Last updated: November 2nd, 2022
The purpose of this REFERRAL Policy is to set forth and establish compliance with guidelines for ethical business conduct, including conducting business honestly, ethically and with integrity, complying with all governmental laws, rules, and regulations that apply to our business, and dealing fairly with our customers, REFERRAL, competitors and employees.
It does apply to all PATTERN DOT REFERRAL of services.
The main objective of this PATTERN DOT Policy is that its service REFERRAL and each of their employees, agents, and subcontractors (REFERRAL’ employees, agents, and subcontractors shall hereinafter be referred to collectively as “Representatives”) conduct their activities by all applicable laws, rules and regulations and the highest standards of ethical conduct. Our REFERRAL are expected to demonstrate their commitment to this objective by reading the guidelines set forth below and complying with them.
This REFERRAL POLICY (the “Policy”) is designed to provide our REFERRAL with general guidance regarding situations that they may encounter as a REFERRAL of services to PATTERN DOT. If a REFERRAL should confront specific issues or questions regarding the interpretation or application of the Policy, it should consult its business partner at PATTERN DOT.
As a REFERRAL of services to PATTERN DOT and its clients, we remind you that you are a representative of PATTERN DOT, and expected to conduct business with the highest standards of ethics and integrity.
As a REFERRAL to PATTERN DOT, we ask that you read this REFERRAL POLICY carefully. This Policy has five principles of conduct:
It is your responsibility as a REFERRAL of PATTERN DOT to arrive at a clear understanding of this REFERRAL POLICY and to adhere to its provisions.
Your commitment to the principles embodied in the following pages is important to PATTERN DOT and the future success of your relationship with PATTERN DOT. If you have questions concerning the implementation of any aspect of this REFERRAL POLICY, please consult your business partner at PATTERN DOT.
Confidential Information
All REFERRAL and their Representatives are expected to maintain the confidentiality of information entrusted to them by PATTERN DOT or its customers. Confidential information includes all non-public information that, if disclosed improperly, might be of use to PATTERN DOT’s competitors, or harmful to PATTERN DOT or its customers. Confidential information should only be collected if truly necessary to accomplish PATTERN DOT’s business purposes. Confidential information should never be used for personal advantage. A REFERRAL and/or its Representatives may be held personally liable for a breach of any confidentiality obligation.
The confidentiality obligations of all REFERRAL and their Representatives exist both during and after the term of any contractual relationship with PATTERN DOT.
Examples of confidential information include financial or operating information, personnel information, pricing, customer lists, related information, trade secrets, information about works of authorship, projects, plans, and proposals, and information of third parties that PATTERN DOT is required to maintain as confidential. Personal information (for example, an individual’s first name and last name in combination with a financial account number) is a type of confidential information.
Any questions regarding a REFERRAL or its Representatives’ obligations of confidentiality should be directed to your business partner at PATTERN DOT.
Inside Information
“Material inside information” is information about PATTERN DOT that is not known to the public and which a reasonable person would consider significant in determining whether to buy, sell or hold PATTERN DOT stock. Neither a REFERRAL nor any of its Representatives may buy or sell PATTERN DOT stock while in the possession of material inside information, nor may the spouse, children, or other persons living in such REFERRAL or any of its Representatives’ houses. A REFERRAL and its Representatives must also refrain from revealing material inside information to such persons and other third parties, including the REFERRAL or its Representatives’ spouse, children, other relatives, and friends. All REFERRAL and their Representatives should be aware that the laws prohibiting trading on material inside information apply to an individual regardless of whether that individual is an employee of PATTERN DOT.
Protection and Proper Use of Company Assets
All REFERRAL and their Representatives are obligated to protect and safeguard PATTERN DOT property and the property of PATTERN DOT’s customers. This applies to property and assets of all kinds, including equipment and supplies, as well as confidential information, including but not limited to proprietary business information.
Protection of confidential Company information is especially important. Unauthorized use or release of information regarding plans, strategies, costs or prices, or financial performance could jeopardize the Company’s competitive position.
