Supplier Code of Conduct
Employers Mutual Casualty Company and its subsidiaries and affiliate, EMC National Life Company (collectively referred to as “EMC”) are committed to conducting business honestly, with integrity, and in accordance with the highest ethical standards. As part of that commitment, EMC expects all of its suppliers, including, but not limited to, external business partners, vendors, consultants, distributors, subcontractors and other service providers to do the same. This Code of Conduct summarizes certain minimum expectations of all EMC's suppliers. EMC's business partners are responsible for ensuring that this Code of Conduct is shared with all employees and subcontractors assigned to perform work on behalf of EMC.
Fair Dealing, Honesty and Integrity
EMC expects its business partners to be fair, honest and ethical in all activities and relationships involving or affecting EMC.
Protection of Information
EMC expects its suppliers to maintain, protect and keep confidential all EMC company and customer information. Any concerns about EMC’s information should be brought to EMC’s attention. All suppliers who will access EMC systems must complete and pass any and all assigned compliance trainings within thirty (30) days of assignment date. All suppliers with access to Protected Health Information are expected to execute a Business Associate Agreement (BAA) with EMC.
EMC expects its suppliers to protect the intellectual property of EMC, and to consult with EMC's Legal Services Department in advance of using or disclosing EMC’s intellectual property.
Conflicts of Interest
EMC expects its suppliers to avoid and report actual or potential conflicts between their personal interests and the interests of EMC. EMC team members are not permitted to give or receive anything of value which could be perceived to be a conflict of interest or to influence a business decision.
EMC expects its suppliers to notify EMC of any suspected or actual fraud related to EMC business. Any concerns regarding fraud or financial irregularities should be brought to EMC’s attention by emailing Vendor.Mgmt@EMCIns.com.
Legal and Regulatory Compliance
EMC expects its suppliers to conduct business in full compliance with any and all applicable laws and regulations.
EMC expects all of its suppliers to comply with the terms of its contracts with EMC.
EMC highly values its brand, reputation, and image in the marketplace. To avoid damaging EMC's reputation, EMC expects its suppliers to coordinate with EMC's Marketing & Communications and Legal Services departments prior to using, displaying, or publishing anything attributable to EMC. Suppliers may not speak to the press regarding EMC business or submit press release that include the EMC name unless expressly authorized in writing by a EMC's Marketing & Communications department.
Inbound Third-Party Risk Management Requests
EMC expects its supplier to send any third-party risk management requests to EMC's Vendor Management Department by emailing Vendor.Mgmt@EMCIns.com.
Health and Safety for On-Site Suppliers
EMC is committed to providing a safe work environment for its team members and supplier who perform work on-site. EMC expects such suppliers to work in a safe and workmanlike manner and comply with all applicable environmental-safety regulations. On-site suppliers should also have their own emergency response procedures and be familiar with EMC's emergency procedures. Coordination of all on-site work must be through EMC's Corporate Safety and Security department. When visiting an EMC property or facility, suppliers must follow all published security procedures. All suppliers must register and visibility display an EMC visitor badge at all times while on site.
Gifts and Payments
It is against EMC policy for our team members and close relatives to accept cash, cash equivalents, and gifts/entertainment of more than a nominal value from EMC suppliers or potential suppliers. Gifts/entertainment of nominal value should reflect good business ethics and good judgment, and are subject to internal reporting and approval requirements.
Please avoid the appearance of impropriety. Any items received that do not meet policy will be returned. No side payments to any person or entity while seeking or retaining EMC business may be made. No illegal payments, kickbacks, bribes, or other payments which violate rules in any form can be made to EMC or our team members.
EMC is just one market participant in our robust private property and casualty insurance industry, and invests resources, both time and financial, to support the continuation of this industry. EMC expects its suppliers (and parent entities) not to engage in business practices and/or conduct, or support causes, which are detrimental to EMC and/or the insurance industry in general. For example, suppliers (and parent entities) may not engage in third-party litigation funding.
Environment, Social, and Governance
To support EMC's Environmental, Social and Governance initiative, EMC expects suppliers to provide information about their own efforts with regards to Environmental, Social and Governance issues.
This Code of Conduct applies to all suppliers engaged by EMC. EMC reserves the right to amend this Code of Conduct at any time without notice. This webpage is not intended to provide legal advice. If you have questions, you should seek advice from your own counsel. This Code of Conduct, and any supplier's code of conduct, does not replace, supersede or override conflicting terms in any contract by and between EMC and a supplier. EMC reserves the right to conduct periodic audit inspections of its suppliers' practices to verify compliance with this Code.