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Wiiisdom
Supplier Code of Ethics

1. Introduction

1.1 Scope of the Policy

WIIISDOM is committed to acting as a “responsible corporate citizen”. WIIISDOM conducts its business according to strict ethical, social, and environmental standards. As such, WIIISDOM requires the same level of compliance from its partners.

WIIISDOM, therefore, expects all its suppliers, agents, subcontractors, business partners, affiliates, directors, officers, and employees (hereinafter the “Suppliers”), to comply with this Supplier Code of Ethics. 

Suppliers must ensure compliance with all local laws and regulations of the countries in which they operate, including, but not limited to, anti-corruption, health and safety, human rights, anti-human trafficking and modern slavery, data protection, international trade, anti-compliance, competition, and environmental protection. 

We base our conduct on alignment with the UN’s 17 Sustainable Development Goals (SDGs) and the Universal Declaration of Human Rights, seeking a better and fairer world for all. We expect our suppliers to also adhere to, respect and ensure compliance with good practices in their companies.

Any breach of conduct or any violation of this code of conduct by our suppliers or their subcontractors will result in a review and possible termination of the business relationship.

 

2. Human Rights And Working Conditions

2.1 Respect for human rights and privacy

At Wiiisdom we do not tolerate human rights abuses, and we will not engage in or be complicit in any activity that solicits or encourages human rights abuses.

We expect that our suppliers fully comply with all employment laws and respect the human rights and privacy of every individual. They shall treat people with respect and dignity, promote diversity and equal opportunities, and create a culture of inclusion, personal commitment, and ethical principles.

2.2. Child labor, human trafficking, and forced labour

Wiiisdom does not agree with child labor. Child labor refers to the exploitation of children through any form of work that deprives children of their childhood, interferes with their ability to attend regular school, and is mentally, physically, socially, and morally harmful.

Suppliers must not use child labor under any circumstances.

Suppliers shall not recruit, transport, transfer, or receive persons for the purpose of exploitation by force, deception, or coercion. They are also prohibited from using or offering labour or services illegally, including through the trafficking of illegal workers. 

Suppliers undertake not to be involved, directly or indirectly, in situations that result in a violation of fundamental human rights or any deprivation of a person’s liberty by another person in order to exploit them for personal or commercial purposes.  

All employees of the Suppliers shall be free to accept employment voluntarily and to leave their employment in accordance with applicable laws.

2.3. Work conditions

Suppliers shall endeavor to ensure their employees’ health, safety, and welfare in the workplace, in accordance with all applicable occupational health and safety laws and regulations. 

Suppliers respect the dignity of every individual and do not tolerate any form of physical, psychological, or verbal harassment or any other abusive behavior in the workplace. 

Suppliers shall ensure that their business practices respect the rights of different demographic groups, including women, and migrant workers. Suppliers shall not engage in harassment or discrimination in employment based on age, ancestry, citizenship, colour, family or medical leave, gender identity or expression, immigration status, marital or family status, medical condition, physical or mental disability, political affiliation, union membership, race, religion, sex (including pregnancy), sexual orientation, or any other characteristic protected by applicable local laws, regulations, and ordinances.

Suppliers shall comply with the legal provisions applicable to employee remuneration and working hours in the countries where they operate.

 

3. Business Ethics

Wiiisdom has a zero tolerance policy towards all forms of bribery and corruption.

Because the Anti-Bribery is a criminal statute and the penalties which may be imposed upon Wiiisdom and our personnel are severe, we take our obligation under the Anti-Bribery and local laws seriously and request that you also consider this matter very carefully and deliberately. If there is an ownership interest in your company by any government official, we must be advised.

3.1. Anti-corruption laws

Suppliers shall apply a strict policy on bribery or influence peddling. Suppliers shall not directly or indirectly give, offer, promise or demand money or anything of value to a public official or employee of a private company in order to exert undue influence or obtain an undue advantage. 

Suppliers are required to take reasonable care to detect and prevent bribery, influence peddling, kickbacks, and other forms of public or commercial corruption in their business arrangements.

3.2. Gifts and invitations

It is forbidden to offer or accept gifts or invitations in order to gain an improper competitive advantage.

Suppliers must ensure that they are permitted by law and regulation to offer or accept gifts, entertainment, or invitations. These must always be legitimate and of reasonable value. 

