OPTIMIZELY SUPPLIER CODE OF CONDUCT

Optimizely is committed to a high standard of ethical conduct and social and environmental responsibility. Optimizely expects its suppliers and their employees, personnel, agents, subcontractors, and sub-tier suppliers (collectively, “Supplier”) to aspire to these same standards. Accordingly, Optimizely has created this Supplier Code of Conduct (“SCoC”), which sets out the standards expected of any Supplier doing business with Optimizely.

This SCoC is drawn from industry codes of conduct, the International Labor Organization Conventions, the Universal Declaration of Human Rights, the UN Guiding Principles on Business and Human Rights, and applicable laws.

LABOR AND HUMAN RIGHTS

Optimizely is committed to upholding the human rights of workers and treating them with dignity and respect. This applies to all workers, including temporary, migrant, student, contract, direct employee, and any other type of worker. As a result, Supplier must manage their own workforce in order to achieve the following results:

Dignity and Respect

Supplier must uphold the human rights of workers and treat them with dignity and respect. This applies to all workers, including without limitation, temporary, migrant, student, and juvenile contract, and dispatch workers, as well as direct employees.

Forced Labor

Supplier will not use forced, bonded (including debt bondage), indentured, or involuntary prison labor, and will not engage in slavery or trafficking of any person. Supplier will ensure that workers have access to their personal documentation (e.g., government-issued identification, passports, or work permits), and will pay any agency recruitment/employment fees and expenses.

Child Labor

All workers shall be at least the local minimum legal working age. The facility must take all necessary precautions to ensure that authorized young workers are protected from working conditions that could pose a danger to their health, safety, or development.

Discrimination

Workers must be selected only on the basis of their ability to do the job. Supplier must not discriminate in employment, including hiring, compensation, advancement, termination, or discipline, on the basis of sex, gender identity, race, religion or belief, age, disability, illness, sexual orientation, pregnancy, marital status, civil partnership, nationality, political opinion, social or ethnic origin, or other protected status. All workers, regardless of gender, shall receive equal pay for work of equal value.

Harassment or Abuse

Workers must be treated with respect and dignity. No worker shall be subject to humiliating or corporal punishment, and the workplace must be free from all forms of physical, sexual, psychological, or verbal punishment, coercion, intimidation, harassment, or abuse.

Wages & Benefits

Supplier will comply with all applicable wages and benefits laws, including those relating to minimum wages, overtime hours, and legally mandated benefits.

Working Hours

Supplier will comply with applicable work hours and overtime laws, set the maximum at 60 hours/week (or lower if local law requires), including overtime, except in emergencies, and guarantee at least one full day off every 7 days.

HEALTH & SAFETY IN THE WORKPLACE

Supplier will integrate the following health and safety management requirements into business processes to provide workers with a healthy and safe work environment:

Health & Safety

Supplier must provide a clean, safe, and healthy work environment and take steps to prevent accidents, illness, and injury arising out of or occurring during the course of work. Workers must always have access to sanitary facilities, which should be adequate and clean. Workers must be provided at no cost with all the appropriate personal protective equipment. Where dormitories and canteens are provided to workers, the same standards apply.

Emergency Preparedness

Supplier will implement emergency plans and procedures, including emergency reporting, employee notification and evacuation procedures, worker training and drills, appropriate fire detection and suppression equipment, adequate means of egress, and recovery plans.

ENVIRONMENTAL

Optimizely recognizes that environmental responsibility is integral to producing world-class products. Supplier will strive to integrate the following environmental requirements into business processes:

Environmental Permits and Reporting

Supplier will obtain and keep current all required environmental permits, approvals, and registrations, and follow their operational and reporting requirements.

Pollution Prevention and Resource Reduction

Throughout their operations, Supplier will work to reduce consumption of resources, including raw materials, energy, and water. Supplier will track, document, and seek to minimize energy consumption and greenhouse gas emissions, and seek ways to improve energy efficiency and use cleaner sources of energy.

Hazardous Substances

Supplier will identify and manage chemicals and other materials that pose a hazard to the environment, to ensure their safe handling, use, storage, and disposal. Supplier will identify, monitor, control, treat, and reduce hazardous emissions, wastewater, and waste generated from its operations.

