1. OBJECTIVE AND SCOPE
Alithya Group inc., together with its subsidiaries (“Alithya”), is committed to carrying out its operations in an ethical and socially responsible manner. This Supplier Code of Business Conduct (the “Code”) provides the standard of conduct for the suppliers providing goods or services to Alithya (“Suppliers”), excluding Alithya’s subcontractors subjected to our Code of Business Conduct. It is based on the core values of Alithya and includes trust, respect, well-being and integrity.
The Code, as it may be updated from time to time at Alithya’s sole discretion, forms an integral part of Alithya’s overall contractual relationship with you as a Supplier. By entering into a business relationship with Alithya, Suppliers agree to comply with the obligations set forth in this Code and maintain adequate policies and processes to that effect, and to ensure their Representatives do so as well.
2. COMPLIANCE WITH LAWS AND REGULATIONS
Suppliers shall comply with all applicable laws and regulations, including, but not limited to, anti-corruption and anti-bribery laws, human rights and labour laws, data privacy and cybersecurity laws, intellectual property laws, and environmental laws.
In the event that local laws and regulations are less stringent than the provisions outlined in this Code, Suppliers shall comply with the more stringent standards of this Code.
2.1 Antitrust and Competition Laws
Alithya is engaged in respecting free and fair competition and expects the same from its Suppliers.
Suppliers must comply with all applicable antitrust and competition laws and cannot engage in any act that improperly reduces competition. Examples of such prohibited acts include agreeing with competitors to fix prices, set discounts or terms of sale, limit production, divide markets, allocate customers, coordinate bidding activities, boycott customers and suppliers, fix employee compensation, or refrain from hiring each other’s employees.
2.2 Business Integrity, Anti-Corruption and Anti-Bribery
Alithya believes in fair, free and open markets and has no tolerance for corruption. All forms of bribery, facilitation payments (such as any payment made directly or indirectly to a governmental official with the intention of expediting a process or that acts as an incentive to execute an action), corruption, kickbacks, extortion, and embezzlement are strictly prohibited. Suppliers shall not engage, directly or indirectly, in any of these types of behaviours.
2.3 Respect for Human Rights and Labour Standards
Alithya is committed to complying with all applicable labour, employment, and human rights laws, and demands the same commitment from its Suppliers. Suppliers must therefore follow local laws on minimum wages, benefits, overtime, work hours and working conditions. Suppliers should also respect employees’ freedom of association and choice with respect to the issue of unions or works council affiliation, consistent with local laws.
2.3.1 Health and Safety
Alithya promotes a healthy, safe and secure working environment and expects that its Suppliers do the same. Suppliers shall follow all applicable laws and regulations regarding health, safety and security at work in their jurisdictions of operation. This includes all necessary actions to prevent work-related accidents and injuries and the engagement to strive for continual improvement in health, safety and security performance.
2.3.2 Forced Labour and Child Labour
Suppliers are strictly prohibited from engaging, directly or indirectly, in any labour activity that is forced or involuntary.
For the purpose of this Code, forced labour means labour or service provided or offered to be provided by a person under circumstances that could reasonably be expected to cause the said person to believe their safety or the safety of a person known to them would be threatened if they failed to provide or offer to provide the labour or service; or all work or service which is exacted from any person under the menace of any penalty and for which the said person has not offered himself voluntarily.
Alithya expects its Suppliers not to employ or retain the services of (i) anyone below the age of 14 years old, or higher if the local employment minimum of age is higher, and (ii) anyone below the age of 18 years old, unless the Supplier is able to demonstrate that the working circumstances are not mentally, physically, socially, or morally dangerous to the child, and that the work does not interfere with the child’s schooling by depriving them of the opportunity to attend school.
2.3.3 Harassment or Discrimination
Suppliers are expected to provide a workplace that does not tolerate harassment (physical verbal, mental, sexual or any other type) and discrimination based on a person’s colour, sex, gender identity or expression, pregnancy, sexual orientation, civil status, age, religion, political convictions, language, ethnic or national origin, social condition, a disability, and any other status protected by law. Suppliers shall be committed to fostering equal opportunities in recruitment, hiring, wages, working conditions and promoting practices. Suppliers’ work environment should support diversity and inclusion as well as treat all workers with respect while abiding by applicable employment laws.
