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Supplier Code of Conduct

At Springtime, we are committed to building and maintaining responsible partnerships based one trust, compliance, and information security. This Supplier Code of Conduct sets forth the minimum requirements all suppliers, service providers, and subcontractors (“Suppliers”) must meet in any engagement with Springtime.

This Supplier Code of Conduct is a binding element of all contracts and governs the business relationship between Springtime and its Suppliers.

1) Legal and Regulatory Compliance

Suppliers shall fully comply with all applicable national and international laws, including but not limited to those related to:

  • IT and cybersecurity
  • Data protection (e.g., GDPR, CCPA, or relevant regional laws)
  • Intellectual property
  • Export control regulations (including dual-use technologies)
  • Labor and human rights
  • Anti-bribery and anti-corruption laws (e.g., UK Bribery Act, FCPA)

2) Business Ethics and Integrity

The highest standard of integrity is expected in all our business dealings. All forms of corruption, extortion, bribery (including facilitation payments), and embezzlement are strictly prohibited and may result in immediate termination and legal action:

  1. Suppliers shall not practice or tolerate any form of corruption, extortion, embezzlement or money laundering. Suppliers shall not offer or accept bribes or other unlawful incentives (e.g., ‘facilitation payments’) to or from their business partners or government officials as stated in the United Nations Convention against Corruption. Suppliers shall not offer to Springtime employees any kind of gifts or personal benefit which could be perceived as a bribe. In all cases, gifts or entertainment shall not be offered to improperly influence a business relationship and must not violate applicable laws or ethical standards.
  2. Suppliers shall disclose to Springtime any situation that could constitute a conflict of interest, such as Springtime employees having professional, private and/or significant financial advantages or interests in any of the supplier’s businesses.
  3. Suppliers will conduct their business in line with fair competition and in accordance with all applicable anti-trust laws. Suppliers shall not share or exchange any prices, costs or other competitive information, or undertaking of any collusive conduct with any other third party to Springtime with respect to any proposed, pending or current Springtime procurement.
  4. Suppliers must comply with all applicable trade control laws and regulations in the import, export, re-export or transfer of goods and services (including software and technology). All invoices and any customs or similar documentation submitted to Springtime or governmental authorities in connection with transactions involving Springtime must accurately describe the goods and services provided and the price thereof.
  5. The supplier undertakes to comply with all trade and other regulatory provisions applicable to them and relevant for the performance of the contractual services. In particular, the supplier confirms that all required notifications, permits, registrations, or other official certificates necessary for the lawful performance of the services have been duly obtained and will be maintained throughout the term of the contract.
  6. Suppliers must:
    • respect and protect all intellectual property and confidential information belonging to Springtime;
    • not use, copy, disclose, or share proprietary materials or source code without explicit written authorization;
    • ensure employees and contractors are bound by confidentiality obligations.
  7. Suppliers will use only subcontractors or other third parties who comply with all applicable laws and regulations, and who adhere to the same (minimum) standards set forth in this Supplier Code of Conduct.

3) Sustainability

Springtime values environmental awareness. Suppliers are encouraged to demonstrate a clear understanding of the environmental risks, impacts and responsibilities associated with the products and services they provide:

  1. Suppliers shall make all reasonable efforts to protect the environment, and to minimize any negative environmental impact of its activities. Suppliers shall comply with all applicable environmental laws and regulations, as well as any reasonable Springtime requirements regarding the prohibition, restriction, labelling for recycling or disposal of specific substances.
  2. Suppliers shall obtain, maintain, and comply with all environmental permits, licenses and registrations necessary for its operations.
  3. Suppliers shall monitor, control, minimize and appropriately treat emissions and pollutants (to air, soil, and water) and other waste generated from its operations.
  4. Suppliers shall strive to continuously reduce the carbon footprint of its operations through actions such as improving energy efficiency, sourcing renewable energy, and eliminating, reducing, and recycling waste. The handling, storage, movement, treatment and disposal of all waste must be carried out in accordance with applicable regulations and in an environmentally responsible manner.
  5. Suppliers shall have an appropriate, structured, and systematic approach to managing its environmental responsibilities that includes, if applicable, establishing a suitable environmental management system.
  6. Suppliers should consider the environmental credentials and performance of vendors within their own supply chain and require them to operate to a minimum set of standards.

4) Human Rights and Social Responsibility

Policies should be in place to confirm the supplier’s commitment to the following points and improvement programs should be in place where relevant.

