Code of Conduct

ONIT VENDOR AND PARTNER CODE OF CONDUCT

PURPOSE AND INTENT

Onit, Inc., and its affiliates (“Onit” or the “Company”) believes that good personal and professional ethics lead to good corporate ethics and good business relationships.  Included in Onit’s definition of good corporate ethics are the standards set forth in this Partner Code of Conduct. To formalize our preference for ethical business partners, all Onit partners and vendors, i.e. partners, contractors, consultants, vendors, and subcontractors (“Partners”) are required to adhere to this Partner Code of Conduct while they are conducting business with and/or on behalf of Onit.  All Onit Partners should educate their representatives and their subcontractors who directly engage with Onit to ensure they understand and comply with the Onit Partner Code of Conduct.

LEGAL, REGULATORY AND ETHICAL COMPLIANCE

  1. All Onit Partners and their representatives are expected to conduct their business in compliance with the applicable laws and regulations of the countries where they conduct business with or on behalf of Onit.
  2. In addition to any specific obligations under Partner’s agreement with Onit, all Onit Partners are expected to comply with the following legal and ethical standards:
    1. Conduct business in full compliance with local labor and employment standards.
    2. Conduct business in full compliance with anti-bribery and anti-corruption laws and with the United States Foreign Corrupt Practices Act (FCPA) and U.K. Bribery Act, specifically agree to not make any direct or indirect payments or promises of payments for the purpose of inducing the individual to misuse their position to obtain or retain business.
    3. Require employees to report to Onit any request for a bribe or offer of a bribe.
    4. Comply with all applicable trade control, export, re-export and import requirements.
    5. Conduct business in full compliance with fair competition laws.
    6. Conduct business in compliance with copyright protections including all international conventions and laws governing the rights of copyright owners.

BUSINESS PRACTICES

  1. Onit Partners and their representatives are expected to conduct their business with integrity and in accordance with their obligations under their specific agreements with Onit. In addition to any specific obligations under Partner’s agreement with Onit, all Onit Partners are expected to:
    1. Honestly and accurately record and report all business information and comply with all applicable laws regarding their completion and accuracy.
    2. Create, retain, and dispose of business records in full compliance with all applicable legal and regulatory requirements.
    3. Protect and responsibly use both the physical and intellectual assets of Onit including property, supplies, consumables, and equipment when authorized by Onit to use such assets.
    4. Use Onit provided information technology and systems (including email) only for authorized Onit business-related purposes.  Onit strictly prohibits Partners and their representatives from using Onit provided technology and systems to create, access, store, print, solicit, or send any material that is intimidating, harassing, threatening, abusive, sexually explicit or otherwise offensive or inappropriate and/or send any false, derogatory, or malicious communications using Onit provided information assets and systems.
    5. Comply with the intellectual property ownership rights of Onit and others including but not limited to copyrights, trademarks, and trade secrets. Use software, hardware and content only in accordance with their associated license or terms of use. Prohibit the illegal use of copyrighted materials including the illegal download of music, internet games and movies.
    6. Never speak to or release statements to the media on Onit’s behalf, unless Partner and its representative is expressly authorized in writing to do so by Onit.
    7. Only provide a gift or entertainment that is nominal in value, in good taste, and complies with applicable laws and Client’s gift policies. Avoid actual conflicts of interest and the appearance of conflicts of interests.

EMPLOYMENT AND LABOR PRACTICES

  1. Onit Partners shall conduct their employment practices in full compliance with applicable employment and labor laws and regulations. Onit Partners must share in Onit’s commitment to human rights and equal opportunity in the workplace.
  2. All Onit Partners are expected to comply with the following:
    1. Provide employees with a workplace that is free of harassment and unlawful discrimination. Regardless of cultural differences, Onit Partners are expected to prohibit discrimination in hiring, compensation, access to training, promotion, termination or retirement based on race, caste, national origin, religion, age, disability, gender, marital status, sexual orientation, gender identity, union membership, veteran or military status, political affiliation or any characteristic protected by applicable laws.
    2. Provide a safe and healthy work environment and fully comply with all applicable safety and health laws, regulations and practices.
    3. Prohibit the use, possession, distribution, and/or sale of illegal drugs, or the abuse of alcohol or prescription drugs, while on Onit or Onit customer owned or leased property or while on Onit business.
    4. Prohibit the possession of weapons and dangerous substances on Onit or Onit customer owned or leased property or while on Onit business.
    5. Use only voluntary labor.  Modern slavery is a crime and a violation of fundamental human rights.  It takes various forms, such as slavery, servitude, forced and compulsory labor and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.  Onit is committed to ensuring there is transparency in Onit’s business and in Onit’s approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the UK Modern Slavery Act 2015.  Onit expects the same high standards from all of our Partners.  Onit strives to ensure against the use of forced, compulsory or trafficked labor, or anyone held in slavery or servitude and we expect that our Partners will apply the same high standards through their own organization and supply chain.
    6. Comply with any applicable laws, rules or regulations prohibiting human trafficking and/or slavery.
    7. Employees and people hired as contract or temporary labor should not be required to lodge “deposits” or their identity papers with their employer and are free to leave their employer after reasonable notice without penalty.
    8. Comply with all local minimum working age laws and requirements and under no circumstances use child labor in any capacity or employ people under the age of 16 years or the legal minimum working age whichever is higher.
    9. Provide a workplace free from physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal abuse or other forms of intimidation.
    10. Strictly adhere to working hours or labor hour statutes. Under no circumstances will any employee be required to work more than the legal standard for a standard work week. Overtime must be voluntary and paid in accordance with local laws and regulations. No employee shall be required to work more than the maximum hours of daily labor set by local laws.
    11. Ensure that all employees are legally authorized to work in the country in which they are working and do not knowingly employ the services of an illegal immigrant.
    12. Conduct business in full compliance with applicable data protection laws.

COMPLIANCE WITH THE ONIT CODE OF CONDUCT

  1. It is the responsibility of the Partner to ensure that its representatives understand and comply with the Onit Partner Code of Conduct and to inform its Onit contact (or a member of Onit management) if and when any situation develops that causes the Partner to operate in violation of the Code set forth in this document.
  2. In addition to any other rights Onit may have under its agreement with Partner, Onit may request the immediate removal of any representative who behaves in a manner that is unlawful or inconsistent with this Code or any Onit policy.

REPORTING COMPLIANCE FAILURES OR QUESTIONABLE BEHAVIOR

  1. Onit Partners are expected to self-monitor their compliance with this Partner Code of Conduct.  To report, contact Onit in any of the following ways: email [email protected] or contact us at Onit, Inc., Attn: Legal Department, 1360 Post Oak Blvd., Suite 2200, Houston, TX 77056.
  2. Partner is encouraged to work with Partner’s primary Onit contact in resolving a business practice or compliance concern. If Partner wishes to report questionable behavior by an Onit employee, there may be times when it is not possible or appropriate to go to Partner’s Onit contact. In such instances, please contact Onit in any of the following ways: email [email protected] or contact us at Onit, Inc., Attn: Legal Department, 1360 Post Oak Blvd., Suite 2200, Houston, TX 77056.
  3. Onit will not tolerate any retribution or retaliation taken against any individual who has, in good faith, sought out advice or has reported questionable behavior and/or a possible violation.