Code Of Ethics
POMEROY’S MODERN-DAY SLAVERY STATEMENT & TRANSPARENCY IN SUPPLY CHAIN PRACTICES
Pomeroy Technologies, LLC (“Pomeroy”), a USA headquartered company with multi-national subsidiaries and affiliates, is an IT services provider with approximately 2,500 employees performing services in North America and Western Europe.
Our organization is committed to operating with responsible business practices, including, but not limited to how we manage sourcing and overall supply chain management. We recognize that slavery and human trafficking continue to pose a threat to the human rights of global citizens and this statement is intended to affirm our steadfast pledge to prevent and mitigate the risk of human trafficking or slavery in our business operations and supply chain.
Pomeroy condemns human rights abuses, including child labor, forced labor and slave labor. Pomeroy has taken the following steps to combat modern slavery and human trafficking from supply chains, which is in line with the obligations created under the UK Modern Slavery Act of 2015 and California’s Transparency in Supply Chains Act.
OUR POLICIES AND CONTROLS
Pomeroy’s Code of Conduct and Code of Ethics expressly set forth the company’s expectation that our business will be conducted with integrity and in keeping with moral, ethical, and legal standards. Our employees and suppliers are required to acknowledge such responsibilities and conform with those obligations while engaging in business operations with, for, or on behalf of Pomeroy in their capacity as an employee or supply chain partner.
In addition to these written policy statements and standards, Pomeroy has engaged an independent third party to host a 24×7 HOTLINE for purposes of providing individuals with an avenue to report any compliance issues or concerns on-line or via telephone while maintaining anonymity, if so desired. The HOTLINE allows for the global reporting of any alleged financial improprieties, and can also be utilized to make complaints regarding any ethical, moral or legal facts or circumstances giving rise to potential human rights violations or improper labor conditions. Complaints made to the HOTLINE are subject to a thorough and equitable investigation and the company takes whatever responsive actions it deems reasonable and/or necessary to ensure that the company’s operations are in keeping with its stated moral, ethical and legal standards.
Pomeroy employees and members of management who have direct responsibility for supply chain management are required to complete training on human trafficking and slavery, particularly with respect to mitigating risks within the supply chains of products.
Pomeroy is also a business participant in the United Nations Global Compact. Inasmuch as our organizational strategies and operations are aligned with the Ten Principles of the UN Global Compact, Pomeroy is committed to demonstrating its support for and furtherance of these universal principles on human rights, labor, environment and anti-corruption, while also operating in a manner that advances the important societal goals stated by the UN Global Compact. It is particularly important to Pomeroy to incorporate the following principles on human rights and labor into its business operations in all respects:
Principle 1: Business should support and respect the protection of internationally proclaimed human rights; and, Principle 2: make sure that they are not complicit in human rights abuses.
Labor. Principle 3: Businesses should uphold the freedom of association and the effective recognition of the right to collective bargaining; Principle 4: the elimination of all forms of forced and compulsory labor; Principle 5: the effective abolition of child labor; and, Principle 6: the elimination of discrimination in respect of employment and occupation.
DUE DILIGENCE PROCESSES
Pomeroy independently evaluates the reputation of suppliers in the marketplace and assesses their business practices before engaging in a supply chain relationship with such parties. Incident to the establishment of a supply chain relationship, Pomeroy requires suppliers to expressly agree to our standard terms and conditions, which requires all suppliers to comply with all labor laws in the jurisdictions where supplier maintains business operations around the globe. A violation of such terms and conditions may result in the immediate termination of a supplier engagement or relationship.
As we expand our business operations and work with suppliers domestically and internationally to meet the needs of customers, Pomeroy will remain vigilant to protect and preserve human rights and eliminate unfair, unethical, and illegal labor conditions or practices.
Pomeroy maintains written policy statements and standards, makes public pronouncements regarding the company’s condemnation of human rights abuses, including child labor, forced labor and slave labor, and provides individuals or entities with the ability to anonymously report any issues, concerns, claims or complaints about potential compliance matters. Pomeroy monitors evolving domestic and global standards, as well as legal and regulatory changes, and stands ready to modify its internal and external operating practices accordingly. Likewise, Pomeroy engages in routine and ongoing review of its supply chain partners to affirm that the suppliers we transact business with around the world are in good standing as it relates to human rights and labor conditions. In the event a supplier’s capacity to operate in compliance with Pomeroy’s stated standards above is the subject of special review, Pomeroy reserves the right to temporarily stay all transactions with the supplier pending a determination on the matter(s) or terminate the relationship and discontinue all transactions. If Pomeroy has reason to believe that any supplier is engaging in illegal activities, which violate human rights or work condition requirements in the applicable jurisdiction, Pomeroy may report same to local law enforcement or the governing legal/regulatory agency for further review and investigation.
ASSESSMENT OF EFFECTIVENESS
Pomeroy undertakes the independent review of its policies, procedures and supplier relationships on an annual basis, or more frequently if or as deemed necessary or appropriate. The purpose of such review process is to ensure that policy updates are made in a timely manner, and the company is able to verify or confirm the absence of any known issues that constitute unmitigated human rights violations or the perpetuation of work conditions that are unsafe or likely to cause harm to others as the result of the use of forced labor, slave labor or child labor. If or as issues may be suspected or otherwise detected, Pomeroy resolves to accentuate and implement more advanced operating standards and more effective risk mitigation/management practices in conformance with the expectations set forth under the UK Modern Slavery Act of 2015 and the requirements set forth in California’s Transparency in Supply Chains Act.