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Privacy Policy

Single Point Global – Privacy Policy

Your privacy is important to us. This Online Privacy Notice describes what information we collect, how we collect it, and how it is used, disclosed, transferred and stored. It also describes your choices regarding use, access and correction of your personal information. This Online Privacy Notice applies to the information we collect through our websites (“Site”). The use of information collected is limited to providing support to the service for which the Client has engaged Single Point Global. If you have any questions regarding this Online Privacy Notice you may contact us as indicated in the “How to Contact Us” section below.

Scope
EU-U.S. Privacy Shield

Single Point Global participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework with respect to only https://www.singlepointglobal.com and https://cms.singlepointglobal.com. Single Point Global is committed to subjecting all personal data from these sources received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List.

Single Point Global is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Single Point Global complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy Shield Framework, www.singlepointglobal.com and cms.singlepointglobal.com are subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Single Point Global may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Under certain conditions, more fully described on the Privacy Shield website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

Principles
Information We Collect

The types of personal information users of our Site may submit include:

contact information (such as name, address, telephone number, email);
other personal information found in content that users provide (for example, when using CMS, when signing up to receive emails or other communications from us, in responding to surveys or on line chat sessions, or in completing web-based forms or registering for products and services through our Site); and
personal information submitted by job applicants, such as a résumé or C.V., employment and education history, salary information and citizenship information.

Our Site also collects certain information by automated means. This type of information may include device type, operating system type, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone where your device is located. We may also record information such as the address of the web page that referred you to our Site and the IP address of the device you use to connect to our Site. We collect this information to analyze trends in the aggregate and administer the site.

In addition, Single Point Global and its partners may use cookies or similar technologies, which are files that websites send to your computer or other Internet-connected device to uniquely identify your browser or to store information or settings on your device. We use these technologies to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our website or service.

Single Point Global Cloud handles information under the direction of its Clients through negotiated contracts, and it has no direct relationship with the individuals whose personal data it processes. If you are a customer of one of our Clients and would no longer like to be contacted by one of our Clients that use our service, please contact the Client that you interact with directly.

How We Use the Information We Collect

We may use the information described above to:

offer and provide products and services;
send promotional materials or other marketing communications;
deliver targeted online advertising;
communicate about programs, offers, and surveys;
communicate with returning users of our Site and auto-fill web-based forms that returning users have previously completed;
respond to inquiries;
operate, evaluate, and improve our business (for example, to develop new products and services, to enhance or improve products and services, and to manage communications);
comply with applicable legal requirements, relevant industry standards, and our policies.

We may also use the information in other ways for which we provide specific notice at the time of collection.

In addition, we use information collected through automated means for the purposes set forth above, including by (i) customizing users’ visits to our Site, (ii) analyzing how users interact with our Site and online advertisements; (iii) delivering targeted advertising and content tailored to our users’ interests; and (iv) managing our Site and other aspects of our business.

Single Point Global Cloud has no direct relationship with the individuals whose personal data it processes on behalf of Clients. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to our Client (the data controller). If requested to remove data we will respond within a reasonable timeframe.

We will retain personal data we process for as long as needed to provide services to our Client. Single Point Global will retain this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Do Not Track

Our services and Site do not respond to your browser’s “do-not-track” signals or comparable mechanisms.

Information We Share

We may share personal information with service providers who perform services on our behalf based on our instructions. These companies are authorized to use your personal information only as necessary to provide these services to us. We may share certain personal information with our affiliates for the purposes described in this Online Privacy Notice.

We partner with a third party to either display advertising on our Site or to manage our advertising on other sites. Our third party partner may use technologies such as cookies to gather information about your activities on this Site and other sites in order to provide you advertising based on your browsing activities and interests.

We may also use third-party web analytics services on our Site to help us analyze Site performance and how users use the Site. The information collected for this purpose (including your IP address and other information collected by automated means) will be disclosed to or collected directly by the service provider.

