Social Responsibility

Vendor Code of Conduct

We have established a Vendor Code of Conduct to ensure our vendors are aware of and meet our business expectations related to legal requirements, ethical practices, human rights, and environmental management. Compliance with the Code is an expectation of doing business with Consolidated Communications, as it defines the non-negotiable minimum standards to which we ask our vendors and suppliers and their sub-tier suppliers or sub-contractors to respect and adhere.

Consolidated Communications Vendor Code of Conduct

Consolidated Communications, Inc. and its affiliates (collectively, “Consolidated”) seeks to be the preferred choice for communications solutions by delivering a better customer experience and investing in our people and technology. Our mission is to turn technology into solutions, connect people and enrich how they work and live. Consistent with our goals, we have established this Vendor Code of Conduct (this “Code”) to make certain that all of our vendors are aware of and meet our business expectations related to legal requirements, ethical practices, human rights, and environmental management. These standards are based on our own Company policies, including Consolidated’s Code of Business Conduct and Ethics and Human and Labor Rights Policy, our corporate values and established international standards, including the International Labor Organization (ILO), the United Nations Universal Declaration of Human Rights, and industry best practices.

Compliance with these standards is an expectation of doing business with Consolidated, as this Code defines the non-negotiable minimum standards to which we ask our vendors and suppliers and their sub-tier suppliers or sub-contractors (each, a “vendor” and collectively “vendors”) to respect and adhere.

Consolidated seeks out vendors with a shared commitment to transparency, collaboration, and mutual respect. We acknowledge that our vendors operate pursuant to their own mission and values. With that said, the conduct of our vendors reflects on our reputation and the level of trust we have worked hard to earn from our partners and customers. We appreciate that our vendors operate in a variety of legal, geographical, and cultural environments, but we expect all vendors to comply and strive to exceed the standards of this Code.

The provisions of this Code are in addition to, and not in lieu of, the terms, conditions or provisions of any legal agreement or contract, including any purchase order or other business arrangement between a vendor and Consolidated.


Business Conduct and Ethics

Consolidated is committed to the highest standards of legal and ethical business conduct.  We place the highest value on the integrity of our directors, officers and employees and demand the same level of integrity of our vendors in all business transactions. We insist on ethical dealings with others and on the ethical handling of actual or apparent conflicts of interest within personal and professional relationships. We do not tolerate any practice that is inconsistent with the principles of honesty, integrity and fairness, anywhere we or our vendors do business. We require that our vendors observe and comply with requirements in the following areas:

  1. Compliance with Law

The business activities of vendors shall comply with all applicable laws and regulations in the countries and jurisdictions in which they operate. This Code applies to activities in the locations where a vendor’s goods are produced and where any related services are performed.

  1. Bribery

Any and all forms of bribery, kickbacks, corruption, extortion or embezzlement are prohibited and vendors shall ensure that adequate procedures are in place at all times to prevent bribery in any commercial dealing undertaken by the vendor, its affiliates or their respective agents.

  1. Conflicts of Interest

Vendors shall disclose to Consolidated any situation that may appear to be a conflict of interest, and are required to avoid conduct that may result in a conflict of interest. Vendor relationships that affect, or appear to affect, the impartiality of our employees’ judgment are prohibited. Consolidated and the vendor may not give or exchange gifts of more than nominal value.

  1. Freedom of Association and Collective Bargaining

Vendors shall respect the legal rights of workers to associate or not to associate with any group, or join or not join trade or labor unions or other organizations, as permitted by and in accordance with all applicable laws and regulations. Vendors should develop and fully implement effective grievance mechanisms which resolve internal industrial disputes, employee complaints, and ensure effective, respectful and transparent communication between employees, their representatives and management.

  1. Intellectual Property and Confidentiality

Vendors shall respect the intellectual property rights of those with whom the vendor does business and competitors. Vendors shall implement processes to protect confidential and proprietary information or trade secrets of Consolidated and others, and shall use such information only for authorized purposes. Any vendor, including its employees and agents, in possession of Consolidated’s confidential and proprietary information must take the necessary steps to protect and safeguard this information. If a vendor mistakenly receives confidential and proprietary information of Consolidated, the vendor must immediately return the information to the Consolidated point of contact. Disclosure or distribution of our confidential and proprietary information without Consolidated’s express permission is a violation of this Code.

  1. Political Contributions and Lobbying

Vendors shall not contact federal or state legislators, regulatory officials or their offices, or make political contributions or conduct lobbying efforts on behalf of Consolidated.