All REFERRAL and their Representatives have the following responsibilities:
Any removable device containing data from PATTERN DOT should be stored in a locked cabinet when not in use.
If a REFERRAL and/or its Representatives have data from PATTERN DOT in a laptop, portable memory stick, or hard drive, the device must be encrypted.
Portable devices (such as mobile phones, smartphones, and music devices) may be used to view confidential information, but may not be used to store confidential information.
If a REFERRAL and/or its Representatives have data from PATTERN DOT in human-readable form (paper, film, etc.), the REFERRAL and/or its Representatives must store this information in a locked cabinet when not in use.
All information in human-readable form must be destroyed when no longer needed, either with a cross-cutting paper shredder, by burning the material, or another appropriate method. All REFERRAL and their Representatives must NEVER dispose of this material in a way that leaves the material in a readable form.
Maintaining Information Security
Proprietary information is a valuable Company asset and includes internal and external communication; digital information stored on laptops, handhelds, desktops, servers, backups, and portable storage devices; and hard copy documents and verbal discussions.
All REFERRAL and their Representatives must comply with all PATTERN DOT security policies and procedures for handling information assets and systems to ensure that PATTERN DOT meets its legal obligations, and protect PATTERN DOT’s reputation, and protect PATTERN DOT’s investment in proprietary information. The confidentiality and integrity of data stored on all REFERRAL and their Representatives’ computer systems must be protected by access controls to ensure that only authorized persons have access.
In addition, all REFERRAL and their Representatives must maintain appropriate security measures to protect personal information and confidential information consistent with all applicable local, state, and federal laws and regulations.
All documents and records which contain confidential information, whether in electronic or paper format, should be marked as “confidential”. All confidential information in electronic format must be encrypted before it is transmitted or transported electronically or physically. Files containing personal information should be secured in a locked office, desk, or cabinet when not in use.
The Internet and e-Mail usage
When using the Internet and Internet e-mail, all REFERRAL and their Representatives shall take the following steps:
Protect all computers with a firewall.
Have up-to-date antivirus software installed on all computers.
Run a virus scan on all files sent to PATTERN DOT. If a REFERRAL and/or its Representatives suspect that a virus has infected files on a computer, the computer must be cleaned of all viruses before transmitting any files to PATTERN DOT.
Avoid transmission of nonpublic customer information. If it is necessary to transmit nonpublic information, all REFERRAL and their Representatives are required to take steps reasonably intended to ensure that information is delivered to the proper person, who is authorized to receive such information for legitimate use. All personal or confidential information in electronic format must be encrypted before it is transmitted or transported electronically or physically.
Purchase and use PGP encryption software at all times when requested by PATTERN DOT to encrypt emails and files.
Ensure that project work is not done in unprotected environments such as internet cafes, and in other places where computer terminals and files could be publicly shared.
Copyrights and License Agreements
It is PATTERN DOT’s policy to comply with all laws regarding intellectual property. All REFERRAL and/or their Representatives shall not install or use unlicensed software in projects related to PATTERN DOT.
Customer Policy of Conduct
REFERRAL shall comply with the Policy of conduct and policies of PATTERN DOT’s customers.
Equal-Opportunity Workplace
PATTERN DOT is committed to a policy of equal-opportunity employment in the countries in which it conducts business and expects its REFERRAL and their Representatives also to comply with this commitment, even where such commitment seems inconsistent with local practice.
PATTERN DOT’s commitment to a policy of equal-opportunity employment means that PATTERN DOT will not tolerate discrimination or harassment by REFERRAL or their Representatives of any employee of REFERRAL or PATTERN DOT based on race, color, religion, sex, sexual orientation, marital status, age, national origin, disability, veteran status or other factors that are unrelated to the conduct of REFERRAL’s business. Furthermore, REFERRAL and their Representatives shall not engage in or tolerate sexual advances, racial or religious slurs, actions, comments, or any other conduct in the workplace that creates an intimidating or otherwise offensive or hostile environment.