In addition, we may disclose information about you (i) if we are required to do so by law or legal process, (ii) to law enforcement authorities or other government entities, and (iii) when we believe disclosure is necessary or appropriate to prevent harm or financial loss, or in connection with an investigation of alleged fraudulent or illegal activity. We also reserve the right to transfer personal information we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, spin-off, dissolution or liquidation), in which case you will be notified via email and/or a prominent notice on our website, of any change in ownership, uses of your personal information, and choices you may have regarding your personal information. We may also disclose your personal information to any other third party with your prior consent.

Social Media

Our website includes social media features and widgets, such as the Facebook Like button, Share This button, or interactive mini-programs that run on our website. These features and widgets may collect your IP address, which webpage you are visiting on our website, and may set cookies to enable the feature and widget to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our website. Your interactions with these features are governed by the privacy policy of the company providing it.

Data Transfers

We collect and maintain personal information within the United States. As needed, we may transfer the personal information we collect about you through the Site to countries other than the country in which the information originally was collected. Those countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your information to other countries, we will protect that information as described in this Online Privacy Notice.

How We Protect Personal Information

The security of your personal information is important to us. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once it is received. We maintain administrative, technical, and physical safeguards designed to protect the personal information you provide on the Site against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use.

Despite these precautions, no system can be completely secure and there remains a risk that unauthorized access or use, hardware or software failure, human error, or a number of other factors my compromise the security of your information. If you have any questions about the security of your personal information, you can contact us at support@singlepointglobal.com.

We may retain your information for as long as your account is active or as needed to provide you services, comply with our legal obligations, resolve disputes and enforce our agreements.

Your Rights and Choices

We offer you certain choices in connection with the personal information we collect from you. To update your preferences, ask us to remove your information from our mailing lists, or submit a request, please address your request to sales@singlepointglobal.com. For any requests related to cloud or colocation services, please address your request to sales@singlepointglobal.com. To the extent provided by the law of the jurisdiction where you live, you may request access to personal information we maintain about you or request that we correct, amend, or delete the information by contacting us as indicated above.

We will respond to these requests within a reasonable timeframe.

Updates To Our Online Privacy Notice

We may update this Privacy Policy to reflect changes to our information practices. If we make any material changes, we will notify you by means of a notice on this website prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

Contact Information

If you have any questions or comments about this Online Privacy Notice, or if you would like us to update information we have about you or your preferences, please contact us at the following:

Email address: sales@singlepointglobal.com

Mailing address:

21720 Red Rum Dr, Suite 122
Ashburn, VA 20147
Attention: CEO/General Counsel

Effective Date

This Online Privacy Notice is effective as of: January 1st, 2018.

Cookies

As you browse singlepointglobal.com, advertising cookies will be placed on your computer so that we can understand what you are interested in. Third parties, such as our display advertising partner, AdRoll, then enables us to present you with retargeting advertising on other sites based on your previous interaction with singlepointglobal.com and data collected through these cookies. The techniques our partners employ do not collect personal information such as your name, email address, postal address or telephone number. You can visit this page to opt out of AdRoll and their partners’ targeted advertising.

SPG PARTNER CODE OF BUSINESS CONDUCT AND ETHICS

This Code of Business Conduct and Ethics (“Code”) is designed to promote:

 

  • Honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships.

  • Full, fair, accurate, timely and understandable disclosure in reports and documents we file with or submit to the U.S. Securities and Exchange Commission and in our other public communications.

  • Compliance with applicable laws, rules and regulations.

 

  • The prompt internal reporting of violations of this Code. and

 

  • Accountability for adherence to this Code.

 

Single Point Global, Inc (SPG) strives to demonstrate integrity in every business interaction and is committed to conducting business ethically and in compliance with applicable laws and regulations. SPG requires businesses that associate themselves with our brand through the resale or distribution of our products and services to uphold the highest ethical standards. SPG requires all channel partners worldwide, including resellers, distributors, alliance partners, OEMs, NPN partners, public sector entities and any other commercial entity or individual with whom SPG may engage in the normal course of SPG’s day to day business operations (“Partner(s)”) to adhere to this Code. SPG may conduct due diligence and periodic monitoring of Partners to ensure compliance with this Code and with other applicable SPG policies, including, but not limited to FCPA/anti-bribery and anti-corruption policies and export compliance requirements. As a condition of doing business with SPG, you consent to such due diligence and monitoring and shall support these efforts upon request by SPG. Any violations of this Code will entitle SPG to exclude Partner from any SPG channel programs, deprive Partner of any benefits earned under such programs, and may result in immediate termination of Partner’s agreement(s) with SPG.