Human Rights

Consolidated requires our vendors to conduct business in a manner that respects human rights, consistent with requirements in the following areas:

  1. Voluntary Labor

A vendor’s employees shall work on a voluntary basis without the threat of violence, criminal penalty, harassment or restrictions on freedom of movement. Vendors shall not use any prison, slave, bonded, forced, indentured, or debt induced labor, or engage in any other forms of compulsory labor, or any other forms of slavery or human trafficking.

  1. Minimum Age

Under no circumstances shall a vendor employ workers under the minimum age for work or mandatory schooling as specified by local law. Young workers shall not engage in employment that is mentally, physically, socially or morally dangerous or harmful. Employment shall not interfere with the worker’s education or compromise enrollment and engagement in school.

  1. Employment Practices

Vendors shall only employ workers who are legally authorized to work in their facilities and are responsible for validating workers’ eligibility to work through appropriate documentation. All work shall be voluntary, and workers shall be free to leave work or terminate their employment upon reasonable notice.

  1. Migrant Labor

Vendors should recognize the unique legal, social, and cultural situations that migrant workers face and shall ensure that such workers are treated with dignity, respect, and in accordance with the same standards that apply to other workers.

  1. Privacy

A vendor shall respect the privacy rights of its workers whenever it gathers private information or implements worker monitoring practices.


Fair and Equal Treatment

Consolidated believes employees should have an equal chance to succeed based on hard work, talent, and commitment, and should always be treated with fairness and respect.  We expect our vendors to adhere to requirements in the following areas:

  1. Discrimination and Harassment

All workers shall be treated with respect and dignity. No worker shall be subject to any physical, sexual, psychological, or verbal harassment or abuse, or other form of intimidation. There shall be no discrimination in employment, including hiring, compensation, advancement, discipline, termination or retirement. Discrimination based on race, color, religion, sex, age, national origin, disability or any other factor prohibited by law shall be prohibited. In particular, attention shall be paid to the rights of workers most vulnerable to discrimination. Vendors shall not conduct medical tests on workers that could be used to discriminate (e.g. pregnancy testing) and the results of any tests that are required by applicable law shall not be used in a discriminatory way.

  1. Grievance Mechanism

Vendors shall provide all workers with transparent, fair, accessible and confidential procedures that result in swift, unbiased and fair resolution of difficulties which may arise as part of their working relationship.  Workers shall be protected from retaliation for submitting such complaints.

  1. Diversity

Consolidated expects vendors to demonstrate a diverse workforce composition, and embrace variation in workforce race, color, religion, sex, gender identity or expression, sexual orientation, national origin, marital status, familial status, genetics, disability, age or veteran status.  Vendors should also promote supply chain inclusion throughout their own supply chains.

  1. Transportation

Vendors shall collaborate with workers to ensure adequate access to necessary services. Any transportation provided by a vendor or agent on vendor’s behalf must be safe and in compliance with legal requirements.

  1. Community

Vendors shall ensure due diligence is undertaken to uphold individual, community or indigenous people’s established rights to property and land.


Benefits, Compensation and Hours

Consolidated expects vendors to provide workers with fair and equal compensation for hours worked, ensure that all work is conducted on a voluntary basis, and adhere to the following:

  1. Wages and Benefits

Vendors shall pay workers promptly and on time, in accordance with legal requirements, and in the name of the individual or entity performing the work. Workers shall be provided with a total compensation package that includes wages, overtime pay, benefits and paid leave which meets or exceeds the minimum legal standards. Workers shall be compensated for overtime hours at the rate legally required in the country of manufacture or performance, and in those countries where such laws do not exist, at a rate at least equal to the regular hourly compensation rate. Compensation terms established by legally binding collective bargaining agreements are to be implemented and adhered to without bias.

  1. Working Time and Rest Days

Vendors shall ensure that work is done in compliance with all applicable laws and industry standards pertaining to regular working hours, and overtime hours, including breaks, rest periods, holidays, and maternity and paternity leaves. Any overtime worked shall be voluntary and compensated fairly. Vendors shall complete expense reports and time reporting accurately and completely and shall not intentionally make a payment or approve an invoice, expense report or other document that is incorrect, misleading or inaccurate.

  1. Living Wage

Vendors shall ensure that workers are provided a living wage, sufficient to meet basic needs for workers and their entitled dependents.


