Code of Conduct

Version April 2021

Pathwire is committed to compliance with laws, regulations and ethical industry standards and best practices that support and reconcile our company group’s social and economic goals and responsibilities in a sustainable way.

We see ourselves as equal partners in our business relationships. Our association with our business partners is based on cooperation and characterised by mutual respect.

Pathwire seeks to do business with suppliers who are committed to acting with integrity and responsibility. This Code of Conduct sets forth Pathwire’s fundamental requirements of its service providers, suppliers and their subcontractors (hereafter referred to as “Business  Partners”). Business Partners are required to inform their subcontractors and employees about Pathwire’s Code of Conduct and to ensure its adherence at every workplace where products and services for Pathwire are rendered. 

1. Compliance with Laws and Regulations

Pathwire requires all of its Business Partners to comply with all applicable legislation and laws, including United States Export Control laws, and also to conduct corporate business in a way that recognizes its ethical responsibilities and fulfils them. The requirements of Pathwire set forth in this Code of Conduct may exceed applicable legal requirements in any respective country. Should any requirement contravene legal provisions of a respective country or local law, the Business Partner must inform Pathwire about this. 

2. Anti-Corruption & Bribery

Business Partners shall not directly or indirectly take part in or condone any form of corruption, including but not limited to bribes, inducements, or facilitation payments, kickbacks, fraud, extortion, money laundering or doing business with prohibited individuals, countries or companies.

Business Partners shall not directly or indirectly accept, offer or provide any improper inducements to, or attempt to influence any government official, entity or political party, candidate or company officer for the purpose of obtaining or retaining business or securing any improper advantage.

3. Social Responsibility

Child Labor / Modern Slavery

Pathwire’s Business Partners shall comply with applicable regulations concerning forced labor, child labor and modern slavery. 

Business Partners are required to take the necessary measures to prevent the employment of persons below the legal minimum age and all regulations designed to protect children and employed youths must be observed. They are also expected to take all necessary measures to identify and eliminate the risk of modern slavery, within their own operations and that of its own supply chain.

Discrimination 

Pathwire is committed to providing equal employment opportunities to current and potential employees and expects its Business Partners to prohibit any form of discrimination in hiring and employment practices and in particular, any distinction, exclusion or preference based on race, gender, age, religious belief, political opinion, membership in workers’ organisations, physical or mental disability, ethnic, national or social background, sexual orientation or other personal characteristic is prohibited. 

Employee rights 

Pathwire requires its Business Partners to comply with all applicable labor and wage laws, rules and regulations. All employees must have sought employment of their own free will and must be treated with dignity and respect. No employee will be exposed to verbal, psychological, physical and/or sexual abuse, coercion or harassment. Business Partners of Pathwire are also responsible for any employees who are employed through agencies or other intermediaries. 

Working hours must comply with applicable laws and industry standards. Business Partners guarantee that the wages paid to employees equal or exceed the minimum wage prescribed by law or the applicable industry-specific minimum wage, whichever is higher. 

Health & Safety 

Business Partners shall provide a safe and healthy working environment and shall adopt the measures needed to prevent such accidents and health hazards as  may arise in connection with work. For this purpose, Business Partners must put in place systems  capable of detecting, avoiding and responding to potential health and safety hazards. In addition, they  guarantee that employees are periodically updated and trained on applicable health and safety  regulations as well as any precautions taken. Business Partners must document this. 

Environmental protection 

The protection of nature and the environment is an integral component of Pathwire's business  practice. Business Partners must comply with all applicable environmental regulations. They are  further expected to undertake an ongoing effort to prevent and reduce environmental contamination.

4. Financial Integrity

Pathwire’s Business Partners must accurately document all transactions related to the business contract and relevant service orders in its financial books, records, statements and in reports provided to Pathwire, and prevent any side agreements, whether oral or written. All financial books and records shall properly document all assets and liabilities using acceptable industry standards and business records must be retained in accordance with record retention policies and applicable laws.

5. Data Governance & IT Risk Management

Pathwire is trusted by our customers to securely process vast quantities of data. To ensure that trust is not compromised, Pathwire has in place a risk management and data privacy program in which Business Partners are evaluated and assessed following identified criteria. Where a Business Partner has access to any form of Pathwire or its customer data, the Business Partner will be required to complete a Security and Data Privacy questionnaire, provide supporting documentation, undergo an on-site visit and/or an audit. In addition, Pathwire addresses and manages identifiable risks with key Business Partners in their respective agreements, which may include but not be limited to, breach of confidentiality, disaster recovery procedures, business continuity, security breaches, financial viability, legal actions, new regulations and industry changes. 

6. Conflicts of Interest

Conflict of interest describes any circumstance that could cast doubt on our Business Partners’ ability to act with total objectivity with regard to Pathwire’s interests. Conflict of interest situations may arise in various ways. If a Business Partner has or may have an actual or potential conflict with Pathwire, or any of its employees, it must be reported directly to Pathwire. 

7. Reporting & Enforcement

Reporting Violations

Complaints or information about actual or potential violations of this Code of Conduct may be reported to Pathwire at any time, also anonymously. Prompt reporting of violations is in the best interest of everyone. Reports will be handled as confidential as possible.

Business Partners can contact Pathwire’s General Counsel at legal@mailgun.com or may also contact our Compliance and Ethics Hotline at Lighthouse Services, www.lighthouse-services.com/mailgun.

Enforcement

Pathwire trusts that our Business Partners recognize and respect adherence to the standards of this Code of Conduct and agree to strictly abide by its terms. Compliance is required to maintain your status as a Business Partner.