UNIVERSITY OF PITTSBURGH POLICY 05-02-18
CATEGORY: FINANCIAL AFFAIRS
SUBJECT: Supplier Code of Conduct
EFFECTIVE DATE: November 1, 2011 Revised
This policy establishes a code of conduct for current and potential University suppliers.
The University of Pittsburgh is committed to conducting its business in an ethical, legal and
socially responsible manner. The University expects its suppliers to share this commitment
and, therefore, has established this Supplier Code of Conduct. Although there may be
different legal and cultural environments applicable to its suppliers, University suppliers
must meet the following minimum requirements in order to do business with the University.
III. SUPPLIER CODE OF CONDUCT
Compliance with Laws, Regulations and Published Standards
University suppliers must comply with all applicable laws, codes or regulations of the
countries, states and localities in which they operate. This includes, but is not limited to,
laws and regulations relating to environmental, occupational health and safety, and labor
practices. In addition, University suppliers must require their suppliers (including
temporary labor agencies) to do the same. University suppliers must conform their
practices to any published standards for their industry.
University suppliers shall comply with all environmental laws and regulations applicable to
their operations worldwide. Such compliance shall include, among other things, the
- Obtaining and maintaining environmental permits and timely filing of required reports
- Proper handling and disposition of hazardous materials
- Monitoring, controlling and treating discharges generated from operations
Occupational Health and Safety Practices
University suppliers shall provide their employees with a safe and healthy working
environment in order to prevent accidents and injury to health arising out of, linked with,
or occurring in the course of work or as a result of the operation of the supplier. Suppliers
shall, among other things, provide:
- Occupational health and safety training
- A system for injury and illness reporting
- Medical treatment and/or compensation to injured/ill workers arising as a result of
working for supplier
- Machine safeguarding and other protective measures to prevent injuries/illnesses
- Clean and safe facilities
The University expects its suppliers to adopt sound labor practices and treat their workers
fairly in accordance with local laws and regulations. In addition, suppliers must comply
with the following standards:
- Freely Chosen Employment. Suppliers shall not use any forced labor, whether in the
form of prison labor, indentured labor, bonded labor or otherwise.
- No Child Labor. Suppliers shall comply with local minimum working age laws and
requirements and not employ child labor.
- Minimum Wages. Suppliers shall provide wages for regular and overtime work and
benefits that meet or exceed legal requirements.
- Working Hours. Suppliers shall not require workers to work more than the maximum
hours of daily labor set by local laws.
- No Harsh, Inhumane Treatment or Abuse. Suppliers shall treat each employee with
dignity and respect. In no event shall Supplier’s workers be subject to threats of
violence, physical punishment, confinement or other form of physical, sexual,
psychological or verbal harassment or abuse.
- No Discrimination. Suppliers shall not discriminate in its employment practices on the
basis of race, color, religion, sex, age, physical disability, national origin, creed or any
other basis prohibited by law.
- Freedom of Association. Suppliers shall recognize and respect the rights of its workers
to organize in labor unions in accordance with local labor laws and established practices.
Ethical Business Practices
Suppliers shall conduct their businesses in accordance with the highest standards of
ethical behavior and in accordance with applicable laws and regulations. Suppliers are
expected to conform to these requirements in each of the following areas:
- Fair Trade Practices. Suppliers shall not engage in collusive bidding, price fixing, price
other unfair trade practices in violation of antitrust laws.
- Bribery, Kickbacks and Fraud. No funds or assets of the supplier shall be paid, loaned
or otherwise disbursed as bribes, "kickbacks", or other payments designed to influence
or compromise the conduct of the University.
- Foreign Corrupt Practices Act. While laws and customs vary throughout the world, all
suppliers must comply with foreign legal requirements and United States laws that apply
to foreign operations, including the Foreign Corrupt Practices Act. The Foreign
Corrupt Practices Act generally makes it unlawful to give anything of value to foreign
government officials, foreign political parties, party officials, or candidates for public
office for the purposes of obtaining or retaining business. See Policy Attachment A for
definitions, scope, and detailed policy requirements related to compliance with the Foreign
Corrupt Practices Act.
