Supplier Code of Conduct

All University of Pennsylvania suppliers are expected to comply with all applicable laws, regulations, and industry standards in the jurisdictions where they operate. This includes, but is not limited to, requirements related to environmental stewardship, occupational health and safety, labor practices, and ethical business conduct. Suppliers are also responsible for ensuring that their subcontractors, staffing agencies, and other supply chain partners adhere to these same standards and compliance expectations.

All University of Pennsylvania suppliers are expected to comply with applicable environmental laws, regulations, and standards in all locations where they operate. This commitment includes maintaining required environmental permits and regulatory filings, ensuring the safe handling, storage, and disposal of hazardous materials, and effectively monitoring, controlling, and treating emissions, waste, and other operational discharges. Suppliers should demonstrate responsible environmental stewardship and support sustainable business practices throughout their operations.

All University of Pennsylvania suppliers are expected to provide a safe, healthy, and secure work environment that minimizes the risk of workplace injuries, illnesses, and occupational hazards. This commitment includes providing appropriate health and safety training, maintaining effective systems for reporting and addressing workplace incidents, ensuring access to medical treatment and applicable worker support, implementing safeguards and protective measures to prevent injuries, and maintaining clean, safe, and well-managed facilities. Suppliers should foster a culture of safety and continuous improvement in workplace health and well-being.

All University of Pennsylvania suppliers are expected to maintain fair and ethical labor practices and to treat all workers with dignity, respect, and in accordance with applicable laws and regulations. Suppliers are expected to uphold the following standards:

1. Freedom of Association – Recognize and respect employees’ rights to freely associate, organize, and engage in collective bargaining in accordance with applicable labor laws and regulations
2. Freely Chosen Employment – Prohibit the use of forced, bonded, indentured, involuntary, or prison labor in any form.
3. No Child Labor – Comply with all applicable minimum age requirements and labor laws and prohibit the use of child labor.
4. Fair Wages and Benefits – Provide compensation, including wages, overtime pay, and benefits, that meets or exceeds applicable legal and regulatory requirements.
5. Working Hours – Adhere to all applicable laws governing working hours, overtime, rest periods, and days of rest.
6. Respectful Workplace – Maintain a workplace free from harassment, intimidation, abuse, coercion, or inhumane treatment. Employees should be treated with dignity, respect, and professionalism at all times.
7. Equal Employment Opportunity – Foster an inclusive work environment and prohibit discrimination in employment practices based on any characteristic protected by applicable law.

All University of Pennsylvania suppliers are expected to conduct business with integrity, transparency, and accountability while complying with all applicable laws, regulations, and University requirements. Suppliers are expected to uphold the following standards:

1. Protection of Intellectual Property and Confidential Information – Respect and protect intellectual property rights and maintain the confidentiality, security, and proper use of University information. Suppliers must safeguard proprietary and confidential data, comply with all requirements governing the use of University trademarks, copyrights, patents, and other intellectual property, and implement appropriate security measures when storing, transmitting, or accessing University information.
2. Fair Business Practices – Conduct business in a fair and competitive manner and comply with all applicable antitrust, competition, and trade regulations.
3. Anti-Bribery and Anti-Corruption – Prohibit bribery, kickbacks, fraud, and any improper payments or inducements intended to influence business decisions or compromise ethical conduct.
4. Compliance with Global Anti-Corruption Laws – Adhere to all applicable anti-corruption laws and regulations, including the U.S. Foreign Corrupt Practices Act (FCPA) and other laws governing international business activities.
5. University Policies and Standards – Comply with applicable University policies, procedures, and standards, including those related to procurement, ethics, and conflicts of interest.

All University of Pennsylvania suppliers are required to comply with all applicable U.S. and international economic sanctions, export control laws, trade restrictions, and embargo programs. This includes sanctions and restrictions administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), the U.S. Department of Commerce, the U.S. Department of State, the United Nations, the European Union, and other applicable regulatory authorities.

Suppliers must not directly or indirectly engage in, support, finance, facilitate, or otherwise participate in activities involving sanctioned countries, prohibited organizations, restricted entities, or designated individuals in violation of applicable laws or regulations. Suppliers are also prohibited from engaging in or supporting terrorism, terrorist financing, money laundering, or other unlawful activities.

Suppliers, their affiliates, subsidiaries, principal owners, officers, directors, and key personnel must not be identified on any applicable sanctions, denied-party, debarment, or terrorist watch lists, including but not limited to:

1. The U.S. Department of the Treasury’s Specially Designated Nationals and Blocked Persons (SDN) List and other OFAC sanctions lists.
2. The U.S. Department of State Terrorist Exclusion List and related sanctions programs.
3. The U.S. Department of Commerce Denied Persons List, Entity List, and other restricted-party lists.
4. United Nations Security Council sanctions lists, including those established under applicable Security Council resolutions.
5. European Union restrictive measures and consolidated sanctions lists.
6. Any other applicable national or international sanctions, terrorist, or prohibited-party lists.

Suppliers must promptly notify Procurement Services of any actual or potential sanctions-related compliance issues, investigations, enforcement actions, regulatory findings, or changes in status that could affect their eligibility to conduct business with the University. The University reserves the right to review supplier compliance practices, request supporting documentation, and take appropriate corrective action, including suspension or termination of the business relationship, if a supplier fails to meet these requirements.

All University of Pennsylvania suppliers are expected to comply with University policies, procedures, and guidelines governing access to University facilities, offices, departments, and employees. Suppliers should conduct all interactions with the Penn community in a professional, respectful, and authorized manner.

Suppliers may not use University technology resources, including email systems, networks, or other electronic communication platforms, to distribute unsolicited communications or marketing materials to members of the University community.

Any on-campus trade shows, exhibits, product demonstrations, marketing events, or similar activities require prior approval from the University. Procurement Services, in collaboration with Penn’s Schools and Centers, reserves the right to approve, restrict, or prohibit supplier solicitation, promotional activities, or campus access as deemed appropriate to support the University’s operational and community needs.

All University of Pennsylvania suppliers are expected to maintain processes and controls that support compliance with this Supplier Code of Conduct and all applicable laws and regulations. Suppliers should periodically assess their operations and supply chains to identify and address areas of non-compliance. If a compliance issue is identified, suppliers are expected to promptly notify Procurement Services and provide an appropriate corrective action plan to address the issue.

The University, or its authorized representatives, may conduct reasonable monitoring and assessment activities to verify compliance with this Supplier Code of Conduct. Such activities may include supplier questionnaires, reviews of publicly available information, documentation requests, on-site visits, or other appropriate evaluation methods.

Suppliers and University employees who become aware of potential violations of this Supplier Code of Conduct are encouraged to promptly report such concerns to Procurement Services.

Based on information obtained through these assessments and in accordance with applicable contractual terms, the University reserves the right to require corrective actions, suspend consideration of a supplier, or terminate a supplier relationship when significant violations of this Supplier Code of Conduct are identified. These actions may be taken in addition to any other rights or remedies available to the University under applicable law or contract.