2.4 Confidentiality of Information and Data Privacy
Suppliers must respect and protect the confidentiality of the information to which they may have access and such information may be disclosed only to authorized persons. Moreover, the confidential information must not be used for their, or anyone else’s private gain.
Suppliers may occasionally be, in their normal course of business when performing their contractual obligations, required to collect certain information about Alithya and, if applicable, about its clients or employees.
Suppliers shall protect Alithya’s and, if applicable, its clients’ and employees’, information, including personal data, if any, in accordance with applicable laws and regulations. Suppliers should only use, access and disclose the personal data as permitted by Alithya.
2.5 Intellectual Property
At all times while providing the services, Suppliers shall respect and protect the Intellectual Property of third parties and Alithya. Suppliers are prohibited from using, transferring, selling, or publishing Alithya’s Intellectual Property without its prior written consent. Suppliers shall also provide their products and services without infringing the Intellectual Property of others.
“Intellectual Property” means any right that is granted or recognized under applicable laws regarding patents, copyrights, neighbouring rights, moral rights, trademarks, trade names, industrial designs and any other statutory provision or common or civil law principle regarding intellectual and industrial property, whether registered or unregistered, and including rights relating to any application for any of the forgoing and the subject matter thereof. It includes ideas, methods, methodologies, procedures, processes, know-how, techniques, models, templates and general-purpose consulting and software tools.
2.6 Environment
Alithya is committed to maintaining a low environmental footprint and expects that its Suppliers do the same and demonstrate clear actions to limit environmental risks and impacts associated with their products and services and improve its resource efficiency. Suppliers shall follow and implement procedures that comply with applicable environmental laws, regulations, and standards. Alithya selects its Suppliers carefully, giving consideration to their environmental footprint. Suppliers are therefore expected to be committed to reducing or eliminating waste, recycling or reusing materials when possible, and having measures in place to, as applicable, prevent pollution, conserve resources and reduce the use of energy resources and greenhouse gas (GHG) emissions, thus aligning with Alithya’s commitments to a lower-carbon economy.
3. CONFLICTS OF INTEREST
Suppliers shall avoid at all times any real or perceived conflict of interest. Should any situation that may appear as a potential conflict of interest arise, Suppliers shall immediately notify Alithya. The Supplier and Alithya will then discuss acceptable mitigation measures to be implemented, if any, depending on the situation.
4. RIGHT TO AUDIT
Suppliers shall have policies and procedures in place and maintain documentation to demonstrate their compliance with this Code and all applicable laws and regulations. Alithya reserves the right to audit its Suppliers at any time to monitor their compliance with this Code, regardless of whether there is a suspected violation or not. Suppliers agree to promptly provide access to Alithya to all accounting reports, books, agreements, policies, procedures, records, or any other relevant documents regarding the performance of the services and/or its compliance with this Code upon request by Alithya.
5. VIOLATIONS
Alithya reserves the right to immediately terminate any agreement or relationship with a Supplier or request corrective action, at its discretion, in the event of an actual or suspected violation.
6. REPRESENTATIVES
“Representative” means any affiliate, subcontractor, director, officer, employee, agent or other person who acts on behalf of, or at the direction of, a Supplier. Suppliers are expected to ensure that their Representatives adhere to standards that are at the minimum equal to those set forth in this Code. Suppliers shall have policies and procedures to ensure compliance therewith. Suppliers will be held liable for any violation of this Code by a Representative.
7. REPORTING CONCERNS OR NON-COMPLIANT SITUATIONS
The Supplier must promptly report to Alithya any concerns or suspicions of non-compliance with this Code either to the Secretariat at secretariat@alithya.com or to Alithya’s ethics line at ethics.committee@deontol.com, or by phone at 1-844-879-4778.