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Vendor Standards of Behavior

Introduction

Public Interest Registry (PIR) is committed to operating as an exemplary domain name registry. This includes a commitment to upholding human rights and related fundamental freedoms. To achieve these objectives, PIR regularly evaluates our corporate processes related to risk management and reasonable care. We also assess the responsible sourcing of goods and services.

This Vendor Standards of Behavior (Standards) sets out our expectations for those who provide goods and services to PIR. The term ’vendor’ as used in these Standards refers to business partners, suppliers, consultants, agents, and other sub-contractors of goods and services who do, or seek to do, business with PIR worldwide. These Standards have been inspired by international benchmarks such as the UN Declaration on Human Rights, the UN Guiding Principles on Business and Human Rights, the Core Conventions of the International Labour Organization (ILO), the US Equal Employment Opportunity Commission, and the EU’s General Data Protection Regulation. They were further informed by PIR’s 2020 human rights assessment conducted with ARTICLE 19 and the Danish Institute for Human Rights, and the output of other domain industry assessments.

PIR reserves the right to periodically update these Standards, with the current version posted to the Policies section at www.pir.org. We also ask that reports of alleged vendor misbehavior be sent to abuse@pir.org for further action.


Standards of Behavior

PIR has always set high standards for the way we conduct business. In turn, we expect our vendors to conduct business responsibly, transparently, and with integrity. To more clearly and reasonably set expectations, we would like to expand upon the following core areas.


Business Ethics

PIR is committed to the highest possible standards of ethical, moral and legal business conduct. Throughout its operations, PIR seeks to avoid misconduct or even the appearance of impropriety in the actions of its directors, officers, employees, and agents. Given the scope of our operations and reliance on select business partners, we necessarily extend these expectations to our vendors and their own suppliers with whom they work to supply goods and services to PIR.

As such, PIR will not tolerate corruption or bribery in any form. Vendors must not directly or indirectly promise, offer, or provide any improper advantage to any person or entity, including officials of a government or a government-controlled entity. PIR’s employees are not allowed to accept any such advantage and we expect the same approach in business dealings from our vendors.

Likewise, vendors are expected to maintain accurate records of their activities and performance that clearly demonstrate conformity with all applicable laws, regulations, standards, or contractual requirements. Vendors also should disclose any personal relationships, economic interest, or other ties to their business held by an employee or contractor with PIR. Furthermore, vendors should not infringe any intellectual property rights in their provision of goods and services to PIR.


Compliance

PIR strives to conduct business according to the highest legal standards. In fact, the foundation of everything we do is built upon our core values—bold stewardship, relentless commitment, unwavering integrity, and honoring people. They are what drive us to live up to PIR’s high standards in the pursuit of our mission. The also oblige us to be persistent and purposeful in all of our efforts, and to never compromise our standards for the sake of expediency, popularity, or profitability. This means that PIR complies with all applicable laws and requirements that affect our business. Likewise, our vendors must ensure their operations comply with applicable laws and regulations.

We expect our vendors to immediately report any concerns about compliance with legal requirements or any aspect of these Standards to their designated point of contact at PIR. Where vendors are found to have contravened the requirements set out in these Standards, PIR reserves the right to terminate any associated agreement or business relationship.


Digital Rights

In today’s business environment, data is vital and the public’s trust that it will be managed responsibly is critical to success. Vendors, therefore, should take appropriate measures to secure and protect all confidential information related to its relationship with PIR and protect all personal data consistent with the standards set in PIR’s Privacy Notice and contractual agreements. Likewise, data may only be used for the purpose authorized under any given contractual agreement.

In the event of a data or security breach, PIR expects vendors to report such concerns to us immediately or, at most, within 72 hours of confirmation of the breach. Vendors should have appropriate processes and systems in place to do so. Vendors should include a means for the confidential reporting of concerns about misconduct or unethical behavior, and an appropriate mechanism for addressing any issues identified. Where issues are identified through internal reporting, whistle-blowers need to be protected from any negative repercussions.

Where vendors are found to have knowingly contravened these standards, PIR may seek to terminate any associated agreement or business relationship.


Worker Rights

PIR strives to promote an environment where every individual is treated with respect. We also are committed to providing a workplace that is free of unlawful discrimination and from abusive, offensive or harassing behavior. In turn, we expect our vendors to treat all employees fairly, honestly, and with respect.

To these ends, vendors must provide working hours that comply with national laws and industry standards, and total worked hours should not exceed the maximum allowable under local legislation. The use of involuntary labor of any type (i.e. forced, trafficked, bonded, indentured, or involuntary prison labor) must not be permitted.

Vendors should ensure that their employees are fairly compensated. At a minimum, compensation must comply with all applicable wage and hour laws or industry standards approved on the basis of collective bargaining (whichever is higher). As appropriate, overtime should be voluntary and compensated in accordance with applicable laws. Likewise, any deductions to wages should only be made in accordance with applicable law or pursuant to a collective agreement. Vendors should not seek to avoid obligations to workers under labor or social security laws and regulations arising from the regular employment relationship through the excessive use of fixed-term contracts, labor-only contracting, sub-contracting, home-working, or apprenticeship schemes.

Vendors must ensure that all employees have the legal right to work. Workers should be free to leave employment without penalty on the provision of reasonable notice. Further, vendors should respect the rights of employees to join (or refrain from joining) worker organizations under the terms of local legislation and, when requested, allow workplace access for such organizations to facilitate their representative functions.

The use of physical or verbal abuse, sexual harassment, or intimidation of workers must be prohibited. Likewise, vendors should not discriminate in hiring, compensation, access to training, promotion, termination, or retirement on the grounds of gender, age, race, religion, disability, sexual orientation, family or marital status, or other legally protected class.

Finally, vendors should not permit child labor to be used in any operation whatsoever, let alone in connection with PIR. No child below the legal age for finishing compulsory schooling, or 15 years of age (whichever is the greater) may be employed by a supplier, subject to ILO exceptions. Where young people under the age of 18 are employed, vendors should ensure that their work is not likely to be harmful to their health or development, including prohibitions against working under hazardous conditions and ensuring compliance with all applicable laws.


Occupational Health & Safety

PIR understands the value of a well-organized, safe, and healthy work environment. Due to the sensitive information gathered during the course of business and in the interest of maintaining safety and security, PIR employees are required to help maintain security in all buildings. This includes, but is not limited to, locking entry office doors, securely storing sensitive materials and proprietary information, and using building passes and suite keys to ensure no unauthorized access. PIR also does not tolerate any type of workplace violence committed or threatened to be committed by or against employees. Our vendors should strive to meet similar standards.

Vendors must ensure all employees work within safe and humane conditions. Facilities must be constructed and maintained in accordance with applicable laws and regulations. Employees should be provided access to clean toilet facilities, potable water, and sanitary facilities for food storage. Likewise, they should be provided adequate training and effective protective equipment to safely carry out their duties. Accommodations, where provided, should be clean, safe, and meet the basic needs of workers while respecting their dignity.

Vendors must ensure that there are appropriate exits, procedures, and equipment in place to deal with emergency situations.


Environment & Land Rights

PIR expects vendors to support its sustainability commitments through the adoption of good operating practices. In particular, vendors should seek to optimize their use of natural resources and minimize the generation of waste. Likewise, vendors should carry out operations with care for the environment and, at a minimum, comply with all applicable environmental laws and regulations.

Vendors should respect the rights to land tenure of local communities and indigenous peoples impacted by its operations, including its raw material sourcing, and will adhere to the Indigenous peoples’ principle of Free, Prior and Informed Consent.