Vendor Code of Conduct
W. P. Carey believes that Investing for the Long Run® requires us to promote ethical business practices; diversity, equity and inclusion; transparent corporate governance; and environmental sustainability. We believe that these measures are key to sustaining our continued growth and long-term success. Our core principle, Doing Good While Doing Well® guides not only our actions, but also our relationships. Therefore, we are dedicated to bringing our commitment to ethics, diversity, transparency and sustainability beyond our own business to those of our vendors.
This Vendor Code of Conduct (“VCOC”) communicates to our vendors our expectations regarding ethical business practices, commitments to human capital and rights, corporate governance and regulatory compliance, and environmental sustainability. These standards speak to our institutional values, while also incorporating recognized best practices, laws and regulations. We expect our vendors, representatives and suppliers to monitor their compliance with all applicable laws, rules and regulations of the countries in which they operate and/or conduct business with or on behalf of W. P. Carey.
We consider vendors to be any firm or individual that directly provides a product or service to W. P. Carey Inc. or its subsidiaries and affiliates (referred to herein collectively as “W. P. Carey”). It is the vendor’s responsibility to achieve and maintain the standards articulated in this VCOC. By continuing to work with W. P. Carey, vendors affirm that they share a commitment to the standards outlined herein. For further guidance on many of the issues discussed in this VCOC, please see W. P. Carey’s “Code of Business Conduct and Ethics” and “ESG Report,” as well as any related policies. The expectations set forth in this VCOC supplement any other vendor-specific requirements outlined in individual vendor agreements with W. P. Carey.
Vendors will be required to submit invoices electronically by registering via Basware’s online portal. This not only increases efficiency and improves on-time processing, it also reduces errors and promotes invoice matching due to better data accuracy. Registration through the Basware portal is free of charge; please reach out to W. P. Carey’s Treasury Team if you have any questions regarding this process.
Information Technology and Confidentiality
Vendors should only utilize secure information technologies and industry best practices that protect the confidentiality, integrity and availability of W. P. Carey data. Vendors shall remain in compliance with the laws and regulations of any jurisdictions (as well as industry guidelines and standards) that are applicable to vendors in their access to and use of personal or confidential information arising from or relating to any service provided to W. P. Carey. To the extent that any vendor receives confidential information from W. P. Carey, where W. P. Carey is bound by the terms of a confidentiality agreement with respect to the treatment of such confidential information, such vendor agrees to abide by the terms of the confidentiality agreement as disclosed by W. P. Carey.
Vendors shall protect the integrity and confidentiality of W. P. Carey’s intellectual property, including but not limited to, business know-how, trade secrets and trademarks.
Vendors, including their employees and other service providers, must avoid purchase or sale of W. P. Carey Inc. (NYSE: WPC) securities while in possession of material, non-public information.
Conflicts of Interest
Vendors should have established processes and measures to disclose and/or prevent a conflict of interest, or the appearance of a conflict of interest, with W. P. Carey.
Vendors should comply with all antitrust and fair competition laws.
Vendors must comply with all applicable anti-corruption and anti-bribery laws of any country in which they operate, including the U.S. Foreign Corrupt Practices Act and the U. K. Bribery Act. Vendors should be direct, honest and truthful in all discussions with regulatory agency representatives and government officials.
Anti-Money Laundering (“AML”) and Office of Foreign Assets Control (“OFAC”)
Vendors must comply with all applicable AML rules and regulations, including the Bank Secrecy Act, the USA PATRIOT Act and applicable FINRA rules and regulations. Vendors should follow industry best-practices in establishing AML policies and/or responding to Know-Your-Customer requirements. Vendors must comply with all OFAC rules and regulations and have regular screening procedures in place for transactions with sanctioned countries and specially designated nationals.
Notice and Legal Consultation
Vendors must disclose and discuss any matter relating to actual or potential violations and noncompliance with laws and regulations with W. P. Carey’s legal counsel.
Vendors should encourage their sub-contractors to also abide by and apply this VCOC in undertaking any matter related to W. P. Carey’s business and should adhere to similar principles when interacting with their own vendors, suppliers and representatives.
Human Capital and Rights
Vendors should strive to actively promote an inclusive workplace where employee differences and lifestyle choice are valued and must commit to creating a work environment free of any form of direct or indirect discrimination, harassment and bullying, including but not limited to: gender, gender expression, race, color, national origin, age, religion, marital status, disability, sexual orientation and veteran status.
W. P. Carey believes that diversity encourages discourse and paves the way for the highest quality performance. To encourage true diversity, W. P. Carey intends to select vendors that positively distinguish themselves in this area and will limit our relationships with vendors whose performance consistently evidences a lack of meaningful interest in diversity and inclusion. Any vendor engaged by W. P. Carey may be asked to provide its diversity data for W. P. Carey’s review and those providing over $25,000 of products or services to W. P. Carey in any calendar year are required to complete our Vendor Diversity Survey.
Vendors must adhere to all relevant local, state and federal laws and regulations pertaining to employment practices, including but not limited to, living wages, working hours, overtime, public holidays, freedom of association and right to collective bargaining, benefits, health and safety, acceptable living conditions and nondiscrimination. Vendors should commit to conducting business in accordance with U.S. equal employment opportunity laws, as well as the International Labour Organization (ILO) Discrimination Convention on protecting human rights.
Workplace Health and Safety
Vendors must commit to promoting a safe and healthy work environment that adheres to all relevant laws and regulations, including utilizing best efforts to prevent worker exposure to potential safety hazards and adhering to other Occupational Safety and Health Administration guidelines and regulations. Vendors should have a written health and safety policy and have a documented system in place for recording and reducing work-related injuries and illnesses.
Vendors will not employ any form of forced, bonded, indentured, prison or child labor. All workers must be engaged voluntarily, and they shall be free to leave work or terminate their employment with reasonable notice. In addition, vendors must treat all employees with dignity and respect and prohibit any inhumane treatment or corporal punishment.
Vendors are encouraged to offer training, learning and development opportunities relevant to their employment for all employees.
Vendors are encouraged to manage and minimize their environmental impact in conducting their business, and to promote and support eco-friendly measures. Vendors should commit to reducing energy and water consumption and implement waste minimization programs, including only using what is needed and utilizing, reusing and recycling resources optimally for maximum material lifecycle.
Vendors will work to reduce their carbon emissions in areas within their control and strive for carbon neutral products and services in their processes.
Vendors must comply with any local, state and federal environmental laws and regulations, including obtaining, maintaining and keeping current any required environmental registrations and permits.
Biodiversity and World Heritage Sites
Where possible, vendors will make a positive contribution to biodiversity and avoid activities on or near UNESCO World Heritage Sites that could impact the integrity of such sites.
Vendors are expected to follow the same or similar environmental policies as those established in W. P. Carey’s ESG Report.
W. P. Carey expects that all members of our vendors’ organization will be cognizant of and comply with the requirements and procedures set forth in this VCOC. W. P. Carey reserves the right to modify this VCOC at any time.
Please contact your W. P. Carey liaison or the W. P. Carey Legal Department if you have any questions regarding this Policy.
All questions or concerns about compliance or ethics issues at W. P. Carey may be directed to our EthicsPoint hotline, which may be accessed through W. P. Carey’s corporate website or by dialing toll free 1 (866) 384-4277. All comments and inquiries raised in good faith will be reviewed on a confidential and non-retaliatory basis.