In addition to the above minimum requirements, the supplier shall define a minimum standard of human rights that applies across all jurisdictions and demonstrate how compliance to this is encouraged and observed. Such standards should refer to, at a minimum, the UN Guiding Principles on Business and Human Rights.

4.1) Human Rights

  1. Suppliers are expected to respect internationally recognized human rights, including those set out in the International Bill of Human Rights, the UN Guiding Principles on Business and Human Rights, and the principles set out in the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work.
  2. Suppliers must ensure that people are employed based on the principle of equal opportunity and without distinction to race, color, gender, religion, affiliation, or origin.
  3. Suppliers shall not use workers under the age of 15 or under the local legal minimum age for work or mandatory schooling age, whichever is higher. No young worker shall do work that is mentally, physically, socially or morally dangerous or harmful or interferes with their schooling by depriving them of the opportunity to attend school. Suppliers should also ensure that working hours for those of school age are not exceeding the maximum hours on a school day.
  4. Suppliers shall under no circumstances use forced labor (including trafficked, indentured, or bonded labor) or contract with subcontractors or suppliers using child labor or forced labor. Mental and physical coercion, slavery and human trafficking are prohibited. A demonstration of reasonable modern slavery due diligence in the supply chain is necessary.
  5. Springtime’s suppliers shall treat their employees with respect and dignity. Any discrimination based on partiality or prejudice is prohibited. This includes discrimination based on ethnicity, gender, sexual orientation, marital status, pregnancy, parental status, religion, etc. Threats of violence, corporal punishment, physical or verbal abuse, or other unlawful harassment are strictly prohibited.
  6. Suppliers must pay workers at least the minimum compensation required by local law and provide all legally mandated benefits. In addition to payment for regular hours of work, workers must be paid for overtime. All work should be voluntary on the part of the employee.
  7. Suppliers are expected to operate in consideration of the International Labour Organisation (ILO) standards regulating working, resting hours, maximum consecutive days of work and annual leave. Hours worked beyond the normal work week shall be voluntary and suppliers must provide a rest period of at least 24 consecutive hours in every seven day period to all their employees.
  8. All employees should be provided with a written employment contract setting out their terms and conditions in accordance with the local relevant legal jurisdiction. We expect all employment and the termination of employment to be carried out in a fair manner.

4.2) Anti-Discrimination and Anti-Harassment

  1. Suppliers shall treat their employees in a fair and equal manner.
  2. Suppliers shall not discriminate in the hiring, compensation, promotion, discipline, termination, or retirement of employees based on gender, gender identity, age, religion, marital status, sexual orientation, disability, social class, political opinion, or national or ethnic origin, or any other characteristic that does not relate to the individual’s qualifications or the inherent requirements for the job. Suppliers will be required to meet the requirements of any applicable discrimination legislation.
  3. Suppliers shall treat their employees with dignity and respect and shall ensure that no worker is subject to any physical, sexual, psychological or verbal harassment, abuse or other form of intimidation.
  4. Suppliers shall make available to all workers within their operations and supply chain a mechanism for which grievances relating to labor practices can be anonymously raised, without fear of retribution. Suppliers shall investigate and take appropriate action to remedy all grievances raised.
  5. Springtime expects suppliers to have a policy in place to consider usability by, and inclusion of, individuals with disabilities when designing products and/or delivering services to Springtime. As part of the policy, there are accessibility standards and/or processes in place that conform to disability guidelines when suppliers are designing products and/or delivering services.
  6. Springtime expects suppliers to have a policy that explicitly bans discrimination/bullying and harassment based on sexual orientation, race, gender or gender identity/expression. In addition, suppliers are also encouraged to have evidence of diversity and inclusiveness training that is inclusive of sexual orientation and gender identity/expression.
  7. Springtime expects suppliers to have equivalent policies to promote diversity in their supply chains and purchase from diverse businesses. Suppliers agree to make a reasonable effort to utilize diverse suppliers and provide evidence to Springtime upon request.

4.3) Health and Safety

  1. Suppliers shall protect workers from over exposure to chemical, biological and physical hazards, and physically demanding tasks in the workplace. Appropriate health and safety information, training and equipment shall be provided to the supplier’s employees.

  2. Suppliers shall also have appropriate safety programs in place covering at least human safety, emergency preparedness and exposure to dangerous chemicals, biological substances, epidemics and pandemics.

4.4) Freedom of Association

  1. In conformance with local laws in the countries where we have employees, we respect the right of all employees to freedom of association with others, including the right to bargain collectively and respect the right of employees do decide not to.