1. ETHICAL PRINCIPLES AND CORE VALUES

SPG expects that all of its Partners will operate their businesses in accordance with the following principles:

 

  • Honesty

  • Integrity

  • Trustworthiness

  • Respect for others

  • Responsibility

  • Accountability

  • Full compliance with all applicable laws, rules, statutes and regulations

  • ​Commitment to this code

Decision Making and the Code of Conduct

When making a decision, ask yourself the following:

  • Is it legal?

  • Does it comply with this Code?

  • Does it reflect SPG’s company values and ethics?

  • Does it respect the rights of others?

Reporting/Speaking Up

SPG encourages its Partners to ask questions and raise issues without fear of retaliation and is committed to treating reports seriously and investigating them thoroughly.

 

If you see something, say something! Partners must report suspected unethical, illegal or suspicious behavior immediately. SPG does not tolerate retaliation against any person or company who makes a good faith report of suspected misconduct or otherwise assists with an investigation or audit. Partner must not tolerate such retaliation either.

2. FAIR DEALING AND LEGAL COMPLIANCE

Partner must be committed to high standards of ethical conduct and must comply with all applicable legal and regulatory requirements and avoid engaging in any activity that involves even the appearance of impropriety.

Competition, Fair Dealings and Antitrust

While SPG competes aggressively for new business, relationships with business Partners are built upon trust and mutual benefits and full compliance with competition/antitrust laws and Partners must engage in fair business practices in advertising and sales.

As our valued Partner, you are required to:

 

  • Communicate with end customers about SPG’s products and services in a manner that is fair and accurate, and that discloses all relevant information. As our Partner, you must never misrepresent or embellish the features, functions or performance of SPG’s technology or related services.

  • Your employees are required to familiarize themselves with SPG’s policies pertaining to ethics and compliance with law and remain aware of the consequences of any violation of policies or laws governing fair competition.

  • Your employees must at all times refrain from price fixing, bid rigging, and any other anti-competitive activities in any geography or jurisdiction in which they operate. Your employees must be made to understand that they cannot coordinate end customer pricing with SPG or any other entity if your company is engaged in reselling or distributing SPG products or services. To do so would be considered price fixing and that is categorically illegal.

  • Use only publicly available information to understand business, customers, competitors, technology trends, and regulatory proposals and developments and thereby completely abstain from any anti-competitive “bid-rigging” activities.

 

 

You are required to notify SPG immediately of any breach of this provision or any other requirement of this document. Silence in the face of knowledge of a violation will exacerbate the problem and increase SPG’s and your potential liability.

Bribery and Facilitation Payments

Partner will not attempt to influence the judgement or behavior of a person in a position of trust and\or decision-making authority or influence by providing any “gift” or anything of value in order to achieve a positive business result. This applies to persons in both government and in private business.

 

Partner will not permit facilitation (or “grease”) payments to government officials or private business in order to secure or speed up routine actions.

 

You agree that you are required to:

 

  • Select your third-party partners and vendors carefully and monitor them continuously to ensure that they comply with these anti-bribery and corruption policies.

  • Keep accurate books and records at all times and monitor that funds are not being used for purposes of bribery, gifts or facilitation payments. and

  • Refuse any offer or request for an unlawful payment and report the incident to SPG’s ethics and compliance hotline.

Corruption, bribery, extortion or embezzlement, in any form, is strictly prohibited. Any violation of these laws will result in the immediate termination of your business relationship with SPG and possibly additional legal action.

Training

Gifts and Entertainment

You are required to ensure that all of your employees are fully and competently trained on the content of this Code. This training must be repeated on a regular basis.

