PARTNER CODE OF CONDUCT

Effective: July 31, 2020

Introduction

Club Feast is committed to operating with the highest degree of integrity and in compliance with all applicable laws. We require our merchants, suppliers, distributors, agents, representatives, and other business partners, as well as their employees, agents, representatives, and subcontractors (collectively, “Partners”), to share in this commitment. Club Feast requires Partners to agree to abide by all applicable laws, including anti-bribery and anti-harassment laws, and this Partner Code of Conduct (the “Code”). Failure to comply with this Code will be considered a breach of the Partner’s contract with Club Feast and may result in Club Feast terminating the business relationship with the Partner immediately.

COMPLIANCE WITH LAWS

All Club Feast Partners must comply with all applicable laws and regulations, including, but not limited to, those set forth below:
  • Labor, Health, and Safety

    Partners must strictly comply with all applicable labor, health, and safety laws and regulations in all markets in which they operate. Partners must prohibit unlawful discrimination or harassment in the workplace, which includes any behavior that creates an intimidating, unsafe or hostile environment, and such prohibition extends to the behavior of Partner’s personnel toward any consumer or Club Feast personnel. Partners must comply with the local minimum wage and maximum working hours requirements, and may not use forced, involuntary, or child labor. Partners must provide all employees with safe and healthy working conditions, including by offering emergency training and resources, practicing industrial hygiene, and enacting equipment safety initiatives, as appropriate.
  • Anti-Corruption

    Partners are strictly prohibited from, directly or indirectly, promising, giving, or authorizing the provision of anything of value to secure an improper advantage, to induce anyone to improperly perform a function or duty, to reward anyone for the improper performance of a function or duty, or with the belief that the acceptance of the thing of value is improper. A thing of value includes, but is not limited to, money, gifts, favors, donations, meals, and entertainment, regardless of amount. Partners must comply with all applicable anti-corruption laws, including the U.S. Foreign Corrupt Practices Act, the Canadian Corruption of Foreign Public Officials Act, as well as any other applicable laws and regulations prohibiting public or commercial bribery, extortion, kickbacks, or other unlawful or improper means of conducting business. Partners are prohibited from promising, giving, or authorizing the provision of “facilitating payments” to expedite or secure the performance of non-discretionary, routine governmental duties, even if permitted by the FCPA or local laws. Partners may never offer, promise, or give, gifts, hospitality and/or travel to government officials on Club Feast’s behalf for the purpose of improperly obtaining or retaining business or securing an improper business advantage. Partners may not request, agree to accept, or accept a thing of value as a reward or in exchange for improperly performing any activity related to Club Feast’s business or if doing so reasonably could be viewed as compromising the Partner’s ability to make objective decisions on behalf of Club Feast.
  • Competition

    Partners must comply with all applicable laws and regulations regarding fair competition and antitrust.
  • Data and Information Privacy

    Partners may not share or disclose Club Feast’s intellectual property, confidential information, or any other proprietary information that the Partner acquires through its engagement with Club Feast to third parties. This includes, but is not limited to, information developed by the Partner in connection with its engagement with Club Feast, and any information relating to products, consumers, pricing, costs, strategies, programs, processes, and practices.
  • Intellectual Property and Confidential Information

    Partners must comply with all applicable data privacy laws and regulations when processing the personal or identifying information of anyone with whom they conduct business, including but not limited to, suppliers, customers, consumers, and employees. Partners must also strictly safeguard the data and information privacy of any Club Feast-related information. Partners agree to make reasonable efforts to keep data secure and confidential at all times.
  • International Trade and Export Controls

    Partners must comply with all applicable import, export, customs, sanctions, embargoes, boycott and other trade compliance laws and regulations.
  • Environmental

    Partners must conduct their operations in ways that are environmentally responsible and in compliance with all environmental laws, regulations, and standards. As part of this commitment, Partners should act to promote energy efficiency, reduce pollution, and conserve resources.

ACCURATE BOOKS AND RECORDS AND AUDIT RIGHTS

Partners must keep accurate books, accounts, and records for all transactions related to business with Club Feast. As part of its commitment to transparency, Partners are required to cooperate fully with Club Feast in any government audits to the extent relevant and applicable to Partner. Partners are prohibited from using fictitious, inaccurate, or misleading documents to support transactions related to business with Club Feast, and are prohibited from engaging in false or misleading accounting practices, such as using undisclosed or unrecorded payments.

REPORTING CONCERNS

It is the obligation of every Partner to immediately report any known or suspected violations by Partner’s employees or representatives, as well as by Club Feast’s employees and representatives, of this Partner Code of Conduct. Reports can be made by sending an email to support@clubfeast.com