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Supplier Code of Business Conduct and Ethics

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Vapor IO, Inc. Code of Business Conduct and Ethics

Vapor IO, Inc. (“Vapor”) is committed to maintaining the highest ethical and business standards and to upholding all applicable laws and regulations related to our business practices. This Code of Business Conduct and Ethics (“Code”) sets forth Vapor’s commitments to ethical business practices and the expectations Vapor has for its suppliers, vendors, contractors, consultants, and other third-party providers of goods and services (collectively “Suppliers”). This Code is not intended to replace, revise or override any existing contractual requirements between Vapor and a Supplier.

If Vapor believes that any Supplier has violated this Code, Vapor has the right to terminate its business relationship with the Supplier and proceed to secure any and all other rights and remedies available to it under applicable law and/or the agreement between the parties. Vapor reserves the right to reasonably change the requirements of the Code. By continuing to provide services to Vapor after such changes have been posted, Suppliers shall be deemed to have accepted such changes.

Compliance with Applicable Law

  • Suppliers must conduct business in compliance with applicable laws and regulations, including as they relate to import, export and trade controls, anti-corruption and bribery, employment, health and safety, data protection and information security.
  • It is Vapor’s policy to fully comply with both the letter and spirit of the Foreign Corrupt Practices Act (“FCPA”) and other applicable international anti-corruption laws.
  • Suppliers shall abide by all applicable fair competition, deceptive trade practices, and antitrust laws and be accurate and truthful in their discussions with Vapor and in preparation of any documentation for Vapor or its representatives or customers.
  • Where Vapor has a higher standard in this Code than applicable law, Vapor expects its Suppliers to comply with the higher standard.
  • Vapor expects Suppliers to immediately report any potential or suspected violations of the law or this Code.

Business Conduct and Ethics

  • Vapor expects its Suppliers to conduct their business in an ethical, honest, and professional manner that does not adversely affect Vapor’s integrity, reputation, or credibility, and to take responsibility for their actions.
  • Suppliers must not tolerate, permit, or engage in bribery, corruption, fraud, or unethical practices, whether in dealings with public officials or individuals in the private sectors, and shall avoid engaging in any activity which could be deemed a corrupt and/or unethical practice.
  • Suppliers are prohibited from giving, receiving, offering, promising, authorizing, directing, or making any bribes, kickbacks or payments of money or anything of value, to or from any public or private officials for the purpose of obtaining or retaining business for the benefit of Vapor or using their position, power, or authority to obtain or give improper benefit or advantage.
  • Vapor does not allow facilitation or “grease” payments to be made, even if they are legal or culturally acceptable in some countries.
  • Other than nominal value marketing items bearing trademark or logo of business partners (for example, pens, cups, mousepads, USB drives), Vapor employees may not accept gifts or courtesies from vendors seeking Vapor’s business.  In no event may a gift, gratuity, entertainment, or expense payment be intended to influence a business decision, transaction or service or to obtain or retain business or gain improper advantage.
  • Suppliers must provide prompt notification to all affected parties in the event an actual or potential conflict of interest arises, such as through a personal relationship or financial interest, or other means by which a person’s private interest interferes in any way, or even appears to interfere, with the interests of the company.
  • Suppliers should ensure that their officers, employees, and other representatives comply with insider trading laws and regulations and refrain from using confidential information obtained in the course of their business relationships as the basis for trading or for enabling others to trade in the securities of a company.
  • Suppliers must always act in good faith in dealing with Vapor and its customers, by representing their products, services and capabilities accurately, by making competitive comparisons fairly, and by promising only what they can deliver legally and ethically.

Human Rights

  • Suppliers are expected to share Vapor’s commitment to human rights by treating all people with respect and dignity. This includes, at a minimum, complying with all applicable employment laws and regulations, including, but not limited to, those laws that relate to discrimination, harassment, working time, overtime, minimum wage, modern slavery, and workplace safety.
  • Vapor is committed to a safe and positive work environment for its employees and customers. Any form of discrimination, harassment, abuse or other unwelcome behavior aimed at an individual based on race, ancestry, color, religion, politics, military service, sex, gender, sexual orientation, marital or family status, pregnancy, age, national or ethnic origin, disability, genetic information or any other category protected by law, is strictly prohibited.
  • All work performed for Supplier must be voluntary. Workers must be free to resign their employment in accordance with local and national laws or regulations without penalty. Vapor does not tolerate the use of any form of forced or involuntary labor of any type, including any form of human trafficking, slavery, indentured servitude, or involuntary labor through threat, force, fraudulent claims, or other coercive means.
  • Suppliers must pay at least the minimum wage and comply with all applicable requirements on wages and benefits set forth by law, regulation or contract, including, but not limited to, those relating to overtime hours, maximum work hours. Suppliers must not require its employees to work more than the regular and overtime permitted by the country where the worker is employed.
  • The use of child labor is prohibited. Suppliers must not employ any person under the relevant minimum age for employment as defined by applicable law and any workers under the age of 18 may not perform work that is likely to jeopardize their health or safety. Suppliers must have hiring practices that accurately verify age and ability to work legally in the country of employment.
  • Suppliers should respect the right of free association of employees to join employee organizations or trade unions and/or engage in collective bargaining, as permitted under applicable laws.

