Supplier Code of Conduct
Supplier Code of Conduct
Effective: August 6, 2026
INTRODUCTION
As a major player in the cloud market, it is of the utmost important that the business of OVH US LLC and its affiliated US entities ("OVHcloud US") is conducted ethically and responsibly. This Supplier Code of Conduct establishes the minimum standards that must be met by all suppliers, vendors, contractors, consultants and agents who do business with or on behalf of our company and its affiliates in the United States and around the world ("Suppliers").
- Respect and comply with the applicable laws, regulations, and standards in the countries where they operate;
- Commit to compliance with the principles set forth in this Supplier Code of Conduct; and
- Maintain accurate records of all matters related to their business with OVHcloud US.
MAJOR PRINCIPLES
- HUMAN RIGHTS
Suppliers must respect human rights in their relations with all stakeholders (employees, clients, suppliers, shareholders and communities) and adhere to the principles set out in the Universal Declaration of Human Rights.
- LABOR
- Child Labor
Suppliers must also prohibit the use of any labor performed by children under the legal age of the country where their business is operating and, under no circumstances, may it use labor by performed by children under the age of 15, regardless of the type of activity in question. In the same regard, Suppliers must not employ minors in conditions which pose a risk to their health or safety (for example, working during the night).
- Forced Labor
Suppliers are asked to prohibit any form of forced or compulsory labor. Employees should be able to freely choose their employer, freely leave their job subject to observing a reasonable notice period, as defined in their employment contract, and must not be subject to any corporal punishment, mental or physical constraints, etc. Employers are prohibited from implementing practices such as holding employees' personal documents (ID, passport, visa, etc.) or requesting payment of recruitment fees.
- Working Hours
The working conditions offered by the employer must observe the applicable country's legislation. Working hours may not exceed a weekly total of 60 hours and must include, at the very least, one (1) rest day after six (6) consecutive working days. In line with local and international regulations, Suppliers must acknowledge their employees right to paid leave, and overtime must be voluntary and paid at an increased rate.
- Discrimination and Harassment
Suppliers must treat all their employees fairly, respectfully and ethically, with respect for human dignity.
Suppliers undertake to promote diversity and equality within their company and formally prohibit any discriminatory practices, whether it's during recruitment processes, in working conditions, pay, access to training, dismissals, etc. This rejection of discrimination particularly covers any discrimination on grounds of race, skin color, origin, gender identity, religion, sexual orientation, disability, age, ethnic group, political beliefs or union membership. Suppliers also undertake to promote working relations that are free from any form of bullying or sexual harassment and must not turn a blind eye to any situations of which they may be made aware. Any reports relating to cases of harassment or discrimination must be taken seriously and handled with all due diligence, with investigations based on the facts and specific circumstances at hand.
- Freedom of Association
In compliance with the applicable local regulations, Suppliers undertake to refrain from limiting its employees right to join a union of their choice and to take part in union activities without fear of retaliation or discrimination.
- Health and Safety
Suppliers must ensure that all their employees have a safe and healthy working environment. In particular, they must make sure that employees receive the appropriate training and safety information and that they are provided with acceptable working conditions. Suppliers must also establish and implement systems, rules, procedures and instructions that are adapted to their activities, in compliance with the applicable regulations. This namely includes marked and signposted emergency exits that can be accessed and used by all, and the presence of fire alarm and extinguisher systems that are kept in good working order. Suppliers must also carry out regular inspections to guarantee compliance with safety standards, take the appropriate measures to reduce risks of accidents in the workplace and occupational illnesses, and monitor any non-compliances detected.
- Child Labor
- ETHICS
- Combatting Corruption and Fraud
Suppliers must actively engage in combatting corruption and influence peddling by implementing an appropriate anti-corruption plan and/or adapted measures to prevent risks of corruption and influence peddling. They must observe the various applicable laws and regulations relating to fraud and corruption, and particularly the Foreign Corrupt Practices Act (FCPA), the UK Bribery Act, the French Sapin II Act, and the OECD conventions. Suppliers must refrain from any fraudulent practices, namely including facilitating payments, bribes, gifts or donations which are inappropriate or unjustified, disproportionate or deceitful, regardless of their form and their recipients.