  2. We value employees openly communicating ideas and concerns regarding their working conditions.

5) Information Security and Data Protection

As an essential component of our Information Security Management System (ISMS), we emphasize safeguarding information, ensuring system integrity, and maintaining business continuity. Suppliers play a critical role in upholding these standards.

5.1) Secure Handling of Data and Systems

The supplier shall comply with all applicable data protection laws and regulations, including, but not limited to, the General Data Protection Regulation (GDPR). This requirement applies particularly to the processing of personal data related to customers, consumers, employees, or other stakeholders. The supplier is responsible for ensuring that personal data is collected, stored, processed, transmitted, used, or deleted in a lawful and secure manner.

To ensure the confidentiality, integrity, and availability of Information entrusted to them, both during and after their engagement with Springtime, the supplier is expected to align their information security practices with internationally recognized standards, such as ISO/IEC 27001, or adopt equivalent best practices that achieve comparable levels of security and control. The measures implemented should be appropriate to the sensitivity, value, and criticality of the data handled throughout its lifecycle.

Suppliers are encouraged to:

  • Handle confidential information with due care and use it only for its intended purpose.
  • Fulfill all contractual obligations related to data protection and information security.
  • Avoid disclosing non-public or proprietary information to third parties without prior written approval from Springtime.


Upon request, suppliers must provide documentation that demonstrates their adherence to information security practices without undue delay. This may include but is not limited to certifications (e.g., ISO/IEC 27001), independent audit reports (e.g., SOC 2), penetration test results, or other evidence of compliance with relevant security standards.

5.2) Reporting Information Security Incidents

Suppliers are expected to report, without undue delay, any actual or suspected information security incidents that could impact Springtime’s data, systems, or operations. For the purposes of this Supplier Code of Conduct, an “information security incident” includes any unauthorized access, disclosure, alteration, loss, or destruction of information, or any event that could compromise the confidentiality, integrity, or availability of Springtime’s data or systems.

Incident reports should include:

  • A detailed summary of the incident and its potential impact.
  • Actions taken to contain and mitigate the situation.
  • Proposed measures to prevent recurrence of similar events.


Springtime encourages suppliers to cooperate fully in investigating and remediating such incidents, ensuring that appropriate corrective actions are implemented. Transparent and timely communication regarding security incidents is essential to preserve trust and minimize potential risks.

5.3) Secure Development and Maintenance

Suppliers involved in software development, cloud infrastructure, or integration are expected to:

  • Follow secure coding practices (e.g., OWASP Top 10).
  • Use up-to-date, licensed components and frameworks.
  • Avoid hardcoded credentials and implement effective secrets management.
  • Conduct regular code reviews, automated testing, and security scans to identify and remediate vulnerabilities.

6) Governance and Management Systems

6.1) Incident Reporting and Response

Suppliers must:

  • Report any actual or suspected data breach, system compromise, or security incident that may impact Springtime within 24 hours of discovery.
  • Cooperate fully with investigations and remediation efforts.
  • Maintain records of incidents and corrective actions taken.

6.2) Monitoring, Audits, and Enforcement

Springtime reserves the right to verify compliance through:

  • Self-assessment questionnaires
  • Documentation requests (e.g., security certifications or risk assessments)
  • On-site or virtual audits, where appropriate


Non-compliance with this Supplier Code of Conduct may result in contract termination, legal action, or disqualification from future business opportunities.

6.3) Use of Subprocessors and Subcontractors

  1. If Suppliers use the services of subprocessors, Suppliers will ensure that they will also conclude a corresponding agreement matching the level of protection of the regulations made in this agreement to ensure information and IT security.
  2. At Springtime’s request, Suppliers will provide the essential content of these agreements.
  3. Suppliers are also obliged to regularly check compliance with these agreements, to document the results of this check and to provide them Springtime on request.

6.4) Continuous Improvement

  1. Suppliers shall demonstrate their commitment to continuous improvement of the standards set forth in this Supplier Code of Conduct by setting performance objectives, executing implementation plans and taking necessary corrective actions for deficiencies identified by internal or external assessments, inspections and management reviews.

7) Acknowledgement and Binding Nature

By engaging in any business relationship with Springtime, the Supplier acknowledges and accepts this Supplier Code of Conduct as an enforceable part of the contractual relationship. It applies to the Supplier’s employees, subsidiaries, and approved subcontractors.