StrongDM, Inc. Anti-Bribery and
Anti-Corruption Policy

At StrongDM, we value our role as a leader in cyber risk. We strongly value our principles, standards and practices and we expect our trusted resellers to do the same. You play a key role in our success as a business and as a member of the community.

Compliance with Laws

Resellers are expected to comply with all applicable laws, rules and regulations in all jurisdictions in which Resellers conducts its business.

Anti-Money Laundering

Resellers may not knowingly engage in, or otherwise facilitate, money laundering activities. Nor may Reseller enter into any contracts or transactions with parties appearing on the Office of Foreign Assets Control’s list of Specially Designated Nationals.

Anti-Corruption and Anti-Bribery

Reseller should not participate in bribes or kickbacks of any kind in dealings with StrongDM, public officials or individuals in the private sector. StrongDM expects its Resellers to comply with all applicable anti-corruption and anti-bribery laws, as well as laws governing lobbying, gifts, and payments to public officials, political campaign contribution laws, and other related regulations. Reseller should not, directly or indirectly, offer or pay anything of value (including travel, gifts, hospitality expenses, and charitable donations) to any official or employee of any government, government agency, political party, public international organization, or any candidate for political office to improperly influence any act or decision of the official, employee, or candidate. Moreover, Reseller should not offer gifts to strongDM employees in an attempt to influence our business decisions or to gain advantage over other resellers. Reseller should not offer anything of value to obtain or retain a benefit or advantage for the giver, and do not offer anything that might appear to influence, compromise judgment, or obligate the StrongDM employee. Any gifts, meals, or entertainment must comply with applicable law, must not violate the giver’s and/or recipient’s policies on the matter, and must be consistent with local custom and practice. Even when gifts are permissible under law and policy, Reseller must still exercise discretion and good judgment, since even “routine” business courtesies have the potential to cause embarrassing situations or create risk for those involved.

Employment Practices and Human Rights

Regardless of the type or location of service provided, strongDM Reseller should adhere to all applicable legal and any other binding obligations concerning employment practices and workplace conditions, including the protection of internationally proclaimed human rights. Resellers are expected to conduct their employment practices in compliance with all applicable laws, rules and regulations, and should, without limitation:

• Commit to a workforce and workplace free of harassment and unlawful discrimination. Resellers will abide by the requirements of 41 CFR 60–1.4(a), 60–300.5(a) and 60–741.5(a), if applicable or any similar laws in the countries in which you carry out business. These regulations prohibit discrimination against qualified individuals based on their status as protected veterans or individuals with disabilities and prohibit discrimination against all individuals based on their race, color, religion, sex, sexual orientation, gender identity or national origin. Moreover, these regulations, if applicable, require that Reseller take affirmative action to employ and advance in employment individuals without regard to race, color, religion, sex, sexual orientation, gender identity, national origin, disability or veteran status.
• Not engage in or support in any way the use of forced labor; whether in the form of indentured labor, bonded labor, or prison labor. Not engage in or support in any way human trafficking; whether in the form of involuntary labor through threat, force, fraudulent claims or other coercion.
• Comply with all local, state, provincial and national minimum working age laws and regulations, including without limitation child labor laws.
• Not utilize or endorse in any manner corporal punishment, physical or verbal abuse, financial punishment such as deduction from wages for disciplinary purposes or other unlawful harassment and any threats or other forms of intimidation.
• Provide all workers with clear and understandable written information about their employment conditions in a language understood by the worker with respect to wages, benefits and location of work, and if applicable, the hazardous nature of any work before they enter employment and as needed throughout their term of employment.
• Not require workers to work more than the maximum hours of daily labor set by local, state, provincial and national laws or regulations. Resellers must ensure overtime is voluntary and paid in accordance with applicable local, state, provincial and national laws or regulations.
• Keep employee records in accordance with applicable local, state, provincial and national laws or regulations and provide in a timely manner, via pay stub or similar documentation, the basis on which employees are paid.
• Respect workers’ rights to freedom of association and collective bargaining in accordance with applicable local, state, provincial and national laws.

Health, Safety and Security

Resellers are expected to integrate sound health, safety and security management practices into all aspects of their business. StrongDM expects Resellers to provide a safe and healthy work environment and comply with all applicable safety and health laws, regulations, and practices. In all instances, though, Resellers must refrain from any form of conduct that is considered dangerous, threatening, or harassing, and must perform service in a manner that is compliant with applicable health and safety laws and regulations.