- Gifts and Entertainment
Suppliers are informed that the OVHcloud US Gifts & Entertainment Policy defines the rules applicable to gifts and invitations offered to OVHcloud US employees. Each gift or invitation received by an OVHcloud US employee is subject to an analysis which particularly reviews its monetary value, the context in which it has been offered, and its nature. The OVHcloud US employee may decline this gift or invitation if it does not respect the applicable internal rules. In any circumstance, gifts or invitations must not be offered in the aim of unduly influencing business relations with OVHcloud US and must be reasonable, infrequent, and modest in value.
- Financial Integrity
Suppliers must keep accurate records of all business transactions and provide transparent financial reporting as required by applicable laws and regulations.
- Intellectual Property and Confidential Information
Supplier must respect intellectual property rights and safeguard OVHcloud US's confidential information. Supplier must not misuse, misappropriate, or infringe upon the intellectual property rights of others.
- Conflicts of Interest
Suppliers undertake to comply with the applicable laws and regulations relating to conflicts of interest, and they must implement the necessary systems to prevent any situations presenting a risk of conflict of interest in its relations with OVHcloud US. Suppliers must report any situations which may constitute a conflict of interest to OVHcloud US.
- Money Laundering and Financing Terrorism
Suppliers demonstrate a high level of vigilance and active contribution to combating economic and financial crimes, money laundering and terrorism financing. In this regard, Suppliers are committed to taking all appropriate measures to combat these practices and that they only conduct business with trusted clients, suppliers and third parties with funds obtained legally. Suppliers particularly undertake to keep its books and accounts in a transparent, accurate and fair manner, in compliance with the applicable regulations.
- Compliance with the Rules Prohibiting Antitrust Violations
Suppliers must conduct their business in respect of competition, avoiding any conflicts of interest, prohibited practices or agreements, such as abuse of a dominant position, unlawful price fixing, or bid rigging. Suppliers must refrain from exchanging strategic future business information with any players in the concerned market, especially relating to prices, and must also refrain from any collusion with competitors or any other concerted action, agreement, express or tacit intent, or coalition. In addition, Suppliers must avoid any situation of economic dependency on OVHcloud US, in order to guarantee fair and balanced business relations.
- Insider Trading
Suppliers must not use privileged information which is not publicly available and which has been provided to them as part of their business relations with OVHcloud US for their own uses to complete financial, bond or share transactions.
- Exports
Suppliers must comply with all applicable laws and regulations relating to imports and exports, and they must particularly respect any applicable trade restrictions, embargoes or economic sanctions, and they must complete all formalities required, such as applications for the necessary authorizations for the provision of goods and services, equipment, licenses and software that they supply.
- Personal Data and Privacy Protection
Suppliers undertake to comply with the applicable regulations relating to personal data protection, in regard to both their clients and their employees and partners. This includes the implementation of the appropriate security measures to protect data from any authorized access, disclosure or abusive use, in order to guarantee the confidentiality and integrity of personal information.
- Information Protection
Suppliers undertake to implement the appropriate measures enabling the security and confidentiality of any information that it may obtain as part of its relations with OVHcloud US to be guaranteed (non-disclosure agreements, back-up measures, restricted access to sensitive and confidential information, etc.).
- Cybersecurity
Suppliers must implement appropriate cybersecurity measures to protect systems and data from unauthorized access, use, disclosure, disruption, modification, or destruction.
- Combatting Corruption and Fraud
- ENVIRONMENT
- General Information
Suppliers must conduct their business in a manner which respects the environment and which complies with all laws on the matter applicable in the country of manufacture or delivery of its products and/or services. They must also undertake to continuously minimize the impacts of their activities on the environment. As part of this, they shall provide OVHcloud US with any information relating to their environmental policy, along with the Environmental Management System or any other environmental framework which they use to guarantee responsible management of natural resources and efficient reduction of their environmental impact.