Health and Safety

Consolidated expects a vendor’s operations, facilities, and procedures to protect and promote worker health and safety, consistent with the occupational health and safety requirements under law and as set forth in Consolidated’s Human and Labor Rights Policy, as well as the following:

  1. Workplace Environment

Vendors shall provide workers with a safe and healthy working environment. At a minimum, potable drinking water, adequate lighting, temperature, ventilation, sanitation facilities, and personal protective equipment shall be provided along with equipped work stations.  In addition, facilities shall be constructed and maintained in accordance with the standards set by applicable laws and regulations.

  1. Hazardous Materials and Product Safety

Vendors shall identify hazardous materials, chemicals and substances, and ensure their safe handling, movement, storage, recycling, reuse and disposal.Vendors shall comply with material restrictions and product safety requirements set by applicable laws and regulations.Vendors shall ensure that key workers are aware of and trained in product safety practices.

  1. First Aid

Vendors shall establish and maintain appropriate first aid equipment at facilities and make first aid equipment available to workers at all times. The location of the equipment shall be prominently marked and communicated to workers. Vendors shall maintain records of health and safety training and accidents and injuries at the workplace.

  1. Emergency Preparedness

Vendors shall be prepared for emergency situations. This includes worker notification and evacuation procedures, emergency training and drills, appropriate first-aid supplies, appropriate fire detection and suppression equipment, and adequate exit facilities. Vendors shall regularly train workers on emergency planning, responsiveness and medical care.

  1. Housing Conditions

If a vendor provides housing it must be voluntary or complementary. Dormitory facilities shall be clean and safe and constructed and maintained in accordance with applicable laws. There shall be clean toilet facilities, access to potable water, and sanitary food preparation and storage facilities. Dormitory facilities shall also provide workers with reasonable personal space, adequate heat and ventilation and clean shower and bathrooms.


Environmental Management

Consolidated requires vendors to comply with all applicable legal environmental requirements and demonstrate continual improvement of its environmental performance, including adherence to the following:

  1. Environmental Permits and Reporting

Vendors shall make sure that they obtain, keep current, and follow the reporting guidelines of all required environmental permits and registrations.

  1. Resource Consumption, Pollution Prevention and Waste Minimization

Vendors shall optimize their consumption of natural resources, including energy and water. Vendors shall implement and demonstrate sound measures to prevent pollution and minimize generation of solid waste, wastewater and air emissions. Prior to discharge or disposal, vendors shall characterize and treat wastewater and solid waste appropriately and according to applicable laws and regulations.

  1. Measurement and Monitoring

Vendors shall monitor their energy and natural resource usage, emissions, discharges, carbon footprint and disposal of wastes, and take a progressive approach to minimize negative impacts on the environment. Consolidated reserves the right to audit a vendor’s and its supply chain environmental management activities and the environmental impact of those activities.


Communications and Reporting

Vendors shall take appropriate steps to ensure the principles of this Code are communicated to their workers. Vendors shall also take appropriate steps to ensure the following principles of this Code are adopted and applied by their workers, suppliers, agents, and contractors.

  1. Books and Records

Vendors shall maintain accurate, transparent and up-to-date books, records and accounts to demonstrate compliance with this Code and applicable laws. Vendors shall not make false, artificial or misleading entries or omissions in any system, book or record for any reason.

  1. Audits and Assessments

Consolidated reserves the right to review a vendor’s books and records and business practices, including product safety and quality, in order to audit compliance with this Code. Such audits shall be conducted by Consolidated or its designated agent in a reasonable manner and scope that will allow Consolidated to ensure compliance. If an audit identifies a violation of this Code, vendors shall act promptly to correct the situation to our reasonable satisfaction, with a corrective action plan.

  1. Reporting

Vendors are responsible for prompt reporting of actual or suspected violations of law, this Code, and any contractual relationship with Consolidated. This includes violations by any worker or agent acting on behalf of either the vendor or Consolidated.

  1. Origin

Vendors shall be capable of disclosing primary origin of all goods and services. Consolidated reserves the right to ask vendors to create supply chain mapping back to origin to facilitate assessment of upstream supply chain compliance.

  1. Import and Export Compliance

If a vendor is responsible for the import or export of goods, software or technology, the vendor must be aware of all applicable laws, be in compliance with such laws and obtain the appropriate import and export licenses when shipping controlled goods, technology or software. Vendors must make accurate declarations and shall not mischaracterize the value or nature of the goods in any way that will create liability for Consolidated.