliates. where “Affiliates” mean any person or party that controls Arena, is controlled by Arena or is under common control with Arena, where “control” means owning, directly or indirectly, more than 50% of the capital stock (or other ownership interest, if not a corporation) of a person or party ordinarily having voting rights or otherwise having the right or ability, by contract or otherwise, to direct the management and policies of such person or party. “The Code” means Arena Suppliers Code of Conduct. “Suppliers” or “Supplier” means current and future vendor(s), supplier(s), contractor(s), consultant(s), agent(s), distribution partners, manufacturers, procurement vendors, and other provider(s) of goods and services.

If you have any questions about the code, you may contact us at legal@arenagroup.com.