- University Policies and Procedures. Suppliers must comply with the University’s
published policies and procedures, including, but not limited to, the University’s Conflict
of interest and Procurement Relationships and Code of Ethics policies
- Intellectual Property Rights. Suppliers shall respect the intellectual property rights of
others, especially the University, its affiliates and business partners. Suppliers shall
take appropriate steps to safeguard and maintain confidential and proprietary
information of the University and shall use such information only for the purposes
specified for use by the University. Suppliers shall observe and respect all University
patents, trademarks and
copyrights and comply with all requirements as to their use
as established by the University. Suppliers shall not transmit confidential or proprietary
information of the University via the internet unless such information is encrypted in
accordance with minimum standards established by the University.
Export Sanctions/Terrorism Activities
University suppliers must abide by all economic sanctions or trade embargoes that the
United States has adopted, whether they apply to foreign countries, political organizations
foreign individuals and entities.
Suppliers should not directly or indirectly engage in or support any terrorist activity. Neither
suppliers nor any of their affiliates, nor any officer or director of the supplier or any of its
affiliates, should be included on any lists of terrorists or terrorist organizations compiled by
the United States government or any other national or international body, including but not
limited to: (i) the U.S. Treasury Department’s Specially Designated Nationals List, (ii) the
U.S. State Department’s Terrorist Exclusion List, (iii) the United Nations List Pursuant to
Security Council Resolution 1390 (2002) and Paragraphs 4(B) or Resolution 1267(1999)
and 8(C) of Resolution 1333 (2000), and (iv) the European Union List Implementing
Article (2)(3) of Regulation (EC) No. 2580/2001 on Specific Restrictive Measures Directed
Against Certain Persons and Entities with a View to Combating Terrorism.
Solicitations by Suppliers
All suppliers shall comply with all guidelines issued by the University relating to access to
University facilities, offices and departments, and employees. No Supplier shall use the
University’s computer system, including its electronic mail system and internet site, for the
purpose of sending unsolicited electronic mail messages to the University community.
Suppliers must receive prior written authorization from the University’s Purchasing
Department to hold trade shows, demonstrate products, utilize University resources (i.e.,
bulletin boards), or make unsolicited calls on University departments.
Monitoring and Compliance
Suppliers shall conduct audits and inspections to insure their compliance with this Supplier
Code of Conduct and applicable legal requirements. If a supplier identifies areas of non-
compliance, the supplier agrees to notify the Purchasing Department as to its plans to
remedy any such non-compliance.
The University or its representatives may engage in monitoring activities to confirm
Supplier’s compliance to this Supplier Code of Conduct, including on-site inspections of
facilities, use of questionnaires, review of publicly available information, or other measures
necessary to assess supplier’s performance.
Any University supplier or University employee that becomes aware of violations of this
policy is obligated to notify the Purchasing Department. Based on the assessment of
information made available to the University, the University of Pittsburgh reserves the
right (in addition to all other legal and contractual rights) to disqualify any potential supplier
or terminate any relationship with any current supplier found to be in violation of this
Supplier Code of Conduct without liability to the University.
This Supplier Code of Conduct is a general statement of the University’s expectations with
respect to suppliers. This Policy should not be read in lieu of but in addition to any supplier
obligations as set forth in any (i) request for proposal or other solicitation, or (ii) agreements
by and between the University of Pittsburgh and the Supplier. In the event of a conflict
between this Policy and any University solicitation document or applicable agreement, the
terms of the University solicitation or agreement shall control.
No exclusions are applicable to this policy.
Policy 05-02-02 Conflict of Interest and Procurement Relationships
Policy 05-02-03, Code of Ethics
Policy 05-02-18 Attachment A