Waste Management

Supplier will work to reduce or eliminate waste of all types. Where waste cannot be eliminated, Supplier will manage and control all waste streams to comply with applicable laws and regulations, and in an environmentally responsible and secure way.

ETHICS AND COMPLIANCE

Supplier will uphold the highest standards of ethics to promote honesty and integrity in business operations, including:

Business Integrity

Supplier will avoid even the appearance of conflicts of interest in their work with us, and will immediately disclose any known family or other close personal relationships with our employees who have an influence over their engagements with us. If Supplier extends any business courtesies to our employees, they will do so infrequently, and the courtesies must be of no more than moderate value. Supplier will also accurately reflect their business dealings in their books and records. Supplier will not offer or accept any form of bribery, corruption, extortion, or embezzlement. Supplier will not make illegal payments directly or indirectly. Supplier will implement monitoring and enforcement procedures to ensure compliance with anti-corruption laws.

Conflicts of Interest

Supplier must not directly engage with any Optimizely employee whose spouse, domestic partner, relative, or other family member is employed by or holds a significant financial interest in the Supplier. 

Gifts

Supplier will avoid gifts to any Optimizely employee when the circumstances create or appear to create a conflict of interest. 

Fair Business, Advertising & Competition

Supplier will obey applicable laws and uphold industry and regulatory standards of fair business, advertising, and competition.

Training and Communication

Supplier must implement training and communication programs to educate its employees regarding the requirements of this SCoC. Supplier must maintain a process for communicating clear and accurate information about its policies to its workers and customers.

Next-Tier Suppliers

Supplier must require an equivalent Code of Conduct of their next-tier suppliers and have a program to assess compliance.

Whistleblower Protection

Supplier will provide an anonymous complaint mechanism for its employees to report possible violations of this SCoC and Supplier’s own code of conduct. Supplier will protect whistleblower confidentiality and prohibit retaliation.

Responsible Materials Sourcing

Supplier will adopt and maintain a policy and exercise due diligence on the source and chain of custody of metals and minerals included in the Supplier’s supply chain to reasonably assure that they are sourced in a way consistent with the OECD Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas or an equivalent and recognized due diligence framework.

Reporting Questionable Conduct

Supplier should report possible violations of the SCoC or other questionable behavior. Report by email at integrity@optimizely.com.

PROTECTING INFORMATION

Supplier must respect intellectual property rights, protect confidential information, comply with security standards, policies, and controls, and comply with privacy rules and regulations. Without limitation, Supplier must meet the following requirements:

Disclosure of Information

Supplier will disclose information regarding business activities and structure, financial situation, and performance in accordance with applicable law and prevailing industry practices. Falsifying records and misrepresenting conditions or practices are prohibited.

Intellectual property

Intellectual property rights are to be respected, transfer of technology and know-how is to be done in a manner that protects intellectual property rights, and customer and Supplier information is to be safeguarded.

Security

Supplier must maintain a security program that implements industry standard controls for assessing risk, protecting customer data with adequate controls, and assuring continued delivery of services. Supplier must report any potential incident involving Optimizely customer data (internally or through a partner or Supplier) as soon as possible.

Privacy

Supplier will (i) comply with all local privacy and data protection laws; (ii) have appropriate processes and practices to secure and protect Personal data; (iii) use personal data only as agreed to by Optimizely representatives or Optimizely’s customers; and (iv) cooperate with Optimizely compliance efforts.

ASSESSMENTS

Supplier will periodically evaluate its operations and those of its subsidiaries, affiliates, and subcontractors to ensure compliance with this SCoC. Supplier will allow Optimizely or an Optimizely agent to conduct an onsite assessment of any operations providing goods or services for Optimizely or Optimizely’s benefit. Supplier will commit to timely correcting any deficiencies identified by an assessment, inspection, or other review.

Any violations of this SCoC may jeopardize a Supplier’s business relationship with Optimizely up to and including termination.

CHANGES TO THE SUPPLIER CODE OF CONDUCT

This SCoC is subject to update by Optimizely from time to time.

Version 2023-08. Published 02 August 2023