Supplier Code of Ethics

It is the policy of Windstream to conduct business in a manner that is ethical and promotes the best interests of its customers, employees, and stockholders. Accordingly, Windstream expects its Suppliers to be ethical and honest, comply with all applicable laws and regulations, and avoid any appearance of impropriety or conflict of interest. Windstream Suppliers are never authorized to commit, or direct others to commit, any illegal or unethical act.

To assist Suppliers in meeting Windstream’s expectations, this Supplier Code of Ethics (“Code”) provides basic guidelines for important areas of business conduct. As used in this Code, “Supplier” refers to any entity providing products, people or services to Windstream, and where applicable, the personnel of Supplier and its subcontractors and agents. Windstream expects Suppliers to comply with these guidelines and always exercise good judgment in applying them to their conduct as a Windstream Supplier. In addition to the Code, Windstream expects all Suppliers to recognize and adhere to Windstream’s Ethics Policy, or a substantially similar internal supplier ethics and compliance program. Suppliers that do not comply with the Code may be subject to corrective action, up to and including termination of Windstream’s agreement(s) with such offending Suppliers.

This Code is not intended to create new or additional rights, or any additional Windstream obligations, in favor of Suppliers, Supplier personnel, or any third parties. It supplements, but does not supersede, the agreements between Windstream and Suppliers. Windstream reserves the right to revise the Code and its Ethics Policy at any time.

Reporting Concerns

Suppliers must promptly report concerns and potential or actual violations of this Code. Suppliers should contact Windstream’s Chief Compliance Officer or Compliance Committee through the Windstream Working with Integrity Helpline at 888-898- 3990, online at https://www.tnwgrc.com/WebReport/ or by mail: Windstream Working with Integrity, Chief Compliance Officer, 4001 N. Rodney Parham Rd., Building 1 Floor 3, Little Rock, AR 72212. The Helpline and online reporting system have been established to provide Suppliers channels to report possible violations confidentially and anonymously. Both the Helpline and online reporting system are staffed by The Network Inc., an independent third party. Suppliers must provide reasonable assistance to any investigation by Windstream of a violation of this Code. Suppliers must protect anyone who works for them, either as an employee or a contractor, from any form of retaliation for reporting suspected or actual violations.

Policy Against Facilitation Payments

Suppliers must know and abide by the laws of the United States, including the Foreign Corrupt Practices Act, and the countries in which international operations are being conducted. Suppliers who are acting on Windstream’s behalf may not, with respect to any government official, pay bribes or engage in corrupt practices to advance any interests associated with Windstream. This includes directly or indirectly offering, promising to pay, or authorizing the payment or provision of money or anything of value to government officials, political parties, or candidates for political office for the purpose of influencing their acts or decisions. A Supplier acting on Windstream’s behalf may not engage in any form of bribery, including commercial bribery. For the avoidance of doubt, when Suppliers team with Windstream in providing goods and services to government entities or otherwise deal with government officials in connection with Windstream matters, gifts or entertainment of any value are not permitted.

If a Supplier, in connection with its work for Windstream, is approached by anyone, including a government official or an agent thereof, and asked to provide a payment or anything of value to influence an act or decision of the official or his/her government, or to secure an improper advantage, the Supplier is required to refuse to make the payment or to provide anything of value and immediately report the incident to Windstream using the Helpline, online reporting system or mailing address.

Falsification or Alteration of Records

Falsifying or altering records or reports, preparing records or reports for improper purposes, or knowingly approving such conduct is prohibited. Suppliers must keep accurate and complete books and records regarding all transactions relating to its work for Windstream. These prohibitions include the following:

  • False or misleading entries or statements should never be made in any Supplier books or records, including expense reports, time records, or other documentation, for any reason.
  • Expense reports must be completed accurately, showing the true purpose and correct amount of each expense item. Expense reports must never seek reimbursement of expenses that are not legitimate business expenses incurred in the course of your duties as a Windstream Supplier. This means that an expense report must never seek reimbursement for personal spending that is unrelated to reasonable, business related expenses.
  • Permanent entries in Supplier records should never be altered.
  • No secret or unrecorded funds or assets should be created or maintained for any reason.
  • Never make a payment or approve a receipt or expense report with the understanding that it will be used for a purpose other than what is described in the record of the transaction.

Gifts and Entertainment

Suppliers warrant that no commissions, payments, kickbacks, lavish gifts, entertainment, or other things of any value have been given to any employee or agent of Windstream in connection with Supplier’s work for Windstream, and acknowledges that the giving of any such payments, gifts, entertainment, or other things of value is strictly in violation of Windstream's policy on conflicts of interest and may result in the cancellation of Windstream’s relationship with a Supplier. Suppliers must notify Windstream of any solicitation by any of Windstream's employees or agents for any payments, gifts, entertainment, or other things of value using the Helpline, online reporting system or mailing address.

