Business Partner Code of Conduct

This Business Partner Code of Conduct (the “Code”) applies to all LogicMonitor Business Partners including, but not limited to, our distributors, resellers, solution and consulting partners, agents, suppliers, vendors, and service providers (“Business Partner(s)”). “LogicMonitor” as used throughout this Code refers to the entire LogicMonitor corporate group and is meant to include all of its subsidiaries, affiliates and business offices, both domestic and international, and all individuals employed therein.

LogicMonitor is dedicated to maintaining the highest standards of business conduct and ethics everywhere we operate or do business, and we are committed to following all applicable laws and regulations. The strength of our reputation is based, not only on our own conduct, but also on the actions of those with whom we do business. For that reason, we aim to work only with third parties who share our values and are committed to compliance with all applicable laws. This Code is the foundation of our relationship with our Business Partners – creating a mutual understanding of our company’s core values and beliefs. This Code is not exhaustive; Business Partners are required to use their best judgment to ensure compliance with unaddressed topics.

Non-Compliance

Part of conducting business with LogicMonitor includes compliance with this Business Partner Code of Conduct. LogicMonitor has the right to terminate business with any Business Partner who fails to adhere to this Code.

Audits and Inspection

LogicMonitor retains the right to audit its Business Partners to ensure compliance with the standards in this Code.  Any violations will be reported to the LogicMonitor Business Partner’s management for their attention and if appropriate, corrective action.

Subcontractors

LogicMonitor must be informed of all Business Partner subcontractors that will be used in conducting business with and for LogicMonitor.  Business Partners must ensure their subcontractors receive this Code and agree to abide by its contents.

Speaking Up

Any violation of the Code, and any indication or suggestion by a Business Partner or employee to take any action that may violate this Code or any applicable law, should immediately be reported.  Anonymous reports can be made through our Compliance and Ethics Hotline at https://www.lighthouse-services.com/logicmonitor  Whether you identify yourself or not, your contact will be kept strictly confidential to the extent reasonably possible within the objectives of these guidelines and Company policy, as permitted by law.

Honest and Accurate Dealings

LogicMonitor competes fairly and in compliance with all applicable laws worldwide.  The integrity of our company and its Business Partners is an integral part of LogicMonitor’s business practices and dealings.  We hold all of our Business Partners to the highest ethical standard. LogicMonitor will not do business with any third parties that engage in unethical or illegal business practices.

False Statements

We value honesty and transparency.  LogicMonitor Business Partners shall not make any false, misleading or inaccurate representations in connection with any LogicMonitor transaction including, but not limited to, oral misrepresentations of fact or false documentation (such as fake purchase orders or invoices, fraudulent or forged contracts, forged letters of destruction and/or other false or inaccurate business records).

Anti-Corruption

LogicMonitor is committed to conducting business in a manner consistent with all international anti-corruption laws and requires the same ethical practices from its Business Partners.  LogicMonitor will conduct its business free from extortion, bribery and all unlawful, unethical or fraudulent activity. LogicMonitor Business Partners must never, directly or indirectly, offer, give, promise or authorize any bribe, kickback, gift, loan, fee, reward or other advantage to any government official or employee, any customer, any LogicMonitor employee or any other person to obtain an unfair business advantage or to improperly influence an action or decision.

Antitrust and Fair Competition 

The policy of LogicMonitor is to require full compliance with both the letter and spirit of all antitrust laws of the countries where we do business.  LogicMonitor Business Partners are not permitted to:

• Propose to or enter into any agreement with any of LogicMonitor’s competitors or the Business Partner’s competitors to fix prices, margins, or terms and conditions or to divide up any markets or customers
• Propose to or enter into any agreement or understanding restricting resale pricing of LogicMonitor products
• Improperly limit sales of LogicMonitor product
• Propose to or enter into reciprocal dealing agreements, price maintenance agreements, exclusive dealing arrangements and requirements contracts or tie-in arrangements.

LogicMonitor Business Partners should avoid even the appearance of engaging in any of these types of behaviors.

Gifts and Entertainment

LogicMonitor takes special precautions when offering or accepting gifts, entertainment or hospitality in the course of business and expects the same from its Business Partners.  Business Partners must be sure to abide by their customers’ rules and all applicable laws governing gifts, meals, and entertainment.  Gifts or entertainment, of any value, must never be offered to government officials or associates, and must never be used to obtain an unfair business advantage.  Never offer, give or accept a gift, favor, service or entertainment if such an action could be viewed as a bribe or attempt to improperly influence a business decision.

Conflicts of Interest

LogicMonitor Business Partners must avoid any situation or relationship that may involve an inappropriate conflict or the appearance of a conflict with the interests of LogicMonitor.  LogicMonitor Business Partners shall not offer or provide excessive gifts, hospitality or entertainment to any LogicMonitor employee or family member of LogicMonitor employees. LogicMonitor employees and their family members may not hold any significant economic interest in any entity that does business with LogicMonitor and Business Partners are required to avoid such relationships with LogicMonitor employees.

If at any point, a Business Partner has an existing or potential conflict with the interests of LogicMonitor, LogicMonitor’s Procurement Department  must be notified immediately.

