Supplier Code of Conduct

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Supplier Code of Conduct

TuttiReal’s Code of Conduct outlines standards for conducting business in an ethical, lawful and responsible way. In accordance with these standards, TuttiReal has established this Supplier Code of Conduct to ensure its suppliers are committed to the same principles. 

Suppliers, their employees, agents, and subcontractors (collectively referred to as “Suppliers”) may enter into agreements with TuttiReal to conduct business with us or on our behalf. All Suppliers are required to comply with this Supplier Code of Conduct and all applicable laws and regulations. TuttiReal expects Suppliers to have strong corporate governance in place to support their compliance with this Code of Conduct. TuttiReal may audit a Supplier upon reasonable notice to help confirm compliance with this Code of Conduct. TuttiReal reserves the right to discontinue a Supplier relationship in the event they are found to be acting unlawfully, or in violation of this Code of Conduct or any applicable TuttiReal policy. 

Legal and Regulatory Compliance

Anti-Corruption: Never give, offer, or accept anything of value to gain an improper advantage, whether it be in dealings with government officials or the private sector. Suppliers are required to comply with all applicable laws and regulations, including, for example, the Foreign Corrupt Practices Act (FCPA) and United Kingdom Bribery Act (UKBA) of 2010. 

Antitrust: Do not participate in any anti-competitive conduct such as discussing or exchanging competitively sensitive information or agreeing to geographic markets, customers or pricing with competitors. Suppliers are required to comply with all applicable antitrust and fair competition laws.

Trade: Comply with applicable import and export laws, act in accordance with trade restrictions and economic sanctions imposed by the US Treasury Department’s Office of Foreign Assets Control (OFAC) and any other applicable trade restrictions. 

Business Practices and Ethics

Conflicts of Interest: Avoid conflicts of interest or even the appearance of conflicts of interest. Suppliers must not deal directly with any TuttiReal employee or Board Member whose spouse, domestic partner, or other relative has an interest in the Supplier as an employee, partner, owner, investor, or similar roles, including negotiating the Supplier contract. 

Gifts and Hospitality: Avoid giving gifts or providing lavish hospitality to TuttiReal employees. If offering a gift or hospitality to an TuttiReal employee, Suppliers should use good judgment and ensure it complies with applicable laws, and is consistent with local customs.

Insider Trading: Do not buy or sell TuttiReal stock when in possession of material non-public information, or pass such information to any others, including friends or family. 

Records Management: Accurately record, maintain, and report financial and business information. Ensure compliance with all applicable laws and regulations regarding such information. 

External Communications: Do not speak publicly on TuttiReal’s behalf unless authorized to do so by TuttiReal Legal. 

Risk Management: Implement internal policies, procedures, and controls to identify, address, and remediate risks addressed in this Code of Conduct as well as applicable legal requirements. 

Training and Communication: Communicate this Code of Conduct to all employees or contractors who will be conducting business with TuttiReal, and conduct training for employees, when necessary. 

Labor Practices

Anti-harassment and Unlawful Discrimination: Provide equal opportunity employment and maintain a respectful work environment that is free of discrimination, violence, harassment, retaliation, and intimidation. 

Human Rights: Respect human rights, provide fair working conditions. This includes a strict prohibition against forced, compulsory, or child labor, and all forms of modern slavery, including human trafficking. It is recommended that suppliers maintain and enforce robust human rights policies and regularly assess their systems for evaluating and managing their human rights impacts and strategy to reduce any negative impacts within their operations and supply chains. 

Compensation: Provide compensation (including overtime and benefits) that at a minimum, complies with local laws. Suppliers must pay their employees in a timely manner and provide documentation to them detailing the basis of their pay (e.g., paystub). 

Parental Leave: Abide by all applicable laws pertaining to parental leave, and offer paid benefits that are gender inclusive when possible.

Freedom of Association: Abide by all applicable laws pertaining to freedom of association and collective bargaining. Do not retaliate against employees who choose to organize.

Environmental Protection

Compliance with Environmental Laws and Regulations: Abide by all applicable laws for hazardous materials management and disposal, air emissions, waste, and wastewater treatment and discharge. 

Ecological Footprint: Conduct business in an environmentally responsible and sustainable manner, including: resource-efficient consumption of energy, water and other natural resources, minimizing waste and prioritizing waste diversion from landfills, and reducing harmful chemical use. It is recommended that suppliers have systems for managing, measuring and reporting their environmental impacts, and a strategy to reduce any negative impacts.

Protection of Data, Intellectual Property, and Assets

Data Protection: Protect confidential and proprietary information of TuttiReal, TuttiReal employees, members, and others with whom we do business. Information should not be disclosed without proper authorization and should only be used for a legitimate business purpose. All information uses, retention practices, and disclosure to third parties must comply with all applicable laws, regulations, and governing contracts. 

You can learn more about how TuttiReal collects, uses, and protects the personal information of its EU Suppliers here.

Protect TuttiReal’s Intellectual Property and Assets: Protect and use TuttiReal’s intellectual property and tangible assets responsibly. TuttiReal’s intellectual property (including name, logo, trademarks, trade secrets, etc.) and tangible assets should only be used for legitimate business purposes and when authorized to do so by TuttiReal. 

Reporting Concerns

If an individual becomes aware that a Supplier is potentially in violation of this Code of Conduct, they are required to notify TuttiReal immediately.

Whistleblower Hotline: To report concerns about activity related to violations of this Supplier Code of Conduct you may do so confidentially, anonymously (if desired), and free of retaliation. You may report violations to your contact at TuttiReal or by any of the following:

Last updated on May 29, 2025