While gifts and entertainment among business associates can be appropriate ways to strengthen ties and build goodwill, they also have the potential to create the perception that business decisions are being unethically influenced. SPG is committed to winning business only on the merits of its products, services and people and SPG and Partner must comply with all legal requirements for giving and receiving gifts and providing meals and\or entertainment. Those laws include, but are not limited to, the Foreign Corrupt Practices Act of 1978 and the UK Anti-Bribery Law of 2013.

We require that your employees are trained to:

 

  • Use sound judgment and comply with all applicable laws, rules, statutes and regulations regarding gifts and other benefits.

  • Never allow gifts, entertainment or other personal benefits to influence decisions or undermine the integrity of business relationships.

  • Never accept gifts or entertainment that are illegal, immoral or would reflect negatively on the company. and

  • Never accept cash, cash equivalents, stocks or other securities.

Political Contributions and Charitable Contributions

Be aware that contributions made in the context of political campaigns, or contributions made for charitable causes that are favored by customers may run afoul of the law. If unsure as to a specific contribution, it is always best to err on side of the law and on the side of caution.

Political Contributions and Charitable Contributions

Partners must become familiar with, understand and comply with all laws, rules, statutes and regulations relating to sales to government entities.

Money Laundering

Money laundering is the process of concealing illicit funds by moving them through legitimate businesses to hide their criminal origin. This is illegal and SPG requires that its Partners adopt a policy of zero tolerance.

Your employees must never knowingly facilitate money laundering or terrorist financing, and must take steps to prevent inadvertent use of the company’s business activities for these purposes.

Employees should be trained to spot signs of money laundering, and your employees are to be required to immediately report any unusual or suspicious activities or transactions, such as:

 

  • attempted payments in cash or from an unusual financing source or non-business account

  • arrangements that involve the transfer of funds to or from countries or entities not related to the transaction or customer

  • unusually complex deals that don’t reflect a legitimate business purpose

  • attempts to evade record-keeping or reporting requirements

  • payments made in currencies other than those specified in the applicable contract

Insider Trading

As our business Partner, your employees may learn information about our company, clients, other business partners or companies that is not publicly available. It is illegal for any individual to use information that is not publicly available in order to profit on a stock trade or for other financial gain, or to share any such information with others.

Your employees must be trained so that they know that they are prohibited from:

 

  • Buying or selling securities based on non-publicly available information. and

  • Providing such non-public information or “tips”, or encourage another person to buy or sell securities based on such non-public “inside” information.

Obtaining and Using Business Intelligence

Partners who collect information on customers and markets in which they operate must do so only through legitimate means. Partner must not seek business intelligence by illegal or unethical means.

3. INTELLECTUAL PROPERTY

Partners must respect the trademarks and other intellectual property rights of SPG and other third-parties and may not knowingly use the intellectual property of any third-party without permission.

4. LABOR AND HUMAN RIGHTS

Partners must uphold the rights of workers and treat them with dignity and respect.

Equal Opportunity

SPG will not tolerate discrimination based on race, color, religion, gender, age, national origin, sexual orientation, marital status, disability or any other protected class. We cannot and will not maintain a business relationship with any entity that tolerates discrimination in its own workplace. You agree to maintain a work environment that contains a policy of anti-discrimination.

Harassment

Any type of harassment, including physical, sexual, verbal or other, is prohibited and will result in termination of our relationship with Partner.

Harassment can include actions, language, written words or objects that create an intimidating or hostile work environment, such as:

  • Yelling at or humiliating someone

  • Physical violence or intimidation

  • Unwanted sexual advances, invitations or comments

  • Visual displays such as derogatory or sexually-oriented pictures or gestures

  • Physical conduct including assault or unwanted touching

  • Threats or demands to submit to sexual requests as a condition of employment or to avoid negative consequences

Bullying

At SPG, we are committed to ensuring that our employees and our Partner’s employees work in a safe and respectful environment that is free of bullying. Bullying can include:

 

  • Spreading malicious rumors or gossip

  • Excluding or isolating someone socially

  • Establishing impossible deliverables

  • Withholding necessary information or purposefully giving the wrong information

  • Intimidating someone

  • Impeding someone’s work

  • Unfairly denying training, leave or promotion

  • Constantly changing work guidelines

  • Sending offensive jokes or emails

  • Criticizing or belittling someone constantly

  • Tampering with a person's personal belongings or work equipment

Forced Labor

You shall employ people under their own free will with no one being subjected to bonded or forced labor. This policy applies to not only your business operations but also those of your supplier network.

