Vendor Code of Conduct
Personify Health
Vendor Code of Conduct
Last updated November 8, 2024
WHO IS PERSONIFY HEALTH?
Personify Health, Inc., is a software and healthcare administration company that
provides a personalized health platform aimed at optimizing business healthcare
investments and empowering people to engage with their health.
WHO DOES THIS CODE APPLY TO?
Personify Health is committed to respecting people and supporting universal human
rights, adhering to local laws and regulations, contributing positively to our
communities, and minimizing our impact on the environment. This Vendor Code of
Conduct (“Code”) applies to any entity (“Vendor”) that (1) contracts with Personify Health
to provide goods or services to Personify Health, (2) provides services on behalf of
Personify Health, or (3) participates in our platform partner programs.
BUSINESS ETHICS
Personify Health expects Vendor to conduct all its business in an ethical and fair
manner. This includes but is not limited to the following:
Conflicts of Interest
Personify Health is committed to conducting all business and operations with the
utmost integrity and high standards of behavior so that no conflict of interest
Confidentialexists or can be reasonably implied or construed to exist. A conflict of
interest is any personal or financial interest, any business or personal activity or
relationship, prior or current employment, or any obligation that may interfere
with the ability to objectively perform job duties and responsibilities or impair
independence and objectivity. Vendor must disclose any actual or potential
conflict of interest related to its activities with Personify Health to the Personify
Health compliance department.
Bribes, Kickbacks, and Other Improper Payments
Vendor shall comply with all applicable national and international anti-corruption
laws and regulations, including the United States Foreign Corrupt Practices Act of
1977, the United Kingdom Bribery Act 2010, and all other applicable anti-bribery
or anti-corruption laws and regulations at a local level. Vendor shall not (neither
directly nor indirectly) offer, provide, or accept anything of value to improperly
influence an official act or to secure an improper advantage to obtain or retain
business. This includes facilitation payments or other benefits provided to public
officials for routine non-discretionary actions.
Entertainment and Gifts
We believe in fair competition among Vendors for Personify Health’s business
and that sound business decisions are based on objective criteria. To ensure that
fair competition and objectivity are maintained, Personify Health prohibits its
employees from accepting material gifts from outside business associates or
from participating in lavish meals or other entertainment paid for by Vendor.
Employees cannot accept any gifts, meals, or entertainment, regardless of value,
from Vendors that are actively engaged in contract negotiation with Personify
Health. Similarly, Personify Health employees may not give gifts to Vendors in a
way that might influence the nature of the relationship between Personify Health
and the Vendor.
Money Laundering and Financial Records
Vendor shall comply with applicable laws and regulations designed to combat
money laundering activities. Vendor shall maintain financial records and reports
according to applicable laws and regulations.
Antitrust
Vendor shall comply with applicable competition and anti-trust laws, which are
designed to prevent one business from gaining an unfair advantage and forcing
other businesses out of the marketplace, such as price fixing, market allocation,
group boycotts, price discrimination, or monopolization.
Trade Regulations and Sanctions
Vendor shall comply with all applicable export control, sanctions and customs
laws, regulations, and trade laws. Vendor must notify Personify Health if it is
listed on, or added to, any US or international sanctions lists. Vendor must
cooperate with Personify Health to avoid violating any international sanctions.
DATA PROTECTION AND INFORMATION SECURITY
When handling or processing personal data of any sort, it is important for Vendor to
protect the confidentiality, integrity, and availability of the personal data. Vendor must
adhere to applicable data protection laws, including security of personal data, as well as
to respective regulation regarding personal data of Personify Health members, clients,
employees, and stakeholders.
At all times the required level of information security and control to be ensured by
Vendor must be commensurate with the sensitivity, value, and criticality of the
information being processed throughout the lifecycle of the information. Vendor must
notify Personify Health of any security incident that compromises the confidentiality
integrity or availability of personal data. Vendor can send notices to
HUMAN RIGHTS AND FAIR LABOR PRACTICES
Vendor must operate in a fashion that supports human rights and adheres to fair labor
practices at all of its locations worldwide. This includes but is not limited to the
following topics.
Human Trafficking and Modern Slavery
As part of our commitment to eradicating human trafficking and modern slavery,
Personify Health is committed to ensuring that there is no modern slavery or
human trafficking within its supply chain as described in our Anti-Modern Slavery
Statement located here: https://personifyhealth.com/legal/modern-slavery-statement
Vendor must comply with applicable international and US federal, state, and local
laws and regulations.
Child Labor
Vendor shall not employ individuals who are (1) under the legal age of
employment in any country or local jurisdiction, or (2) under the minimum age
established for developing countries by the International Labour Organization,
whichever is higher. See https://www.ilo.org/global/standards/subjects-covered-
by-international-labour-standards/child-labour/lang–en/index.htm.
Forced Labor
Vendor shall not use any form of forced, bonded, compulsory labor, or modern
forms of slavery. 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). Vendor shall ensure that
workers do not pay fees or make any payment connected to obtaining
employment throughout the hiring process and the employment period.
Punishment, mental and/or physical coercion as well as any other form of human
trafficking is prohibited. Disciplinary policies and procedures shall be clearly
defined and communicated to the workers.
Compensation and Working Hours
Vendor shall comply with all applicable local laws and mandatory industry
standards regarding working hours, including overtime, rest breaks, and paid
vacation. Vendor shall compensate its workers in accordance with local minimum
wage legislation and terms of applicable collective bargaining agreements as well
as with industry standards.
Freedom of Association and Collective Bargaining
Vendor shall recognize and respect the right to collective bargaining in
accordance with applicable local laws.
Diversity and Inclusion
Vendor shall promote an inclusive work environment that values the diversity of
its employees. Vendor must not discriminate in employment, including hiring,
compensation, advancement, discipline, termination, or retirement, on the
grounds of race, caste, gender, gender identity, sexual orientation, color, national
origin, age, mental or physical disability, health conditions or diseases,
pregnancy, religion, union membership, marital status, veteran status, or political
affiliation.
SAFE AND HEALTHY WORK ENVIRONMENTS
Safety is a priority for Personify Health, and we expect it from our Vendors.
Personify Health requires that the conditions within which the employees of our
Vendors are working align with applicable US and international standards. The care of
the local environment through waste management and similar initiatives sufficiently
conforms with US and internationally recognized standards.
SUSTAINABILITY
Protecting the environment is an ongoing commitment. Vendor must comply with all
applicable national, state, and local laws and regulations in their country of operation
and meet or exceed international standards for environmental protection. Vendor of
manufactured goods to Personify Health must maintain supply chain records and make
them available as required. Records must include material sources and any
environmental certifications as applicable.
REPORTING CONCERNS TO PERSONIFY HEALTH
Vendors are encouraged to report to Personify Health any questions, concerns, or
potential violations of this Vendor Code of Conduct.