In no case may they be offered or accepted with the aim of influencing the beneficiary, nor may they be contrary to the rules and principles laid down by the organization to which the beneficiary belongs. They must be in line with current market practices and customs. 

Wiiisdom employees must declare any received or given gifts. Each declaration is received and reviewed directly by the Wiiisdom Office of Ethics and Compliance.

3.3. Economic crime and money laundering

Suppliers do not directly or indirectly engage in money laundering, terrorist financing activities, tax evasion or fraud, or in conduct that violates anti-money laundering laws by accepting, transferring, converting, or concealing money obtained from criminal activities or related to terrorist financing.

3.4. Competition

Suppliers shall comply with all applicable competition laws and regulations and shall endeavor to compete fairly.

In this respect, Suppliers shall refrain from any practice consisting in: 

  • exchanging non-public data and information concerning prices, customers, marketing, personal data (including customers or prospects contact data), or any other commercially sensitive information;
  • agreeing on prices with their competitors;
  • engaging in illegal cartels in public procurement;
  • allocating customers or territories.

3.5. Conflict of interest

Within the framework of their commercial relations with WIIISDOM, Suppliers are required to avoid all conflicts of interest in any form whatsoever and all situations that may give the appearance of a conflict of interest.

Suppliers are responsible for using good judgment to objectively evaluate their activities that may result in a conflict of interest and for bringing any potential conflict situations to the attention of their managers so they can provide appropriate guidance.

 

4. Confidential Information, Personal Data, and Subcontracting

Suppliers are required to protect sensitive information and data, including those belonging to WIIISDOM, especially when it consists in confidential information and data or of a personal nature. Suppliers are prohibited from using such information and data outside the framework of the commercial agreements that bind them to their customers, including WIIISDOM without having obtained the prior written approval of said customers or any other person concerned. 

Suppliers are also required to comply with all laws and regulations relating to the protection of personal data, including the General Data Protection Regulation (GDPR) where any personal information is collected, stored, processed, transmitted, or shared by the Supplier and shall take appropriate measures to keep the data confidential and protected from unauthorized access, destruction, use, modification, and disclosure, through adequate organizational and technical measures.

When Suppliers use subcontractors to develop, manufacture or provide products or services to WIIISDOM, each supplier undertakes to ensure the application of the rules of this code of ethics and the protection of personal data by each subcontractor. If a violation of the present code of ethics is committed by a subcontractor of the supplier, this last one will assume, with respect to WIIISDOM, the entirety of the responsibilities engendered by this violation.

As part of the services rendered to WIIISDOM, each supplier agrees not to attempt to mitigate the damages and penalties it would have to pay to WIIISDOM or any data subject in the event of a violation by such supplier of any applicable law relating to personal data protection.

 

5. Intellectual Property

Suppliers are required to comply with applicable intellectual property law. They are prohibited from infringing on the intellectual property rights held by a third party in the development, manufacture, or supply of products or services for WIIISDOM. They must strictly comply with the law and not provide counterfeit products.

 

6. Environmental Protection

At Wiiisdom we are committed to our social responsibility to promote environmental sustainability and protect the environment. We expect our suppliers to also embrace our commitment and do their part in protecting the world by reducing their ecological footprint.

Suppliers shall comply with all applicable environmental laws and regulations. They shall respect their environment and limit the impact of their activities on the environment as much as possible. 

Suppliers shall encourage energy efficiency and give preference to renewable energy. They shall strive to protect natural resources by finding innovative ways to reduce the use of energy, water, land, and materials.

Suppliers must make concrete efforts to eliminate or reduce the levels of waste generated. When waste cannot be eliminated, Suppliers shall ensure that the correct disposal process is applicable with respect to the environment, local laws, and the safety of the surrounding community.

 

7. Reporting Questionable Behavior

To report questionable behavior or a possible violation of this Code, suppliers are encouraged to work with their primary Wiiisdom contact in resolving their concerns. 

If that is not possible or appropriate, please contact Wiiisdom at legal@wiiisdom.com.

Wiiisdom will maintain confidentiality to the extent possible and will not tolerate any retaliation taken against any individual who, in good faith, has sought advice to report questionable conduct.