Child Labor

Neither you nor your suppliers shall employ any people under the minimum legal working age of the country in which they work. Partner must comply with all applicable child labor laws, including the minimum age for employment in all countries where it does business, or the age for completing compulsory education in such countries, whichever is higher.

Wages and Benefits

Partners must pay their workers at least the minimum wage, including compensation for overtime hours, required by applicable laws and regulations and provide all legally required benefits.

Workers must be paid in a timely manner, and the basis on which workers are being paid must be clearly conveyed to them in a timely manner. Partners must maintain accurate records of employee hours worked and wages paid.

Health and Safety

Partner must be committed to creating safe working conditions and a healthy work environment for all of their workers, and Partner must comply with all applicable health and safety regulations in the applicable geography, including but not limited to OSHA.

5. CONFLICTS AND RESPONSIBLE USE OF COMMUNICATIONS

Conflicts of Interest

A conflict of interest can occur when your organization’s activities, investments or associations compromises your ability to act in the best interests of our partnership. Under this Code, you are required inform your employees that they must avoid the types of situations that can give rise to conflicts of interest.

Under this Code, you must require that your employees disclose any relationships, associations or activities that could create actual, potential, or even perceived conflicts of interest to their manager or the Human Resources Department, and you in turn agree to promptly inform us.

External Communication on Behalf of SPG

You acknowledge and agree that you are not authorized to make any public statement or representations on behalf of SPG.

Use of Social Media

Social media provides opportunities to network and create exposure for your company and brand, as well as ours, but there are risks associated with employees’ use of social media platforms. Your employees are expected to be trained to not post anything on social media about SPG that is inaccurate, misleading, unfair, deceptive, obscene or offensive.

 

Employees are required to:

 

  • Reveal their relationship with your company as well as ours when commenting online about issues related to SPG.

  • Respect the privacy of other persons and refrain from publishing photos of them without their consent. This is especially applicable if your employee is posting anything about a SPG customer or other business partner. and

  • You must ensure any information that your employees post related to the company is accurate. You agree and acknowledge that you are responsible for the online conduct of your employees.

Your employees must not:

 

  • “Pretext” or “Catfish”, i.e., pretend to be someone they are not online.

  • Share confidential information about SPG, its clients, stakeholders or suppliers. or

  • Post comments or pictures that could harm SPG’s brand, reputation or commercial interests

6. CONFIDENTIALITY, PRIVACY AND SECURITY

Confidentiality

Except as may expressly allowed under our contract with your company, your company and your employees are required to maintain the confidentiality of all SPG proprietary information.

Proprietary information includes all non-public information that might be unlawful to disclose or otherwise harmful to SPG and its customers and\or other business partners if disclosed.

Confidential information can include, but may not be limited to:

 

  • Customer lists

  • Pricing information

  • Terms of contracts

  • Company policies and procedures

  • Information Security Protocols

  • Financial statements, data or records

  • Product development and marketing plans and strategies

  • Trade secrets

  • SPG employee information

  • Any other information that could damage SPG or its customers or suppliers if it was disclosed

Privacy

SPG is committed to ensuring the privacy of its customers, employees, and others (“SPG Stakeholders”). Partners are required to comply with all privacy laws and regulations. Partners must take appropriate precautions including administrative, technical, and physical measures to safeguard SPG Stakeholders’ personal information against loss, theft, and misuse, as well as unauthorized access, disclosure, alternation, and destruction. We require that our Partners do the same with their own employees and stakeholders. You are required to strictly adhere to the provisions of HIPAA, GDPR and all other applicable laws, rules, statutes and regulations that pertain to privacy matters.


We require that you ensure that your employees and contractors not disclose any private, personal information of:
 

  • SPG Employees

  • SPG Customers

  • SPG Suppliers

  • SPG Competitors

  • Other Third parties
     

This type of information includes but is not limited to names, addresses, health care information, phone numbers, addresses, email addresses, etc. You must require that your employees and contractors store all personal information securely, mark it as confidential and store it only for as long as it is needed for the purpose for which it was collected.
 

