This Partner Code of Ethics and Business Conduct applies to suppliers, vendors, consultants, agencies, contractors, affiliates, service providers and other business partners working with or for Blunative Corp. (“Business Partners”).
Business Partners must act lawfully, professionally and transparently in all activities connected with Blunative.
Business Partners must provide accurate information during onboarding and cooperation, maintain controls appropriate to their risk profile, comply with applicable laws, avoid conduct that may harm Blunative or its clients, and ensure relevant personnel and subcontractors understand applicable standards.
Business Partners must not speak for, bind, represent or make commitments on behalf of Blunative unless expressly authorized in writing.
Business Partners must not offer, promise, authorize, give, request or accept bribes, kickbacks or improper advantages. This applies to dealings with public officials, private companies, clients, vendors, financial institutions, platforms, intermediaries and other third parties.
Business courtesies must be lawful, modest, occasional, transparent and appropriate. Cash or cash equivalents, benefits requested as a condition for business, gifts intended to influence a decision, inappropriate hospitality during sensitive negotiations, benefits that violate law or recipient rules, and anything that could undermine trust if disclosed are prohibited.
Business Partners must disclose actual, potential or perceived conflicts of interest connected with Blunative.
Business Partners must comply with competition and antitrust laws and must not participate in price fixing, market allocation, customer allocation, bid rigging, coordinated boycotts, unlawful information exchange or other conduct that restricts fair competition.
Business Partners must comply with applicable sanctions, export control, customs, anti-boycott and trade laws. They must not involve Blunative in dealings with sanctioned persons, prohibited territories or restricted activities where prohibited by law.
Business Partners must not participate in or facilitate money laundering, terrorist financing, fraud, tax evasion or other financial crime. Warning signs may include unusual payment routes, forged or inconsistent documents, unrelated third-party payments, transactions without a clear business purpose, offshore or personal accounts without justification, or unexplained overpayments and refund requests.
Business Partners must keep accurate books, invoices, reports, disclosures and transaction records. They must not falsify records, conceal payments, use hidden accounts, misstate expenses or participate in tax evasion.
Business Partners must protect Blunative’s confidential information, personal data, client information, financial institution collaboration materials, payment management files, compliance monitoring materials, KYC-related documents, platform information, reports, systems and intellectual property.
Such information may be used only for authorized purposes and shared only with persons who have a legitimate need to know. Business Partners must maintain appropriate security measures and promptly report actual or suspected confidentiality, data or security incidents.
Public communications connected with Blunative must be accurate, substantiated and not misleading. Business Partners must not use Blunative’s name, logo, relationship, client references, materials, case studies or work product in advertising, websites, social media or public statements without prior written approval.
Business Partners using artificial intelligence in connection with Blunative work must do so lawfully, responsibly and with appropriate human review. AI tools must not expose confidential information, personal data, client materials or intellectual property, and must not be used to generate misleading, biased, unverified or inappropriate outputs.
Business Partners must respect human rights and comply with applicable labor, employment, health, safety and environmental laws.
Blunative does not tolerate forced labor, child labor, human trafficking, unlawful discrimination, harassment, retaliation or unsafe working conditions.
Workers must be employed lawfully and must be able to raise concerns without fear of retaliation.
Business Partners should manage workplace risks, use resources responsibly, reduce waste where practical and handle hazardous materials only in accordance with law.
Business Partners are responsible for subcontractors involved in Blunative-related work. Subcontractors must be selected with appropriate diligence and required to follow standards consistent with this Code.
Blunative may request information or conduct reasonable checks to verify compliance with this Code. Suspected violations must be reported promptly.
Serious or repeated non-compliance may result in corrective action, suspension, termination of cooperation or legal action.