Supplier Code of Conduct

Supplier Code of Conduct 


InMobi Pte Ltd. together with its subsidiaries and affiliates, including Glance InMobi Pte. Ltd. and its subsidiaries (collectively, “InMobi”) is committed to conducting its business in an ethical, legal, and socially responsible manner. InMobi firmly believes that relationships with InMobi’s third-party representatives, suppliers, vendors, subcontractors, service providers, re-sellers, and business development agents, and their affiliated entities (collectively, “Suppliers”), are integral to achieving its business objectives and expects its Suppliers to uphold the values of integrity and ethics in all business dealings, which are in line with InMobi policies and applicable laws. This Supplier Code of Conduct (“Code”) is in line with InMobi’s Code of Business Conduct and Ethics and applies to all Suppliers. Furthermore, in the event the Supplier engages any third party to provide services/goods to InMobi, the Supplier shall ensure that such a third party adheres to this Code. The Supplier shall be responsible for monitoring compliance by such a third party and determining that they are in accordance with applicable laws and regulations. 

Ethics, Integrity & Compliance 

The Supplier must: 

  • Be transparent and truthful in providing information to InMobi. The Supplier confirms that none of its directors, officers, or employees involved in the supply of goods and services to InMobi have any connection, through family, professional, or other association, with InMobi directors, officers, or employees. The Supplier shall avoid even the appearance of conflicts of interest in their work with InMobi and must proactively raise actual or potential conflicts of interest with InMobi so that the situation can be evaluated and addressed appropriately. 

  • Comply with applicable Trade Control laws and regulations of the countries and jurisdictions in which InMobi operates worldwide (i.e., export controls, economic sanctions, import/customs etc.).  

  • Comply with relevant anti-bribery and corruption laws, including, but without limitation, the U.S. Foreign Corrupt Practices Act (“FCPA”), the U.K. Bribery Act 2010, the India Prevention of Corruption Act of 1988, in both letter and in spirit. Supplier must (i) implement monitoring and enforcement mechanisms to ensure compliance with applicable anti-bribery and anti-corruption laws; (ii) refrain from offering any bribe, kickbacks or facilitation payments; (iii) not permit or engage in any unethical practices, corruption, extortion, or bribery – whether they are working with government officials or solely in the private sector; (iv) not offer, directly or indirectly, any form of gift, entertainment or anything of value to anyone on behalf of InMobi including government officials, customers or their representatives to obtain or retain business, influence business decisions, and/or secure an unfair advantage 

  • perform all business dealings transparently and maintain accurate details of the same in business books and records including receipts and expenses related to InMobi’s business.  Suppliers shall make such books and records available for review by InMobi or by an independent party agreed upon by the Supplier and InMobi, at InMobi’s reasonable request. 

  • uphold standards of fair business, advertising and competition.  Suppliers must adhere to applicable laws and regulations, and ensure that the quality of product/service delivered shall be in-line with all the contract terms and conditions. Supplier must, while using InMobi’s properties or facilities, comply with all of InMobi’s applicable policies and requirements.  

 

Labor and Human Rights 

The Supplier must: 

  • Respect the human rights of the people and communities in which they operate and should strive to improve the lives of the people and communities in which they operate. Supplier must not engage in child labor (the term “child” refers to any person under the minimum legal age for employment where the work is performed).  Supplier must only utilize labor where the individuals performing such labor have freely chosen such employment – their workforce must not be a result of slavery or the trafficking of persons.  All work must be voluntary, and all workers must be free to terminate their employment at any time.  

  • Only engage in labor practices that comply with applicable laws, including anti-human trafficking laws. Supplier must provide evidence, if requested, that they have implemented policies and due diligence procedures to manage ethical issues within their supply chain, including all labor-related processes to ensure they comply with laws on modern slavery and human trafficking. 

  • Suppliers must provide a safe work environment, abiding by local laws and regulations. Suppliers must ensure health and safety are effectively managed, so that health and safety risks, issues, incidents, and non-compliance are identified and addressed to provide adequate facilities to ensure the health and well-being of its workforce.  