Health and Safety

  • Vapor expects all Suppliers to provide a safe and healthy working environment and ensure all business operations are carried out in compliance with all applicable health, safety and environmental legislation and regulations within the countries and industries they operate.
  • Suppliers shall implement reasonable and effective occupational health and safety measures designed to prevent accidents and injury linked with, arising out of, in the course of work or as a result of the operation of Supplier facilities or services.
  • Suppliers shall provide all workers with appropriate workplace health and safety information and training, as well as protective equipment as needed.
  • Suppliers should have a procedure in place within their management system to measure and regularly assess the effectiveness of their current policies and procedures regarding health, safety and environmental obligations (set forth below).

Environmental Impact ​

  • Vapor is committed to social and environmental responsibility in our internal business activities as well as within our supply chain and asks our Suppliers to help us use resources efficiently.
  • Suppliers shall comply with all national and local environmental laws applicable to air emissions, waste handling and disposal, water use, wastewater and solid waste discharges, and hazardous and toxic substances.
  • Suppliers must manage and dispose of all materials in an environmentally responsible and secure manner that is protective of human health and the environment.
  • Suppliers shall validate and maintain records demonstrating that source materials were harvested in accordance with all international treaties in addition to national and local laws and shall not use “conflict minerals” as defined by applicable law.
  • Suppliers must obtain, maintain, and make available all required environmental permits and registrations.

Confidentiality and Data Protection

  • All Suppliers and their representatives are expected to maintain the confidentiality of information entrusted to them by Vapor or its customers. Suppliers must comply with all applicable confidentiality and use restrictions and use reasonable and appropriate measures to ensure the integrity and security of Vapor’s trade secrets and other proprietary and/or non-public information.
  • Suppliers must respect and protect Vapor’s intellectual property rights and those of others and use such intellectual property only in accordance with valid licenses, terms of use, or other relevant contractual provisions.
  • Suppliers must comply with all applicable laws regarding privacy and data protection and regulatory requirements where personal information of any kind is collected, disclosed, processed, stored, or transmitted, including where applicable, the General Data Protection Regulation (“GDPR”) and California Consumer Privacy Act (“CCPA”).
  • When transmitting personally identifiable information across international borders, and before collecting, storing, using, processing, transmitting or disclosing any of Vapor’s or its customers’ personal information, Suppliers must confirm that proper authorization has been obtained and implement reasonable and appropriate confidentiality and data protection measures to secure such personal information against unauthorized access or use.

Internal Controls and Business Records​

  • Vapor expects its Suppliers to have effective management systems implemented in all areas of operation to ensure compliance with applicable laws, this Code and its own internal standards and accounting obligations.
  • Suppliers shall self-monitor and maintain records necessary to demonstrate their compliance with applicable law and this Code, notifying Vapor promptly of any non-compliance and making records available for inspection during normal business hours upon reasonable notice.
  • Suppliers must ensure any authorized subcontractors it engages also comply with this Code and shall be responsible for any violations by such subcontractors.
  • Suppliers must maintain integrity, transparency and accuracy in all records of matters relating to their business with Vapor.

Reporting Concerns​

  • If you become aware of any issue or practice involving a potential or actual violation of this Code or any Vapor policy or applicable law or regulation, please report the matter immediately to Vapor’s General Counsel at legal@vapor.io or, if you wish your report to be anonymous, you may call Vapor’s compliance hotline at 844-280-0005 or report via the web at www.lighthouse-services.com/vapor.  Any violations can be reported confidentially.
  • Suppliers may not engage in retaliation against any workers who report concerns and shall create programs to ensure the protection of worker whistleblower confidentiality and prohibit retaliation against workers who participate in such programs in good faith or refuse an order that is in violation of this Code or applicable law.

Vapor IO, Inc.​

6200 Bridgepoint Parkway, Building Four,
Ste. 250, Austin, TX 78730
1-888-477-6660

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