Alight’s Supplier Code of Conduct

Introduction and Scope

Alight is committed to the highest standards of ethical conduct, integrity, and corporate social responsibility. All suppliers to Alight are expected to conduct their business in accordance with the highest standards of ethical behavior and in accordance with applicable laws and regulations and Alight’s policies on corporate conduct (“Supplier Code”). This Supplier Code applies to all suppliers and each of their vendors, suppliers, subcontractors and agents providing goods, software, or services directly or indirectly to Alight (each a “Supplier”).

Policy Compliance

Alight may assess Supplier’s’ compliance with this Supplier Code, and any violations of this Supplier Code may jeopardize the Supplier’s business relationship with Alight, up to and including termination.

Reporting and the Alight Ethics Helpline

Alight Code of Conduct outlines the ethical standard for Alight employees, officers and directors, contractors, and suppliers as appropriate, and any agents, affiliates, partners or third parties representing Alight. Suppliers are expected to report any suspected wrongdoing. The Alight Ethics Helpline or 1- 844-570-4239 is a convenient and anonymous way for Suppliers to report suspected wrongdoing without fear of retaliation. It is available 24 hours a day, 365 days a year. Alternatively, Appropriate action is taken against those found to have violated applicable law or Alight policy.

Treat people right

Alight believes that all workers within our service delivery and supply chain deserve a fair and ethical workplace. Suppliers shall uphold these standards:

Harassment and discrimination

Suppliers must promote a workplace that is free of discrimination in hiring and other employment practices, and not discriminate based on any protected status or characteristic. Suppliers will provide a work environment free from any form of harassment or discrimination of any kind, including behavior that is disrespectful, abusive or humiliating on the basis of gender, race, ethnicity, religion, sexual orientation, gender identity, national origin, age, disability, pregnancy, veteran status, marital or domestic partner status or any other status protected by law.

Diversity and equal treatment

Alight believes that including diverse partners in our business is important to our success. We expect our suppliers to identify, adopt, and integrate diversity into their own supply processes and hiring, including equal treatment of minority and women-owned businesses in the supplier selection process.

Supplier shall provide equal treatment without regard to any protected status or characteristic in all aspects of Supplier’s employment decisions, including:

Recruitment and hiring
Promotion and performance
Development and training
Benefits and compensation
Termination of employment

Maintaining a safe and healthy workplace

Suppliers shall provide workers with a safe and healthy workplace that complies with all applicable health and safety laws and regulations. Suppliers must take proactive measures to prevent workplace hazards. This commitment to safety also means that Suppliers must never tolerate any threats or acts of violence, including intimidation, bullying, and attempts to instill fear in others.

Human rights and labor concerns

No forced or child labor

Suppliers shall not engage in or permit forced labor, human trafficking or underage labor. Additionally, Supplier must not employ or allow employees under 15 years old or the legally required minimum age, whichever is higher.

Wages

Suppliers shall provide wages and benefits that met or exceed local legal requirements and provide them in a timely manner.

Freedom of association and collective bargaining

Supplier shall respect the rights of its workers to freely choose whether or not to join associations, organizations and trade unions, and to bargain collectively as provided by local law or regulation.

Follow the laws and our policies

Compliance means not only observing the law, but also conducting corporate business in a way that recognizes and fulfills social and ethical responsibilities. In addition to any specific obligations under the Supplier’s agreement with Alight, Supplier shall adhere to the following standards:

Anti-bribery and anti-corruption laws

Alight is committed to compliance with anti-corruption laws in all countries where Alight operates and expects the same of its Suppliers. These laws include the U.S. Foreign Corrupt Practices Act (FCPA), the U.K. Bribery Act, U.S. fraud statutes, state laws and similar international rules. The laws prohibit improper payments, such as bribes and kickbacks, or promises to make improper payments, whether or not the offer is successful. The offering, paying, soliciting or accepting of bribes or kickbacks is strictly prohibited. Supplier shall not make or promise to make an illegal payment or otherwise offer anything of value to any government officials or anyone else for the purpose of securing an improper advantage or to obtain or retain business.

Fair dealing and marketing practices

Alight competes fairly in the marketplace and abides by fair competition and antitrust laws and expects the same of its Supplier’s. Supplier shall not enter into any agreements, whether express or implied, that violate the letter or spirit of anti-competition laws. In addition, Supplier shall not alter or draft agreements with Alight to conceal or falsify deal terms. We expect Supplier’ marketing and sales activities on Alight’s behalf to be ethical.

Financial crime, anti-money laundering and anti-terrorism laws

Supplier shall comply with the financial crime, anti-money laundering and anti-terrorism laws in all jurisdictions where it does business. Alight will conduct business only with reputable parties that are engaged in legitimate business activities with funds derived from legitimate sources. Supplier will not accept funds known to be derived from illegal activities.

International trade restrictions

Supplier shall comply with U.S. trade restriction laws and regulations, including economic sanctions, applicable import/export rules and anti-boycott activities and expects the same of its Suppliers. These import and export laws apply not only to goods but also to technology, software, intellectual property and technical information. Complying with all applicable international trade restriction and economic sanctions laws includes never knowingly employing or doing business with anyone suspected of being connected with criminal or terrorist activities or who is subject to economic sanctions.

Accepting and giving gifts and entertainment

Supplier shall ensure that acceptance of any business courtesies, gifts, or entertainment by any of its personnel is proper and consistent with the Anti-Corruption rules. Supplier shall not offer gifts or entertainment to Alight employees at any time during a Request for Proposal (RFPs) or other supplier-selection process.

Avoid conflicts

At Alight, we act with integrity and avoid conflicts that may prevent us from acting in the best interest of our clients and expect the same from our Supplier. Supplier shall disclose actual or potential conflicts of interest relating to their activities with Alight.

Environmental Responsibility

Alight is committed to providing service in a manner that maintains a safe and healthy workplace for our Colleagues and minimizes our potential impact on the environment. Supplier will operate a safe and healthy workplace in an environmentally responsible and efficient manner to minimize adverse impacts on the environment. Supplier will abide by Alight’s environmental policy communicated to Supplier from time to time, and will upon request, provide Alight with details regarding its compliance with Alight environmental policy, and the percentage of Suppliers’ operations covered by ISO 14001 (Environmental Management System).

Protect Alight and data in our care

Subject to the terms of any specific contractual provisions that apply, Supplier shall comply with all laws and regulations regarding the security and privacy of information (including personal data, personally identifiable information and personal health information), data protection and cross-border data transfers. In addition, Supplier shall maintain appropriate documents and records to ensure regulatory compliance.

Training

Supplier shall maintain a training program adequate to ensure that management and employees comply with all regulatory requirements and expectations set forth in this Supplier Code. Supplier shall cooperate with Alight as needed to develop and maintain employee training programs to implement the policies and topics outlined in this Supplier Code. Supplier shall ensure that its personnel read and comply with the Supplier Code and all associated training. Depending on the nature of the of the goods or services, Alight may require Supplier’s personnel to certify compliance with Alight’s Supplier Code. Training topics may include:

Anti-Sexual Harassment;
Anti-Corruption;
Data Privacy including HIPAA and GDPR (where applicable);
Data Security; and
Diversity

Alight may require training on additional topics depending on the services to be provided and applicable jurisdictions and laws. Upon reasonable request, Supplier shall provide Alight with evidence of training assignment and completion.