- Waste Management
Suppliers must prevent and combat any form of pollution and to minimize the production of waste and wastewater. Suppliers must have a waste management system and use efficient technologies aiming to reduce their environmental impact as much as possible. Prior to its disposal or elimination, Suppliers must characterize and sort their waste (solids, hazardous, etc.) and wastewater in an appropriate manner, in compliance with the applicable laws and regulations. OVHcloud US has set itself the ambitious target of achieving Zero Waste to Landfill by 2025. We therefore expect that our Suppliers support us in this commitment (reducing non-sustainable packaging, limiting waste, packaging innovations, etc.).
- High-Risk Products and Substances
Suppliers must also comply with all applicable laws and regulations relating to the prohibition and restriction of the use of high-risk products and substances, such as chemical products or electronic components.
- Greenhouse Gas Emissions and Carbon Footprint
Suppliers must characterize, inspect, manage and process atmospheric pollutants and must reduce greenhouse gas emissions under the framework of the Carbon Net Zero by 2030 objectives, particularly by opting for low-carbon solutions and raising employee awareness of climate challenges. At OVHcloud US's request, Suppliers must take all reasonable measures to provide the company with any data that may assist it in calculating its own carbon emissions, undertaking to provide accurate data within reasonable time frames. Suppliers must indicate the carbon emissions of the products and services that they supply to us.
- Sustainable Resource Use
Suppliers should work toward improving energy efficiency and implementing water conservation measures. Supplier are encouraged to set environmental targets and regularly measure and report on their progress.
- Product Safety and Quality
Suppliers must meet generally recognized or contractually agreed quality requirements to provide goods and services that consistently meet OVHcloud US's needs, perform as warranted, and are safe for their intended use.
- Responsible Sourcing
Suppliers must ensure that products supplied to OVHcloud US do not contain metals derived from minerals or their derivatives originated from conflict regions that directly or indirectly finance or benefit armed groups. Suppliers should know the original of materials and components in their products and, upon request, provide OVHcloud US with supply chain mapping back to the origin.
- General Information
- ENERGY
OVHcloud US applies a sustainable and resilient approach to energy use, involving its Suppliers as key players in a responsible value chain. Within this context, Suppliers commit to helping OVHcloud US to improve its energy performance across its entire supply chain. OVHcloud US expects that Suppliers undertake to communicate the energy performance criteria and energy consumption of an offered product during its operational life. Suppliers particularly undertake to propose solutions with better energy performances when the other criteria (technical and economic) allow for it.
- GENERAL
- Compliance with Supplier Code of Conduct
This Supplier Code of Conduct constitutes a framework to which each Supplier wishing to be listed and conduct business with OVHcloud US must adhere. This Supplier Code of Conduct therefore must be signed by Suppliers, who undertake to ensure that its content is respected. In this regard, OVHcloud US may be required to ask its Suppliers to provide evidence of their compliance with the commitments made in relation to this Code of Conduct. Any violation of this Code of Conduct committed by a Supplier shall lawfully justify OVHcloud US's decision to discontinue its business relations with them.
- Reporting Violations of the Supplier Code of Conduct
Suppliers may report any suspected violations of the OVHcloud US Supplier Code of Conduct to OVHcloud US. To do so, they can contact the Legal team at OVHcloud US by sending an email to legal@corp.ovh.us or by using the whistleblower reporting platform, which allows for anonymous reporting, accessible at https://secure.ethicspoint.com/domain/media/en/gui/60659/index.html.
- Consequences of Violating the Supplier Code of Conduct
Violations of this Supplier Code of Conduct may result in actions up to, and including, termination of the business relationship with OVHcloud US, depending on the severity of the violation and the specific circumstances. Suppliers are expected to take prompt corrective action to remedy any identified non-compliance.
- Compliance with Supplier Code of Conduct
- SUPPLIER ACKNOWLEDGEMENT
Suppliers are required to acknowledge that they have read and understood this Supplier Code of Conduct and agree to comply with its provisions. Suppliers are responsible for ensuring that their employees, agents, subcontractors, and affiliates understand and comply with these standards.
By accepting a business relationship with OVHcloud US, Suppliers acknowledge their acceptance of this Code and intention to comply with its requirements.
Name of Company/Supplier:_ ___________________
Signature: ____________________
Name: _______________________
Title: _______________________
Date: ________________________