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Third Party Code of Conduct

The Mentimeter culture and work environment are made up of how each and every one of us acts, talks and behaves, every day and with that in mind, we (Mentimeter) have adopted this Code of Conduct (the “Code”) defining the basic requirements we place on all of our suppliers and others having a business relationship with Mentimeter (you). Suppliers should also encourage third parties they work with to comply with our standards. The Code is written taking into consideration the Ten Principles of the UN Global Compact together with our own policies and core values. We expect everyone of the above mentioned to know and follow the Code as a natural part of the engagement and/or contract with Mentimeter.

If you have questions, or if you find yourself in a situation where you feel the Code may be violated, please email [email protected].

1. Conflicts of Interest

As a supplier of ours, we always need you to avoid all conflicts of interest that may influence our business relationship. We’re all humans here, which means at times you may face conflicting loyalties between personal or professional benefits for you, your other business relations, your friends or family, and Mentimeter. Situations may arise, and circumstances may change, at any time with the result that a situation that didn’t used to be an issue is suddenly a conflict of interest. Any situation that involves, or might later involve a conflict of interest, should be disclosed promptly to Mentimeter and agreed together with a neutral party on how to handle it.

2. Confidentiality

When you receive access to confidential information in relation to Mentimeter, it’s up to you to keep it safe and make sure it stays confidential. This includes all information that is not public and that can be of use to competitors or otherwise be harmful to Mentimeter if it’s disclosed. It also includes information that others, such as users, vendors or partners, have entrusted with us. This obligation applies even after your engagement or contract ends.

This is easy: always comply with the laws and regulations in the applicable jurisdiction(s). All of us respect and obey the law, in letter and in spirit. Make sure you know enough about the laws that apply. If you find that the law conflicts with this Code or any of our policies, always go with the law and discuss the perceived conflict with appropriate personnel.

4. Human Rights and Labor Practices

This is even easier: Always respect all human rights. We treat everyone in our business and supply chain with the dignity and respect they deserve and in accordance with internationally proclaimed human rights. We are opposed to all forms of human trafficking, slavery, servitude, forced or compulsory labor, and we don’t ever use any of it in our business. We also never employ workers under the age of 15. We expect all of our suppliers to respect these values and operate in accordance with the aforesaid. 

5. Non-Discrimination

The diversity of the Mentimeter team is a tremendous asset and we work hard to have a safe and discrimination-free work environment. Mentimeter strives to ensure equal treatment and opportunities for all people regardless of age, gender, sexual orientation, religion, social or ethnic origin, disability, pregnancy, parenthood, union membership and political affiliation. Mentimeter does not tolerate any unacceptable treatment of individuals such as mental cruelty, sexual harassment or discrimination including language and physical contact, that is sexual, coercive, threatening, abusive or exploitative. Consequently, we also expect and require all of our suppliers to respect and enforce these values appropriately and operate in accordance with the aforesaid.

6. Working Hours, Wages & Benefits for Employees

Working life balance is very important to us at Mentimeter and we respect and comply with all applicable working-hours regulations as well as wage and compensation laws. We also recognize the legal rights of workers to seek representation, associate freely, form, join or not join trade unions and to engage in collective bargaining; neither disadvantage nor prefer members of employee organizations or trade unions. We expect and require our suppliers to always respect and comply with applicable laws and collective bargaining agreements.

7. Health & Safety of Employees

Mentimeter provides a safe and healthy work environment. We ensure that our employees have access to adequate and relevant health and safety information and training. Each employee has a responsibility for maintaining a safe and healthy work environment. We expect and require that our suppliers ensure that their workplace and the working conditions they provide are healthy and safe for all workers, both from a physical and psychological perspective.

8. Grievance Mechanism

We encourage everyone we work with to speak up about any misconduct. We rely on each and every one of you  taking that responsibility and the goal is always to resolve problems as quickly as possible so that we all can continue doing great work! All we ask is that you only raise concerns in good faith. If you become aware of any misconduct, please contact us using the contact details found in the beginning of this Code. Upon our receipt of a grievance we will review and register the matter. Based on our review we will, in our discretion, inform and seek a response from the party allegedly in breach of the Code. Upon such response (or lack thereof) we will further investigate, form and implement an action plan designed to address the matter at hand. The matter will be continuously monitored and if the action plan does not provide for satisfactory results we will revisit the matter and form and implement a new action plan. 

9. Environmental Protection

Mentimeter is committed to operating environmentally responsible by adopting policies and strategies to promote sustainable development. We encourage the use of environmentally sound technologies and always seek to cooperate to improve environmental performance. All of us shall act in accordance with the applicable statutory and international standards regarding the environment, minimize environmental pollution and make continuous improvements in environmental protection. We strongly encourage our partners to cooperate with their suppliers and other stakeholders to improve their environmental performance and extend environmental responsibility throughout the supply chain.

10. Anti-Corruption and Bribery

This area has strict laws all over the world. In short, these laws forbid giving anything of value, directly or indirectly, to any government official, political candidate, or business person, in order to get business deals or privileges. Consequently we, including the people and companies we work with, don’t. Because we are better than that, and also because doing so could end up in significant penalties for Mentimeter and criminal charges for individuals. None of us therefore tolerate any form of corruption or bribery and do not grant, offer or promise anything of value to a government official or to a counterparty in the private sector to influence official action or obtain an improper advantage. We will not accept or provide compensation in the form of cash, cash equivalents (e.g. gift cards), loans, travel, subsistence, services or any other item or circumstance that obligates the receiving party to provide something in return.

11. Fair Competition, Antitrust Laws and Intellectual Property Rights

We play fair and we compete simply by being better, but never by employing practices that are illegal, unethical, or questionable. We don’t use information that was obtained without the owner’s consent or secret information that is wrongfully disclosed by past or present employees of other companies. We expect you to deal fairly with your customers, suppliers, competitors and employees, and always respect their rights. We also expect you to never take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of facts or any other kind of intentional dirty tricks or unfair practice.

All of us always act in accordance with national and international competition laws and do not participate in price fixing, market or customer allocation, market sharing or bid rigging with competitors.

We also respect the intellectual property rights of others and we expect you to do the same, including what is stated above. 

12. Anti-Money Laundering, Terrorism Financing

None of us will ever directly or indirectly facilitate money laundering or terrorism financing.

13. Data Privacy

We will always process personal data confidentially and responsibly, respect everyone’s privacy and ensure that personal data is effectively protected and used only for legitimate purposes. This applies also to you who work with us, we need you to always respect our users’ integrity and only process personal data in accordance with applicable data privacy legislation and regulatory frameworks. For more information on how Mentimeter handles these matters, please see our Privacy Policy.

14. Export Control and Customs

We, as well as you who work with us, will always ensure compliance with applicable export control and customs regulations.

15. Supply Chain

We expect everyone we work with to comply with this Code, meaning also that your organization is compliant with the Code. We also require you to ensure that your own suppliers comply with the principles of this Code. If you are aware of any behavior in breach of this Code within your organization, please report your concern to [email protected].

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