  • Workers will be permitted to associate freely, bargain collectively, and seek representation in accordance with local laws. 

 

Non-Discrimination, Diversity and Inclusion. 

The Suppliers must:   

  • Provide a workplace free from discrimination, harassment, or any type of abuse. Supplier shall take appropriate initiative to ensure a harassment-free workplace by way of publication of policies, periodic trainings and requisite & timely support to affected parties. 

  • Not unlawfully discriminate in employment opportunities or practices on the basis of gender, race, color, religion, age, citizenship, sexual orientation, gender identity, gender expression, marital status, pregnancy, national origin, ancestry, physical or mental disability or condition, or any other protected class under applicable laws.  

 

Environmental Responsibility 

InMobi expects its suppliers to support sound environmental management principles and reduce their impact on the environment within which they operate. Suppliers must comply with all local environmental laws applicable to their operations in the countries in which they operate. 

 

Data Privacy and Security 

The Supplier must: 

  • Protect and responsibly use the physical and intellectual assets of InMobi, including trade secrets, confidential and proprietary data, when authorized to use and as per the terms of any agreement between InMobi and the Supplier. The supplier shall use software, hardware, and content only in accordance with their associated licenses or terms of use. 

  • Protect the privacy of personal information of everyone with whom they do business, including suppliers, customers, consumers, and workers.  

  • Adhere to and maintain security standards commensurate with industry-recognized security frameworks (ISO/IEC 27001, SOC 2 Type 2, NIST CSF). Act in good faith to deliver Information Security & Privacy obligations in a timely manner, including but not limited to extending support to annual audits and risk assessments, ensuring third-party assessments and attestations are kept current, and meeting regulatory requirements at all times (such as GDPR, CPRA, HIPAA). The supplier is also responsible for mitigating any security risks identified as part of due diligence assessment performed by InMobi on Supplier security practices. 

  • Provide appropriate organizational, physical, and technical security measures to protect InMobi’s or its clients’ data in its possession against unauthorized access, usage, destruction, and modification even beyond the period of the contract. 

  • Inform InMobi of any instance of security incidents/data breaches within 12 hours of discovering them and also promptly notify InMobi of major changes/vulnerabilities that may affect InMobi. The supplier is expected to fully cooperate with InMobi and provide InMobi with reasonable access to the data processing facility for conducting investigations into the reported data breach incident. 

 

Business Continuity: 

InMobi expects its suppliers to manage business continuity risk to ensure availability of critical services to InMobi. during a disaster event. It is a requirement that each supplier maintains a comprehensive business continuity and disaster recovery program that addresses the loss of facilities, technology, human capital, or suppliers necessary to support InMobi. Suppliers will provide InMobi with the supplier’s business continuity and disaster recovery plans as requested. 

 

Branding Guidelines: 

All usage of the InMobi logo must strictly adhere to InMobi brand guidelines. The supplier shall not use the InMobi brand name, logo, or any other visual vehicles implying or representing InMobi without explicit consent and shall not make any comments about their engagement with InMobi in the media without prior approval. 

 

Cooperation: 

The supplier agrees to cooperate with any information requests or audits InMobi may initiate to confirm the supplier’s fulfillment of the responsibilities set forth in this Code. InMobi reserves the right to terminate the relationship with any supplier that fails to comply with the standards set forth under this Code without any damages or penalties to InMobi. 

 

Reporting: 

Suppliers and their supply chains are obliged to inform InMobi immediately if they suspect or become aware of any unethical conduct, actual or potential violation of the Code or of any applicable law, regulation, or rule. Reports can be made to your business POC at InMobi, or to/at Glance_compliance@glance.com or Inmobi_compliance@inmobi.com. InMobi does not retaliate against anyone for submitting in good faith a report of suspected or known misconduct, nor does InMobi tolerate others retaliating. If any part of this Code is unclear, please reach out to your InMobi POC.