Supplier Code of Conduct

WP Engine is committed to doing the right thing. We treat each other with kindness and respect, creating a safe place for everyone to thrive. We expect our suppliers to do the same, and to adhere to the responsibilities outlined below.

As a supplier, you must ensure that the practices and principles outlined in this policy are followed by your employees and agents, as well as flowed down throughout your own supply chain.

SUPPLIER RESPONSIBILITIES

• Supplier Obligations. Suppliers must comply with all applicable laws, legal regulations, directives, and guidelines, as well as all contractual obligations they have with us.
• On-Site Policies. Suppliers using our properties or facilities must comply with all of our on-site policies and requirements.
• Industry Certifications. Suppliers must maintain certain certifications applicable to their industry and agree to provide them to us upon request.
• Information Disclosure. Suppliers must accurately disclose information regarding their labor, health, safety and environmental practices, business activities, structure, financial situation, and performance, in accordance with prevailing industry practices.
• Audit Rights. Suppliers must cooperate with us on information requests or audits to confirm their fulfillment of these responsibilities. Although we will attempt to work with suppliers to resolve deficiencies, we may terminate our relationship with any supplier that fails to meet these responsibilities.

LABOR AND HUMAN RIGHTS

WP Engine is committed to treating workers fairly and fostering a culture of diversity, equality, and authenticity in the workplace. To support that commitment, suppliers must manage their own workforce to meet the following standards:

• Modern Slavery. Suppliers will not use or permit any form of forced, bonded, or indentured labor, involuntary or exploitative prison labor, slavery, or trafficking of persons. All work must be voluntary, and all workers must be free to terminate their employment at any time. Suppliers will not unreasonably restrict workers’ freedom to move into, out of, or at working facilities. As part of the hiring process, suppliers are expected to give each worker a written agreement describing the worker’s terms of employment in a language understood by the worker, and, if internationally relocating, the written agreement will be provided before they leave their country of origin.
• Child Labor. Suppliers will not use child labor and shall work to prevent all forms of child labor. “Child” means any person under age 15, under the age for completing compulsory education, or under the minimum age for employment in the country, whichever is greatest. Workers under the age of 18 will not perform work that is likely to jeopardize their health or safety, including night shifts and overtime.
• Wages. Suppliers will pay their employees wages and benefits not less than what is legally-mandated and will comply with the law regarding wage deductions, minimum wages, overtime hours, and legally-mandated benefits. Suppliers must provide information about wages and benefits to all employees in accordance with applicable law. Suppliers will not deduct from wages as a disciplinary measure.
• Working Hours. Except in emergency or unusual situations, for suppliers’ workers paid hourly, workweeks are expected not to exceed 60 hours per week (including overtime) or, if less, the maximum set by local law. Workers should be allowed at least one day off every seven days.
• Fair Treatment. Suppliers will not permit harassment, abuse, corporal punishment, or inhumane treatment. Suppliers will not subject workers or potential workers to unlawful medical tests or physical exams. Suppliers will not discriminate in screening, hiring, or employment practices based on race, color, age, sex, gender, gender identity, gender expression, sexual orientation, marital status, ethnicity, national origin, caste, disability, protected genetic information, medical condition, pregnancy, religion, political affiliation, trade union membership, covered veteran status, or body art. Workers’ religious practices will be reasonably accommodated. In addition, suppliers will demonstrate a commitment to identify, measure, and improve a culture of diversity and inclusion through all aspects of workplace management.
• Worker Rights. Workers will be permitted to associate freely, bargain collectively, and seek representation in accordance with local laws. Suppliers are expected to permit workers to openly communicate and share grievances with management about working conditions without fear of reprisal or harassment.

