USAA
SUPPLIER
CODE OF
CONDUCT
USAA SUPPLIER CODE OF CONDUCT
A
t USAA, we live our core values of service, loyalty, honesty, and
integrity. These simple yet essential values ensure that we conduct
ourselves with the utmost integrity, delivering high quality products
while following all applicable laws, regulations, and standards of business
conduct, and avoiding even the appearance of impropriety. It’s what our
members expect. We are committed to meeting those expectations, and we in
turn hold our suppliers to the highest standards of ethical conduct.
This Supplier Code of Conduct expresses the expectations we hold for our
suppliers, and mirrors the standards we set for our own employees in our
USAA Code of Business Ethics and Conduct.
Suppliers, vendors, contractors, consultants, agents, and other providers of
goods and services who do business with USAA are expected to follow this
Code. Nothing in this Code is meant to supersede any more specific provision
in a particular contract.
Conflicts of Interest
Suppliers and contractors are expected to avoid both actual and potential
conflicts of interest — those circumstances in which their personal interests
influence or appear to influence their ability to act in the best interest of USAA
and its members. We expect our suppliers to report to USAA any situations
of potential or apparent conflicts between their personal interests and the
interests of USAA.
Ethical Business Practices
Suppliers are expected to refrain from any and all forms of illegal or improper
activity, including corruption, misrepresentation, extortion, embezzlement,
bribery, insider trading, or utilization of Conflict Minerals. Suppliers must
perform in compliance with all applicable local, state, federal, and international
laws and regulations, such as without limitation, the U.S. Foreign Corrupt
Practices Act and the U.K. Bribery Act.
Confidential Information
Suppliers must take proper care to protect all sensitive information, including
confidential, proprietary, and personal information of USAA and its members
in accordance with applicable laws, prevailing industry practices, and contract
terms. Suppliers are expected to safeguard the confidential information of
third parties and not use confidential third-party information to benefit USAA.
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USAA SUPPLIER CODE OF CONDUCT
Financial Integrity
Suppliers are expected to accurately record, maintain, and report business
documentation, including but not limited to, financial accounts, time entry,
expense reports, payroll records, resumes and submissions to USAA, the
member or regulatory authorities.
Fair Competition and Anti-Trust
Suppliers are expected to conduct business in accordance with all applicable
anti-trust or anti-competition laws and regulations.
Entertainment, Favors, and Gifts
In any business relationship, suppliers are expected to ensure that the offering
or receipt of any gift or business courtesy is permitted by law and regulation;
does not violate the rules and standards of the recipient’s organization; is
consistent with reasonable marketplace customs; and will not adversely
impact the reputation of USAA. USAA employees are not allowed to accept
gifts, favors, or entertainment intended to improperly influence, or could
be perceived to improperly influence, their judgment or performance as
a USAA employee. USAA employees are also not allowed to accept gifts
valued over $100, and may not be in the form of cash, gift cards, or alcohol.
USAA procurement personnel may not accept gifts or any other form of
consideration from any individual or entity doing business or seeking to do
business with USAA. Suppliers are expected to not offer gifts, favors, or
entertainment to USAA employees that would violate this policy
Discrimination and Harassment
Suppliers are expected to comply with all applicable laws concerning
discrimination in hiring and employment practices. Suppliers are encouraged
to provide an inclusive and supportive working environment, free of
harassment and discrimination, in which all employees are valued and
empowered to succeed.
Human Rights in the Workplace
Suppliers are expected to maintain and promote fundamental human rights.
Supplier employees should not be forced, bonded, indentured, or subjected
to involuntary prison labor. Suppliers are expected to adhere to the minimum
employment age limit defined by national law or regulation, and in no instance
shall engage in child labor.
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USAA SUPPLIER CODE OF CONDUCT
Workplace Safety
Suppliers are expected to comply with applicable safety and health laws,
regulations, policies, and procedures. Suppliers should provide for the health,
safety, and welfare of their people, visitors, and others who may be affected by
their activities.
Compensation, Working Hours, and Conditions
Suppliers are expected to provide compensation in compliance with all applicable
wage laws, including those relating to minimum wages, overtime hours, and
legally mandated benefits. Employees should be able to earn fair wages, as
determined by applicable local law. Work weeks should not exceed the maximum
set by local law. Suppliers should provide adequate and safe working conditions
and comply with applicable health and safety policies and laws.
Export/Import Control
Suppliers must ensure that their business practices are in accordance with all
applicable laws and regulations governing the export and import of domestic
and foreign origin parts and components and related technical data.
Environment
Suppliers are encouraged to implement systems designed to reduce
greenhouse gas emissions, increase energy efficiency, reduce water
consumption, and increase waste diversion from landfills.
Reporting and Accountability
Suppliers are expected to provide their employees with access to an adequate
avenue of raising issues or concerns without fear of retaliation. USAA reserves
the right at any time to review a supplier’s adherence to this code and to
investigate any complaints or violation of policy.
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USAA SUPPLIER CODE OF CONDUCT
The mission of USAA is to facilitate the financial
security of its members, associates, and their families
through the provision of a full range of highly
competitive financial products and services.
USAA is committed to the highest standards of ethics and professional conduct
with members, employees, the communities in which we live and work,
governments, and businesses with which we are affiliated. Corporate business
activities and individual conduct must reflect good judgment and be consistent
with USAA’s core values of service, loyalty, honesty, and integrity.
We expect our suppliers, contractors, and others who do business on our behalf,
to conduct USAA-related business activities in compliance with the applicable
laws and regulations and the standards set forth in our USAA Code of Business
Ethics and Conduct.
We encourage our suppliers to implement their own written code of conduct,
and to flow down the principles of a code of conduct to the entities that furnish
goods and services to them.
Report misconduct to USAA’s Office of Ethics:
Mail: USAA Office of Ethics
PO Box 692292
San Antonio, TX 78269-2292
Email:ethics@usaa.com
24-hour Anonymous Reporting Helpline:
Inside the U.S.: (855) 208-8583
For Helpline numbers outside the U.S. go to:
www.usaaethicsmatters.ethicspoint.com
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