
Global Partner Code of Conduct
This Global Partner Code of Conduct applies to any Partner doing business with Geotab Inc. or any of its affiliates or subsidiaries worldwide. For this purpose of this policy, “Partner” refers to any person or entity with a business relationship with Geotab, including those that provide goods or services to Geotab, regardless of the type or absence of compensation for such goods or services, those who act as resellers of Geotab products and services, and those who otherwise participate in the Geotab products and services ecosystem (e.g. Geotab Marketplace Partners). “Worker” refers to any person a Partner compensates in any form or manner in exchange for performing labor or any other work.

Partner Compliance with Geotab’s Global Partner Code of Conduct
Applicable laws
At a minimum, Geotab’s Partners must comply with all applicable laws, regulations, legal directives and guidelines, and contract obligations they may have with us. For avoidance of doubt, in the event the terms of a contract between a Partner and Geotab conflict with this Code, the terms of the contract will prevail to the extent of the conflict.
Applicable policies
Certifications
Disclose information
Global sanctions
Partners must be familiar with and follow the export control laws and regulations of each of those countries in which Partner operates, together with the various export control laws and regulations of Canada and the United States. In particular, Partners will comply with the geographical and targeted sanctions regimes of the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC). Partners will ensure that they do not do business with any person or entity listed on OFAC’s Specially Designated Nationals (SDN) List or Consolidated Sanctions List, or with any other persons or entities as prohibited by applicable law.
Applicable obligations
Partner cooperation
Partners will cooperate with any information requests or audits that Geotab or our customers may initiate.
Labor and human rights

Modern Slavery
Geotab is committed to ensuring that no part of our business, including our supply chain, engages in or facilitates modern slavery or human trafficking. Accordingly, our Partners must ensure that they do not participate in or facilitate modern slavery or human trafficking. Read Geotab’s full Modern Slavery Statement here.
Freely chosen employment
As part of the hiring process, Partners are expected to give each worker a written agreement (or statement) describing the worker’s terms of employment in a language understood by the worker, and, if internationally relocating, the writing will be provided before the worker leaves their country of origin. Partners will integrate the following labor and wage standards into their business processes to provide workers with a law-abiding work environment:

Underage Labor
Wages
Working hours
Fair Treatment, non-discrimination, diversity and inclusion
Freedom of association and collective bargaining
No retaliation
Fair investigation
Information
Land and Water Rights
Partners will respect the legal and customary land, forest, and water rights of local communities, Indigenous Peoples, and others. Partners must ensure that any acquisition or use of land is based on free, prior, and informed consent, and they will not participate in or benefit from forced eviction or illegal land grabbing.
Health and safety

Occupational safety and health
Respect, Diversity and Non-discrimination
Workplace harassment
Emergency preparedness
Sanitation, food and housing
Environmental

Environmental permits and reporting
Resource efficiency and clean energy
Hazardous and restricted substances
Waste mitigation: wastewater, solid waste and stormwater management
Information
Ethics and compliance

Business integrity
Partners will maintain the highest level of business integrity in all interactions with Geotab and on behalf of Geotab. This includes a zero-tolerance policy for bribery, corruption, kickbacks, extortion, and embezzlement in any form. Partners will not engage in any activity that could result in improper advantages or the influence of business decisions through unlawful or unethical means. To ensure transparency and fairness, Partners will disclose any potential or actual conflicts of interest, particularly those involving family or close personal relationships with Geotab employees or representatives who may affect their business with Geotab. Business courtesies extended to Geotab employees or representatives must be modest, occasional, and should not influence or appear to influence business decisions. In dealings related to Geotab’s government sales or services for government end use, Partners must exercise extreme caution regarding business courtesies and will not offer, solicit, or accept any item of value that violates applicable law, regulation, or government ethics standards, or that could be construed as influencing or seeking to influence a government official or employee. Partners will conduct their business in strict compliance with all applicable anti-corruption laws and will implement effective monitoring and enforcement procedures to ensure compliance with such anti-corruption laws. Any allegations of corrupt practices or unethical behavior involving Partners or their employees, anywhere in the world, must be reported to Geotab without delay through Geotab’s Integrity Helpline. Furthermore, Partners will maintain accurate and truthful records of all business transactions to reflect their commitment to ethical business practices.
Intellectual property
Fair Competition and Anti-Trust
Partners must conduct all business activities in compliance with all applicable fair competition and anti-trust laws, including prohibitions on price-fixing, bid-rigging, market allocation, and abuse of dominant position.
Responsible materials sourcing and use
Privacy and information/cyber security
Geotab does not sell data that it processes from its customers, Partners or other third parties in such a manner that can identify the subjects of the data. Accordingly, Partners may not sell any third party data received or obtained during their relationship with Geotab and may not use any such third-party data without prior written authorization from Geotab. Partners will comply with all applicable laws and regulations and contract terms and conditions regarding privacy, data protection and information/cybersecurity. Further, Partners must read Geotab’s privacy policy and will not undertake any actions that cause Geotab to violate said policy. Partners shall notify Geotab without undue delay (e.g., within 24-72 hours or other time period specified by applicable legislation or regulation, if shorter) of any suspected or confirmed data breach or security incident that involves Geotab data or impacts the services provided to Geotab.
Accessibility
Information
Reporting Concerns
Geotab’s Integrity Helpline provides a confidential avenue for partners, customers, and employees to report ethical concerns.This channel may be used to report suspected misconduct, including fraud, bribery, or any actions that violate Geotab’s corporate values. Reports can be submitted online without a username or password, or you can speak with an operator over the phone in more than 150 languages.
Management system

The Partner’s quality management system must contain the following minimum elements:
2. Processes to identify, monitor, and comply with all applicable laws, regulations, standards, requirements, and contract terms and conditions,
3. Risk management processes,
4. Communications and training for all workers and lower tier Partners, as determined by Partners,
5. Ongoing assessments, monitoring and continued improvement, including corrective action processes.
References
Responsible Business Alliance Code of Conduct (previously known as the electronic industry citizenship coalition)
United Nations Guiding Principles on Business and Human Rights
United Nations Universal Declaration of Human Rights
Web Content Accessibility Guidelines (WCAG) 2.0, Level AA
General Accessibility
Workplace Hazardous Materials Information System (WHMIS)
United State Federal Acquisition Regulation (FAR) and Agency Supplements to the FAR