Protection of Confidential/Proprietary Information

Our Business Partners must respect LogicMonitor’s intellectual property, trade secrets and other confidential, proprietary or sensitive information and may not use or disclose any such information except in accordance with their contract with LogicMonitor or with our prior, written consent. Any information or data regarding LogicMonitor must be treated as confidential at all times unless that information becomes publicly available through no fault of the Business Partner. Our Business Partners may not disclose our confidential or proprietary information to persons outside of their organizations, nor may they disclose such information within their own organizations except on a strict “need to know” basis for the purpose intended by LogicMonitor. Business Partners are also prohibited from using our confidential information for their own benefit or the benefit of any other person or entity besides LogicMonitor.  LogicMonitor Business Partners must notify LogicMonitor’s Law Department of any unauthorized use of LogicMonitor trade secrets, brands, trademarks, logos or confidential information.

Note that nothing in this section is meant to modify or negate an existing confidentiality or non-disclosure agreement between LogicMonitor and one of its Business Partners.

Export Controls

LogicMonitor’s business operations extend globally; we sell services and license software worldwide.  It is LogicMonitor’s policy to abide by all international trade laws, without exception, and all LogicMonitor Business Partners must strictly comply with all export and reexport restrictions applicable to LogicMonitor.  When working on LogicMonitor business, our Business Partners are also required to comply with United States trade sanction and export control regulations, regardless of where in the world they are incorporated or operating. Specifically, our Business Partners must not conduct any business on our behalf with any persons, entities or countries subject to U.S. sanction or embargo. In connection with LogicMonitor business, our Business Partners are also prohibited from participating in boycotts that are not sanctioned by the U.S. government.  In addition, all import and export documentation must be complete and accurate prior to importation / exportation and copies should be retained for at least five years following any transaction.  Such documentation may include information about the admissibility, classification, valuation, country of origin, labeling, and applicable rate of duty of the item being imported or exported.

Lawful Employment and Labor Standards

LogicMonitor strongly opposes the use of illegal child labor, forced or bonded labor, human exploitation, and all other forms of unacceptable treatment of workers.  We expect our Business Partners to treat their employees fairly, in accordance with local laws, regulations and standards regarding labor and employment.  Business Partners are required to follow all general workplace standards, including health and safety, environmental, and labor standards.  In addition, Business Partners shall implement and maintain a reliable record keeping system to verify compliance with all applicable labor and employment standards.

Legal Right to Work

LogicMonitor Business Partners shall, prior to employing any worker, validate and review all relevant documentation to ensure that such worker has the legal right to work in that jurisdiction.

Involuntary Labor

Employment with LogicMonitor Business Partners should be an expression of free choice and there may be no forced, compelled, bonded, indenture, prison or involuntary labor.

Child Labor

LogicMonitor Business Partners must abide by all working age laws in their countries of operation and should not use child labor.  LogicMonitor Business Partners should adopt procedures to verify and maintain documentation that no workers are younger than the local legal age for employment.

Harassment

Workers have a right to a workplace free of harassment.  LogicMonitor requires that its Business Partners prohibit all types of harassment including, but not limited to physical, verbal and sexual harassment.

Fair Treatment, Non-Discrimination, Diversity and Inclusion

LogicMonitor Business Partners shall demonstrate a commitment to the principles of fairness, equal opportunity, diversity and inclusion.

At a minimum, LogicMonitor Business Partners will make all employment-related decisions, including but not limited to hiring, compensation, promotion, discipline, or termination based on skills, qualifications, and/or performance and will not illegally discriminate against employees and workers based on age, gender, race, sexual orientation, perceived disability, national, cultural, religious or personal beliefs, or any other status protected by applicable law.

LogicMonitor Business Partners are encouraged to provide equal opportunity for qualified small businesses, minority-owned and women-owned businesses, and other diverse and underrepresented suppliers in the supplier selection process.

Business Partners also are encouraged to develop and maintain policies and programs that promote diversity and inclusion that may include quantifiable goals to increase diversity and inclusion, measures and controls (including audits), reporting and training.

Safe Working Conditions

LogicMonitor Business Partners shall provide a safe, healthy and hygienic workplace, in compliance with all local and national regulations.

Business Partners must protect employees from chemical, biological, and physical hazards, in addition to on-site accidents.  To help ensure safety, the Business Partner must provide employees with the necessary training and protective equipment where applicable.

Working Hours, Wages and Benefits

LogicMonitor Business Partners shall afford workers and employees working hours that comply with national laws and industry standards.

LogicMonitor Business Partners shall provide wages and benefits that comply with all applicable local wage and hour laws and regulations including those relating to minimum wages, overtime hours, piece rates and other elements of compensation, and provide legally mandated benefits.

Environmental

LogicMonitor Business Partners shall operate in an environmentally responsible and efficient manner and shall make efforts to minimize adverse impacts on the environment, as well as adverse impacts on public health and safety.

At a minimum, this includes operating in compliance with all applicable environmental laws, regulations and standards, including but not limited to those related to waste management and disposal, recycling, wastewater treatment and discharge, air emissions controls, hazardous and toxic materials handling, environmental permits and environmental reporting.

Business Partners are encouraged to develop and maintain environmental policies and programs that include quantifiable goals to reduce environmental impact, measures and controls (including audits), reporting and training.

Your Responsibility for Compliance

It is our Business Partner’s responsibility to ensure that its employees, agents and subcontractors working on LogicMonitor business understand and comply with this Code.  Failure to adhere to this Code or any applicable law is grounds for termination of our business relationship.  We expect our Business Partners to have adequate systems in place to investigate and remediate allegations of wrongdoing, to the extent permissible by local law, and you are required to immediately notify LogicMonitor upon becoming aware of any potential legal violations or unethical conduct related to LogicMonitor business.

Any questions regarding this Business Partner Code of Conduct can be directed to our Procurement team via email at [email protected]