
Global Partner Code of Conduct
Geotab Inc. is committed to transparency, treating all people with respect and dignity, ensuring safe working conditions and conducting environmentally responsible and ethical operations. We expect Partners in our operations and supply chain, and their Partners at all tiers, to embrace the following social, environmental and ethical responsibilities with equal enthusiasm for transparency. Geotab reserves the right to require its Partners to provide proof of their compliance with the requirements set out in this document.
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
All Partners must adhere to the following requirements in order to maintain a partnership with Geotab:
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 of a conflict in any contract between a Partner, Geotab and this Code, the contract will prevail.
Applicable policies
Partners accessing or using Geotab’s property, facilities, information technology (IT) systems or other assets will comply with all of our applicable policies and requirements as communicated by Geotab at the time of onboarding.
Certifications
If Geotab requires certifications by third parties for various reasons to manage health, safety and auditability, such as ISO 50001, 14001 or OHSAS 18001, Partners will promptly obtain such certifications or provide reasonable timelines to compliance.
Disclose information
Partners will accurately and completely disclose information regarding their labor, employment, health and safety, environmental practices, business activities, organizational structure, financial situation and contract performance, at least annually and promptly upon Geotab’s request.
Global sanctions
Partners must be familiar with and follow the rules of global sanctions, and be aware of the sanctions’ impact on their business. 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
Partners will identify, understand and comply with all applicable obligations related to importing and exporting, including customs laws and regulations. Partners must understand and comply with all applicable requirements to obtain licenses to export goods, services or technologies.
Partner cooperation
Partners will cooperate with any information requests or audits that Geotab or our customers may initiate. Though Geotab seeks to work cooperatively with Partners to resolve issues, we may terminate our relationship with any Partner that fails to comply with this Code.
Labor and human rights
Geotab is committed to upholding the human rights of workers and treating persons with dignity and respect. This applies to all workers, including temporary, migrant, student, contract, direct employee and any other type of worker. As a result, Partners must manage their own workforce in a manner which adheres to the following:

Modern Slavery
Freely chosen employment
Partners will not use or permit any form of forced, bonded or indentured labor. All work must be voluntary, and all workers must be free to terminate their employment at any time. Partners will not hold workers’ identity, immigration or work permit documents longer than reasonably necessary for administrative processing. Partners will not require workers to pay recruitment fees or other fees for their employment, either directly or through third parties, and will repay any worker who has paid such fees. Partners will not unreasonably restrict workers’ freedom to move into, out of, or within working facilities, except where role-based access and privacy/security controls mandate restricted access.
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
Health and safety
Geotab is committed to ensuring a safe and healthy work environment. Partners will integrate the following health and safety management requirements into their business processes to provide workers with a healthy and safe work environment:

Occupational safety and health
Respect, Diversity and Non-discrimination
Workplace harassment
Emergency preparedness
Sanitation, food and housing
Information
Environmental
Geotab recognizes that environmental responsibility is integral to producing world-class products. In manufacturing operations and construction, Partners will strive to create regenerative processes and work to minimize adverse effects on the community, environment and natural resources while safeguarding the health and safety of the public. Partners will integrate the following green standards into their business processes:

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
Partners will uphold the highest standards of ethics to promote honesty and integrity in their business dealings and operations. Partners will adopt policies and procedures that integrate the following principles of business ethics into their processes:

Business integrity
Intellectual property
Responsible materials sourcing and use
Privacy and information/cyber security
Accessibility
Information
Management system
Partners will adopt or establish a management system to carry out the responsibilities set out in this Code. The management system will be designed to ensure that Partners’ operations: (a) comply with Geotab requirements, contract terms and conditions and applicable laws and regulations; (b) conform to these responsibilities; and (c) identify and mitigate operational risks related to these responsibilities. Partners’ management systems should also facilitate continuous improvement. Partners will provide Geotab with information evidencing that their management systems meet the requirements of this Code at least annually and promptly upon request.

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
This Global Supplier Code of Conduct is based on Geotab’s Core Values and the following:
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