Child Labor
It is a PATTERN DOT policy that child labor not be used for the performance of any services. This means that PATTERN DOT will not engage any vendor or REFERRAL that uses child labor or directly engages children to perform services and all vendors must agree that it will not use any child labor or directly engage children to perform services. “Child” refers to any person under the age of 15 (or 14 where the law of the country permits), or under the age for completing compulsory education, or under the minimum age for employment in the country, whichever is greatest. The use of legitimate workplace apprenticeship programs, which comply with all laws and regulations, is supported. Workers under the age of 18 shall not perform work that is likely to jeopardize the health or safety of young workers.
Gifts and Other Payments
Employees of PATTERN DOT may neither give nor accept any gift or payment for unlawfully or improperly influencing business decisions. Accordingly, REFERRAL and their Representatives may not give gifts of more than $100 USD in connection with the business of PATTERN DOT, since such gifts can affect or might appear intended to affect the judgment of the person receiving the gift.
Improper Payments
Under no circumstances shall a REFERRAL or its Representatives give or offer to an employee of PATTERN DOT bribes, kickbacks, or other improper payments of any kind, or gifts of money. This prohibition applies to dealings with current or potential customers, REFERRAL, Representatives, consultants, or any other party seeking to establish a business relationship with PATTERN DOT.
Anti-Money Laundering
No REFERRAL or its Representatives may participate in money laundering, which is the process of concealing funds that have been illegally obtained. No REFERRAL or its Representatives may use its relationship with PATTERN DOT to disguise or attempt to disguise the sources of illegally obtained funds. Transactions with Governments In doing business with governments and officials in any country, PATTERN DOT is committed to acting with honesty and integrity and will comply with all applicable laws and regulations and expects its REFERRAL and their Representatives also to comply with all such applicable laws and regulations.
No REFERRAL or its Representatives may use any funds or other assets of PATTERN DOT or on behalf of PATTERN DOT for contributions or payments to political parties, whether foreign or domestic, political funds or organizations, candidates for public office, or government officials or employees. A REFERRAL should consult its business partner at PATTERN DOT whenever it is considering anything that might constitute a political contribution from funds or other assets of PATTERN DOT or on behalf of PATTERN DOT. A REFERRAL and its Representatives may, of course, use their funds for political contributions as they desire, in compliance with applicable laws.
Anti-Trust and Unfair Competition
PATTERN DOT will comply with the antitrust and unfair competition laws in all countries where it does business and expects its REFERRAL and their Representatives also to comply with such laws.
PATTERN DOT is committed to complying with the laws and regulations of the countries in which it conducts business and expects its REFERRAL and their Representatives also to comply, including with U.S. laws that apply internationally, as well as this REFERRAL POLICY, even where they seem inconsistent with local practice.
The compliance by our REFERRAL and their Representatives with this Policy is of critical importance to PATTERN DOT. Each REFERRAL and each of their Representatives have a responsibility to promptly report any suspected or known violations of this Policy, including any violation of the law. PATTERN DOT will treat the reported information confidentially, and will not tolerate any acts of retribution or retaliation against you because you made a good faith report of alleged violations.
Each REFERRAL and each of their Representatives should raise any concerns regarding potential unethical business behavior with your business partner at PATTERN DOT.
An individual shall not be held criminally or civilly liable under any Federal or State trade secret law for the disclosure of a trade secret that is made in confidence to a Federal, State, or local government official or to an attorney solely to report or investigate a suspected violation of the law. An individual shall not be held criminally or civilly liable under any Federal or State trade secret law for the disclosure of a trade secret that is made in a complaint or other document filed in a lawsuit or other proceeding if such filing is made under seal. An individual who files a lawsuit for retaliation by an employer for reporting a suspected violation of law may disclose the trade secret to the attorney of the individual and use the trade secret information in the court proceeding, if the individual files any document containing the trade secret under seal; and does not disclose the trade secret, except under court order.
In case of any concerns or questions about this policy please contact us at:
E-mail: customerservice@patterndot.com
Address: Av. Homero #203 Int. 804 Col. Polanco V Sección, Miguel Hidalgo C.P. 11560, Ciudad de México, México.
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