HEALTH AND SAFETY

Suppliers must recognize the importance of maintaining a safe work environment for their workers in order to minimize work-related injury and illness. Suppliers will integrate the following health and safety management requirements into business processes to provide workers with a healthy and safe work environment:

• Occupational Safety and Health. Suppliers will comply with all applicable safety and health laws and regulations, and identify, evaluate, and control worker exposure to safety and health hazards.
• Emergency Preparedness. Suppliers will identify and plan for potential emergencies and will implement emergency plans and provide guidance to workers on emergency response procedures.
• Sanitation, Food, and Housing. Suppliers will provide workers with ready access to clean toilet facilities, potable water, and sanitary food preparation, storage, and eating facilities. If suppliers provide workers with residential facilities, those facilities will be clean and safe, with adequate personal space, entry and exit privileges, emergency egresses, heat and ventilation, and hot water for bathing and showering.

ENVIRONMENTAL

WP Engine recognizes that environmental responsibility is integral to operating a modern enterprise. In manufacturing operations and construction, suppliers will strive to create regenerative processes and will minimize adverse effects on the community, environment, and natural resources while safeguarding the health and safety of the public by complying with the following:

• Environmental Permits. Suppliers will obtain and keep current all required environmental permits, approvals, and registrations, and follow their operational and reporting requirements.
• Resource Efficiency and Clean Energy. Throughout their operations, suppliers will work to reduce consumption of resources, including raw materials, energy, and water. Suppliers will track, document, and seek to minimize energy consumption and greenhouse gas emissions, and seek ways to improve energy efficiency and use cleaner sources of energy.
• Hazardous Substances. Suppliers will identify and manage chemicals and other materials that pose a hazard to the environment, to ensure their safe handling, use, storage, and disposal. Suppliers will identify, monitor, control, treat, and reduce hazardous air emissions, wastewater, and waste generated from its operations.
• Waste Mitigation. Suppliers will work to reduce or eliminate waste of all types. Where waste cannot be eliminated, suppliers will manage and control all waste streams to comply with applicable laws and regulations, and in an environmentally responsible and secure way.

ETHICS AND COMPLIANCE

Suppliers will uphold the highest standards of ethics to promote honesty and integrity in business operations, including:

• Business Integrity. Suppliers will immediately disclose any known family or other close personal relationships with our employees who have an influence over their engagements with us in order to avoid conflicts of interest. If suppliers extend any business courtesies to our employees, they will do so infrequently and the courtesies must be of no more than moderate value. Suppliers will also accurately reflect their business dealings in their books  records. Suppliers must have a zero tolerance policy to prohibit any form of bribery, corruption, extortion, or embezzlement. Bribes or other means of obtaining undue or improper advantage are not to be promised, offered, authorized, given, or accepted. Suppliers will not make illegal payments directly or indirectly. Suppliers will implement monitoring and enforcement procedures to ensure compliance with anti-corruption laws.
• Intellectual Property. Suppliers will respect intellectual property rights, and will conduct technology and know-how transfers in a manner protecting both customer and supplier intellectual property rights.
• Privacy and Information Security. Suppliers will protect the privacy of personal information of everyone with whom they do business, including suppliers, customers, consumers, and workers, and implement programs that ensure the confidentiality, anonymity, and protection of supplier and employee whistleblowers.
• Accessibility. Suppliers will embed relevant accessibility standards compliant with WCAG 2.1 Level AA, innovation, and best practices to deliver inclusive products and services for our users and stakeholders.

MANAGEMENT SYSTEM

Suppliers are expected to have and maintain a management system to carry out the responsibilities contained in this Supplier Code of Conduct. The management system ensures the supplier can comply with these requirements, applicable laws and regulations, and identify and mitigate operational risks related to these responsibilities. In order to support compliance, the management system should contain the following elements:

• Executive level commitment and accountability
• Processes to identify, monitor, and comply with all applicable laws, regulations, standards, and requirements
• Risk management processes
• Communications and training for all workers and suppliers
• Ongoing assessments, monitoring, and continued improvement, including corrective action processes
• A program that provides workers with a means to report grievances anonymously and without fear of retaliation, unless prohibited by law
• A program to ensure suppliers will continuously monitor these reporting processes, record issues raised, investigate as appropriate, and take appropriate action.

We developed this Supplier Code of Conduct based on our Core Values: