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Supplier Code of Conduct Statement

Effective Date: 07/28/2021

Introduction

At Minitab, LLC and all our subsidiaries (“Minitab”), our mission is to serve everyone who practices or teaches data analysis. Our mission is to help people discover valuable insights in their data by delivering exceptional software and unparalleled services. In alignment with our mission, we have developed the Minitab Supplier Code of Conduct (“the Code”) to ensure that all of our suppliers and manufacturers meet our basic expectations of doing business related to legal requirements, ethical practices, human rights, and environmental management.

Compliance with these standards is an expectation of doing business with Minitab, as the Code defines the minimum standards that we ask our suppliers and their sub-tier suppliers or sub- contractors (“the Supplier”), to respect and adhere to. Minitab seeks to develop and strengthen partnerships based on a shared commitment of transparency, collaboration, and mutual respect.

We recognize that our suppliers are independent businesses and the exclusive employers of their workers. However, the actions of our suppliers can be attributed to Minitab, affecting not only our reputation, but the level of trust we have worked hard to earn from partners and customers. While Minitab appreciates that our suppliers operate in a variety of different legal, geographical, and cultural environments we expect all Suppliers to comply with the Code, and hope that our Suppliers will strive to exceed these standards. The standards of this Code are in addition to, and not in lieu of, the provisions of any legal agreement or contract between a supplier and Minitab.

The following seven categories encompass the Minitab Supplier Code of Conduct.

Business Integrity

Minitab is committed to the highest standards of business integrity. We do not tolerate any practice that is inconsistent with the principles of honesty, integrity, and accountability, anywhere we do business.

Requirements

  1. Compliance with Law - Suppliers’ Business activities shall comply with all applicable laws and regulations in the countries and jurisdictions in which they operate.
  2. Bribery - There is a prohibition of any and all forms of bribery, corruption, extortion or embezzlement and there are adequate procedures in place to prevent bribery in all commercial dealings undertaken by the supplier.
  3. Conflicts of Interest - Suppliers will disclose to Minitab any situation that may appear to be a conflict of interest.
  4. Freedom of Association - Suppliers shall respect the rights of workers to associate or not to associate with any group, as permitted by and in accordance with all applicable laws and regulations.
  5. Records - The Supplier shall maintain transparent and up to date books and records to demonstrate compliance with this code and applicable governmental and industry regulations.
  6. Intellectual Property - The Supplier respects the intellectual property rights of others. The Supplier takes appropriate steps to safeguard and maintain confidential and proprietary information or trade secrets of Minitab and uses such information only for the purposes authorized for use by Minitab.
  7. Additional Standards - In addition to this Code, the Supplier is bound to any additional requirements as applicable to the materials or services to be delivered to Minitab.

Human Rights

Minitab expects our Suppliers to conduct their activities in a manner that respects human rights.

Requirements

  1. Voluntary Labor – The Supplier employs all workers on a voluntary basis free from any threat of violence, threats of criminal penalty, and restrictions on freedom of movement. Suppliers shall not use any prison, slave, bonded, forced, indentured, or debt induced labor, or engage in any other forms of compulsory labor, or any other forms of slavery or human trafficking.
  2. Minimum Age - Under no circumstances will the Supplier employ workers under the minimum age for work or mandatory schooling as specified by the local law, whichever is higher. When young workers are employed, they must not do work that is mentally, physically, socially, or morally dangerous or harmful or interferes with their schooling by depriving them of the opportunity to attend school. In the case of hazardous work, the minimum age is 18.
  3. Employment Practices - The Supplier shall only employ workers who are legally authorized to work in their facilities and are responsible for validating workers’ eligibility to work through appropriate documentation.
  4. Migrant Labor - Supplier recognizes the unique legal, social, and cultural situations that migrant workers face and will ensure that such workers are treated with dignity, respect, and in accordance with the same standards as apply to other workers.
  5. Privacy - The Supplier shall respect the privacy rights of its workers whenever it gathers private information or implements worker monitoring practices.
  6. Recruitment & Security - Supplier shall ensure that if third-party recruitment agencies are used, they are compliant with the provisions of this Code and the law. Suppliers recruiting foreign contract workers either directly or through third party agencies shall be responsible for payment of all recruitment-related fees and expenses. When the Supplier retains direct or contracted workers to provide security to safeguard its personnel and property, the Supplier will make sure that security personnel apply the standards in this code.

Fair and Equal Treatment

Minitab believes all workers deserve an equal chance to succeed based on their hard work, talent, and commitment, and should always be treated with respect.

Requirements

  1. Discrimination & Harassment - All workers are treated with respect and dignity. No worker is subject to any physical, sexual, psychological, verbal harassment, abuse or other form of intimidation. There is no discrimination in employment, including hiring, compensation, advancement, discipline, termination or retirement. Discrimination based on caste, national origin, ethnicity, religion, age, disability, gender, marital status, sexual orientation, union membership, political affiliation, health, disability or pregnancy is prevented.
  2. Grievance Mechanism - The Supplier shall provide all workers with transparent, fair, accessible and confidential procedures that result in swift, unbiased and fair resolution of difficulties which may arise as part of their working relationship. Workers will be protected from retaliation for submitting such complaints.
  3. Diversity - Minitab expects its Suppliers to demonstrate a diverse workforce composition actively embracing workforce age, gender, race, national or ethnic origin, religion, language, political beliefs, sexual orientation, physical ability and promoting supply chain inclusion throughout their own supply chains.
  4. EEO/AA Obligations - Minitab, LLC is an equal opportunity employer and federal contractor or subcontractor. As applicable, the parties agree that they shall abide by the requirements of 41 CFR Section 60-1.4(a); 41 CFR Section 60-300.5(a); 41 CFR Section 60-741.5(a); and 29 CFR Part 471, Appendix A to Subpart A with respect to affirmative action program and posting requirements, and that these requirements are incorporated herein. These regulations require that covered prime contractors and subcontractors ensure nondiscrimination and take affirmative action in employment to employ and advance qualified individuals without regard to sex, gender identity, sexual orientation, race, color, religious creed, national origin, physical or mental disability, and protected Veteran status. These regulations also prohibit covered contractors from taking adverse action against applicants or employees because they have inquired about, discussed, or disclosed their or their co-worker’s compensation information in certain situations.

Benefits, Compensation, and Hours

Minitab expects Suppliers to provide workers with fair and equal compensation for hours worked, and that all work is conducted on a voluntary basis.

Requirements

  1. Wages Benefits – The Supplier pays workers on time, in accordance with legal requirements, and in all circumstances, wages must be paid on at least a monthly basis and in the name of the individual performing the work.
  2. Working Time & Rest Days - The Supplier must ensure that its workers work in compliance with all applicable laws and mandatory industry standards pertaining to regular working hours, and overtime hours, including breaks, rest periods, holidays, and maternity and paternity leaves.

Health and Safety

Minitab expects the Suppliers operations, facilities, and procedures to protect and promote worker health and safety.

Requirements

  1. First Aid – The Supplier shall establish and maintain appropriate first aid equipment at the facility and make it available to workers at all times. The location of the equipment shall be prominently marked and communicated to workers. The Supplier shall maintain records of health and safety training, and accidents and injuries at the workplace.
  2. Emergency Preparedness - The Supplier shall be prepared for emergency situations. This includes worker notification and evacuation procedures, emergency training and drills, appropriate first-aid supplies, appropriate fire detection and suppression equipment, and adequate exit facilities. The Supplier shall regularly train workers on emergency planning, and responsiveness.

Environmental Management

Minitab requires its Suppliers to comply with all applicable legal environmental requirements and demonstrate continual improvement of its environmental performance.

Communication and Reporting

Suppliers shall take appropriate steps to ensure the principles of this Code are communicated to their workers. Suppliers shall also take appropriate steps to ensure the principles of this Code are adopted and applied by their workers, suppliers, agents, and contractors.

Requirements

  1. Audits & Assessments - Minitab reserves the right to audit compliance with this Code. Audits are facility inspections that include worker interviews and a review of the Supplier’s records and business practices. Such audits are conducted by Minitab or its appointed partner. If an audit identifies a violation of this Code, Suppliers shall act promptly to correct the situation to Minitab’s satisfaction, with a corrective action plan.
  2. Reporting - Suppliers are responsible for prompt reporting of actual or suspected violations of law, this Code, and any contractual relationship with Minitab. This includes violations by any worker or agent acting on behalf of either the supplier or Minitab. You may report a violation via e-mail at: legal@minitab.com or by phone at 814-238-3280.
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