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Third Party Code of Conduct

Third Party Code of Conduct

Fewmoretaps OÜ d/b/a Trustname.com (“Trustname”, “we”, “us”) has an ambitious goal — to help build a better Internet. We believe ethical operations and a responsible supply chain are essential to achieving that goal. Trustname is committed to the highest standards of ethics and integrity in everything we do.

This Third Party Code of Conduct (the “Code”) outlines Trustname’s requirements and expectations for our suppliers, resellers, contractors, agents, and other business partners (“Third Parties”). All Third Parties are required to acknowledge and comply with this Code as a condition of doing business with Trustname.

Human Rights

We believe a better Internet is built on human rights, and that human rights should inform how we do business. Trustname is committed to respecting human rights in line with the United Nations Guiding Principles on Business and Human Rights (UNGP).

Third Parties are required to respect human rights by avoiding causing human rights harms and by mitigating and remediating any harms that do occur. Trustname encourages Third Parties to publicly commit to the UNGPs and to periodically report on their implementation.

For more information, see Trustname’s Human Rights Policy.

Labor

Freedom of Association and Collective Bargaining

Trustname supports the principles in the ILO Declaration on Fundamental Principles and Rights at Work. Third Parties should respect and protect the rights of workers to associate freely and to join or not join collective bargaining organizations (such as labor unions and workers’ councils), in accordance with local law and international human rights standards.

Occupational Health and Safety

Third Parties must maintain procedures to minimize workplace hazards and protect workers from chemical, biological, physical, or other risks. Where appropriate, personal protective equipment must be provided. Workers must not be disciplined for raising safety concerns.

Third Parties must comply with all applicable health, safety, quality, and environmental laws and maintain all required permits, licenses, and registrations. Procedures to prevent, manage, track, and report occupational injury and illness must be in place, including providing access to necessary medical treatment and reporting workplace incidents as required.

Child Labor

Third Parties are required to prohibit child labor consistent with the ILO Declaration and applicable law in their operations and supply chains. Trustname encourages participation in industry efforts aimed at eliminating child labor.

Forced Labor and Human Trafficking

Third Parties are required to prohibit forced or compulsory labor, servitude, and human trafficking consistent with the ILO Declaration and applicable law. Trustname encourages participation in efforts aimed at eliminating forced labor and human trafficking.

For more information, see Trustname’s Modern Slavery and Human Trafficking Statement.

Discrimination and Harassment

Trustname expects all workers to be treated with dignity and respect. Third Parties must maintain and enforce clear policies that prohibit harassment and discrimination and provide fair processes for addressing complaints, consistent with applicable law and recognized standards (including the UN Global Compact Ten Principles).

Diversity, Equity, and Inclusion

Third Parties are expected to adopt policies and practices that support diverse, equitable, and inclusive workplaces. Trustname encourages transparency and public reporting on DEI initiatives where appropriate.

Governance

Anti-Bribery and Anti-Corruption

Third Parties must not offer, give, promise, or authorize any bribe, kickback, gift, loan, fee, reward, or other improper advantage to any government official, customer, partner, employee, or any other person to improperly influence an action or decision.

Third Parties must comply with all applicable anti-corruption laws, including (where relevant) the U.K. Bribery Act 2010 and other local anti-bribery laws.

Trade Compliance and Sanctions

Trustname is committed to conducting business in compliance with applicable import/export controls and sanctions laws, including (as applicable) EU, U.K., and U.S. restrictions. Third Parties must ensure that their products and services comply with applicable trade laws and sanctions regulations.

Trustname does not knowingly do business with Third Parties that are subject to applicable sanctions restrictions. Third Parties warrant that they are not owned or controlled by sanctioned persons or entities, where such restrictions apply.

Anti-Competitive Behavior

Third Parties must comply with competition and antitrust laws and must not engage in agreements or coordinated conduct that restrains competition. Third Parties should promote compliance throughout their own supply chains.

Conflicts of Interest

Third Parties must avoid conflicts of interest and must act with objectivity in their dealings with Trustname. If a potential or actual conflict arises that may interfere with a Third Party’s ability to act objectively, the Third Party must disclose all relevant details to Trustname promptly.

Data Privacy

Third Parties must comply with applicable data protection laws (including, where applicable, the GDPR). Third Parties must process Trustname personal data only as necessary to provide contracted services and must not use such data for secondary purposes.

Data Security

Third Parties are expected to implement reasonable administrative, physical, and technical safeguards consistent with recognized information security best practices and industry standards. Third Parties with access to Trustname systems must follow Trustname security requirements, including access controls and credential handling.

Where appropriate, Trustname may require background checks for personnel assigned to Trustname work, consistent with applicable law.

Government Contracting

If Trustname engages in government-related contracting or is subject to contractual flow-down obligations, certain requirements may apply to Third Parties. Third Parties must comply with all applicable flow-down obligations communicated in writing by Trustname.

Environmental Sustainability

Greenhouse Gas Emissions

Third Parties are encouraged to identify, manage, and report greenhouse gas (GHG) emissions using recognized methodologies such as the GHG Protocol, or to commit to working toward those objectives. Trustname encourages Third Parties to set goals to reduce emissions, support renewable energy, and mitigate residual emissions where feasible.

Responsible Sourcing of Materials

Where Third Parties provide hardware or materials, they are expected to exercise due diligence and commit to responsible sourcing, particularly for materials that may originate from high-risk areas associated with human rights abuses, environmental harm, child labor, or forced labor.

Compliance

Third Parties must promptly notify Trustname of any violation of this Code. Trustname reserves the right to conduct reasonable audits or inspections related to credible evidence of non-compliance or in connection with contractual obligations, subject to applicable law and confidentiality commitments.

Trustname may provide reporting channels for Third Parties to raise concerns. Trustname will handle reports as confidentially as reasonably possible, consistent with conducting a fair investigation and complying with applicable law. Trustname prohibits retaliation against good-faith reporting.

Third Parties must immediately report any actual or suspected security incident affecting Trustname data or systems to Trustname’s security contact: [email protected].

A Third Party found in violation of this Code that fails to take corrective action after reasonable notice may jeopardize its business relationship with Trustname, up to and including termination, subject to contract terms and applicable law.

 

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