Appearance of Impropriety — Conflicts of Interest

Windstream awards business on the basis of several factors, including but not limited to, product or service needs, costs, project management resources, experience and performance record. A Supplier must not have a relationship with any employee at Windstream that affects or might appear to affect the objectivity of an employee’s judgment or that is or appears to be a conflict of interest.

Treatment of People with Respect and Dignity

Windstream expects Suppliers to treat all employees with respect and dignity and not to use corporal punishment, threats of violence, physical abuse or other forms of physical coercion, harassment or intimidation. Suppliers’ employment, wage and benefits practices should not be based upon grounds of sex, race, age, color, religion, national origin, marital status, veteran status or disability, in accordance with state and federal law. Additionally, Windstream expects Suppliers to use their best efforts to achieve a diverse work force.

Freedom of Association

Windstream expects Suppliers to respect the legal rights of their employees to join or not to join worker organizations, including trade unions or similar external representative organizations. Suppliers should strive for effective employee communication as a means of promoting positive employee relations.

Labor Rights

Suppliers must implement hiring practices to accurately verify the age of all workers and workers’ legal right to work prior to employment. Suppliers will not employ individuals under the legal minimum working age of the jurisdiction and/or country where the Supplier operates. Suppliers must not use forced or involuntary labor whether bonded, imprisoned, or indentured, including debt servitude. Suppliers must comply with all applicable wage and hour laws and regulations, including, but not limited to, those relating to minimum wages, overtime hours, piece rates and other elements of compensation, and legally mandated benefits. Suppliers’ employees should understand their employment conditions including payment terms and benefits.

Safety, Health and the Environment

Windstream is committed to providing a safe, healthy and alcohol and drug free work place for its employees and for visitors to Windstream’s facilities, and Windstream expects Suppliers to do that same. Suppliers should provide appropriate health and safety information and training to their employees. Suppliers are expected to follow all applicable safety, health, and environmental laws, as well as any related Windstream policies, and should have a program or mechanism(s) to enforce and monitor compliance with health and safety requirements. Such programs and/or mechanisms should include at least the following: (i) assurances that the Suppliers’ workers are provided with a safe place to work and are qualified to perform their work functions safely; (ii) the ability to track occupational injuries and illness; (iii) an emergency preparedness plan and response procedure; (iv) efforts to eliminate or reduce waste of all types, including waste of water and energy; and (v) an environmental management system with a focus on continuously monitoring and improving environmental performance.

Use and Protection of Company Assets

Windstream’s property and resources are highly valuable. Suppliers are responsible for protecting Windstream’s tangible and intangible property and ensuring their legitimate Windstream-related business use. Some examples of Windstream property include our funds, buildings and facilities, company vehicles, resources used to provide communications services, office equipment, intellectual property and confidential information. Suppliers are responsible for safeguarding Windstream property in their possession and control, and for using such resources only for legitimate business purposes to advance the interests of Windstream. Windstream property may not be taken, sold, loaned, given away, licensed, assigned, damaged, used for nonbusiness purposes or otherwise disposed of regardless of its condition or value, unless the Supplier has specific written approval from an authorized Windstream representative.

In addition, if Windstream issues a building key or access device to a Supplier, the key or access device must: (i) be safeguarded; (ii) be used only by the authorized recipient; (iii) not be transferred without the consent of Windstream; (iv) not be duplicated; and (v) be returned to Windstream immediately when the employment of its holder is terminated, when its holder no longer requires such building key or access device, or at the request of Windstream.

Property Rights of Others

Windstream respects the property rights of others. In the conduct of business, Windstream has occasion to receive and use proprietary information of others, such as customer lists, technical developments or operational data, as well as other material that is not publicly available. Windstream must use this information only in accordance with the agreements under which such information is received. Windstream's policy is to honor and respect the intellectual property rights of others. Such intellectual property rights include patents, trademarks and copyrights. Suppliers should not engage in any improper use of the intellectual property rights of others, including the unlawful or unauthorized copying, revealing or use of anyone’s intellectual property.

Confidential Information and Privacy

Windstream values and protects confidential information, including information about our customers, employees, operations, finances and business plans, and information created by our customers, in accordance with applicable law. Windstream may execute a non-disclosure agreement with a Supplier before providing access to confidential information. Suppliers are required to protect Windstream’s confidential information in accordance with that agreement; any disclosure of Windstream’s confidential information is prohibited. This includes inadvertent disclosures, which means that Suppliers must not have discussions involving Windstream’s confidential information in public areas where discussions could be easily intercepted or overheard. Suppliers may use Windstream’s confidential information solely for the purposes for which it is provided under the agreement, and must not make independent use of Windstream’s data.

To Report Concerns and Potential or Actual Violations

Phone:
Working with Integrity Helpline, (888) 898-3990

Web:
https://www.tnwgrc.com/WebReport/

Mail:
Windstream Working with Integrity
Chief Compliance Officer
4001 N. Rodney Parham Rd.
Building 1, Floor 3
Little Rock, AR 72212

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