When providing personal information, your employees and contractors must limit access to only those with a clear business need for the information.
 

Your employees and contractors are required to report any breaches of privacy, including the loss, theft of or unauthorized access to personal information, to their manager, and in turn any such breach must be immediately reported to us, and you are required to take any and all steps that SPG may suggest to mitigate any damage or loss that SPG may incur as a result of the breach.

Information Technology

It is possible that you may be provided some IT equipment from SPG, such as a laptop computer. You may therefore have access to SPG company data that is stored on that equipment or may be accessed by that equipment. Your employees and contractors are required to help safeguard all computer equipment and data against malicious acts by individuals inside or outside the company. We require that you provided industry standard Cyber-security training to all employees and contractors to ensure compliance with computer security policies.

SPG Bookings Policy

If you are engaged in acting as a reseller or distributor of SPG’s products and services, you are required to be intimately familiar:
 

  • You are required to at all times fully comply with all applicable laws, rules, statutes and regulations pertaining to Export Control matters.

  • You may not supply SPG technology to any person or entity that is excluded under OFAC or any other applicable law or regulation.

  • Under no circumstances should you engage in or enter into any “side agreements” or commitments of any nature with any customers outside of the deliverables stated in the applicable purchase order. e.g, any agreements that call for different payment terms or software features or functionality that is not specified in the contract or quote.

  • You may not enter into any transaction for the provision of SPG technology or services unless\until you have a valid PO from the end user customer. and

  • Any and all information provided to SPG pursuant to the sale or licensing of our services or technology must be complete and fully accurate in all respects.

7. CORPORATE RESPONSIBILITY

The Environment

SPG is committed to reducing the environmental impact of our operations and expects you to share that commitment. You must conduct your operations in ways that are environmentally responsible and endeavor to reduce or eliminate waste, including water and energy, by implementing appropriate conservation measures in your facilities.

Business Controls

Partners must maintain effective business controls that are capable of preventing and detecting unlawful conduct by their employees and counterparties. An effective business controls program should contain the following: (i) periodic risk assessments that lead to adjustments in business controls that take into account the current risk environment. (ii) a commitment to legal compliance, ethics, environmental, occupational health and safety, commercial practices, and labor programs. (iii) a designated company representative(s) responsible for overseeing and implementing legal compliance, ethics, environmental, occupational health and safety, commercial practices, and labor programs. and (iv) clearly communicated mechanisms for employees to report misconduct or seek guidance without fear of retaliation.

Record Keeping

As a public company, SPG maintains accurate books and records, and as our Partner, we require that you keep your books, records, accounts and financial statements in a complete, accurate, understandable, detailed and timely manner.

 

All documents that pertain to SPG related business must be maintained for at least five (5) years or as required by law post date of transaction.

 

Your employees are required to, and your systems must be designed so as to:

 

  • Maintain these records for as long as required. 

  • Maintain official record keeping systems to retain and file records required for business, legal, financial, research or archival purposes. and

  • Your employees must be trained to never destroy documents in response to, or in anticipation of, an investigation or audit.

8. COMPLAINCE

Partner will comply with this Code, SPG’s policies, procedures, requirements and other Partner obligations as established by SPG from time to time located https://www.singlepointglobal.com/legal.

Ensuring Compliance and Process to Receive and Investigate Reports of Violations

Partner must have in place a process whereby its employees, independent contractors, consultants, and others who do business for or on behalf of Partner can safely and confidentially report violations of this Code to Partner’s management, and to do so anonymously (subject to local legal restrictions on anonymous reporting). Partner must promptly investigate any observed or reported violations of this Code.

Corrective Action Process

Partner must have a process for timely correction of any deficiencies or violations of this Code identified by any internal or external audit, assessment, inspection, investigation, or review.

Reporting

Partner must in good faith report any violations of this Code (whether such violations are your own, another Partner’s, or a SPG employee’s) by calling: +1 (703) 348-8415 IMMEDIATELY.

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