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Supplier Code of Conduct

At Sterling, we value our relationships with suppliers and subcontractors and believe that they are integral to our success. We also believe in doing business with suppliers that embrace and demonstrate a high principle of ethical behavior. As such, we are providing you with a list of our core values to clearly convey our expectations for conduct by our suppliers and subcontractors:

Business Ethics and Transparency

  • Avoid all conflicts of interest, and even the appearance of such. Conflicts of interest exist when any relationship or activity impairs the ability to make objective and fair decisions.
  • Demonstrate and adhere to the highest level of ethical standards, communicating truthful information clearly and correctly to all stakeholders.
  • Comply with all federal, state, and local laws and regulations including all aspects of the Foreign Corrupt Practices Act and all other applicable laws related to bribery of any political, regulatory, or government officials.
  • Keep property, resources, and information secure including confidential information of Sterling, our customers, and our employees.
  • If you see something say something so issues or concerns are not hidden or covered up, but instead introduced into the open to be properly addressed and resolved.
  • Treat all people fairly and honestly.

Human Rights & Labor Standards

  • Comply with all aspects of Executive Order 11246 that governs equal employment rights in the workplace.
  • Foster a diverse and inclusive work environment that ensures dignity and respect where discrimination, intimidation and harassment will not be tolerated.
  • Comply with the Civil Rights Act of 1964 and the American with Disabilities Act of 1990.
  • Comply with all aspects of wage and work hour laws.
  • Prohibit the use of child labor and forced labor in violence-free workplaces.

Environment & Safety

  • Embed safety in every aspect of performance, provide a safe workplace, and commit to keeping personnel safe as your highest priority. Personnel must be trained and qualified to perform their work safely and be provided with appropriate safety equipment and tools.
  • Comply with all federal, state, and local safety laws regarding incident prevention.
  • Treat the environment with respect and adopt as a purpose the goal to protect it for generations to come, respecting the spirit of environmental protection laws. Suppliers are expected to support environmental stewardship utilizing business process that enable waste prevention maintain public health, wildlife habitats, and preserve the integrity of the planet.

Failure to conduct business in a manner that meets the core values and requirements that are listed above could result in termination of the supplier relationship with Sterling. As a partner with Sterling, suppliers shall report any violations of this code.