Ethics and Integrity

Moveit, Inc. dba Cross Country Recruiting (referred to as XCTR) is committed to the highest standard of business ethics and integrity everywhere it does business and our continued success depends on our employees, vendors and other business partners acting with honesty and integrity while conducting business with or on XCTR.

Scope

This Code of Conduct sets forth the basic standards that Moveit, Inc. and Cross-Country Recruiting maintains. Clients and Vendors, distributors, agents, third-party intermediaries, suppliers, representatives, and other business partners and their employees, directors, officers, agents, representatives, and subcontractors (collectively referred to as “Clients and Vendors”) are expected to comply with these minimum standards to do business with XCTR.

Compliance with Laws and Regulations

XCTR complies with all applicable local, state, federal, and national laws, regulations of the jurisdictions in which they are doing business, and other relevant legislation applicable to its business.

Vendor Diversity

XCTR will partner with a diverse pool of suppliers and vendors through inclusive sourcing procedures that promote equal opportunities.

Integrity

XCTR conducts its overall business with integrity and specifically complies with the following principles:

Business Records

• Honestly and accurately record and report all business information and comply with all applicable laws regarding their completion and accuracy. 
• Create, retain, and dispose of business records in full compliance with all applicable legal and regulatory requirements.

Interactions with Regulators

• Act professionally and be honest, direct, and truthful with all regulatory agency representatives and government officials.

Media/Investors

• Do not speak to the media or investors on behalf of XCTR clients and vendors unless expressly authorized in writing.

Conflicts of Interest

• Avoid the appearance or actual improprieties of conflicts of interest.

Labor Practices and Human Rights

XCTR expects its Clients and Vendors to respect and promote human rights, including operating in compliance with the ILO Declaration on Fundamental Principles and Rights at Work. Clients and Vendors must comply, at a minimum, with the following labor, human rights, and employment practices:

Compensation

• XCTR Clients and Vendors must fairly compensate their employees by providing wages and benefits which comply with the local and national laws and regulations of the jurisdictions in which the Clients or Vendors are doing business.

Hours of Labor

• Working hours must comply with local regulations. 
• Where the country's laws and regulations do not address standard working hours, XCTR Clients and Vendors must ensure that the work week does not exceed 60 hours. 
• XCTR Clients and Vendors must provide workers rest days (at least one day off for every seven-day period) and leave privileges.

Discrimination/Fair Treatment

• Clients and Vendors must not discriminate based on race, color, national origin, gender, sexual orientation, religion, disability, or any other characteristic prohibited by applicable law. 
• Clients and Vendors must base all conditions of employment on an individual’s ability to do the job, not based on personal characteristics or beliefs. 
• Clients and Vendors must follow all applicable employment laws, not engage in acts of verbal or physical harassment, and must not utilize mental or physical disciplinary practices.

Diversity and Inclusion

• Clients and Vendors must provide an inclusive and supportive working environment for employees and respect and promote diversity and inclusion.
• Freedom of Association: Clients and Vendors must allow workers to exercise freedom of association.

Immigration Law and Compliance

• Clients and Vendors must only employ workers with a legal right to work. Clients and Vendors must have procedures to ensure compliance with this requirement.

Employee Identification

• Clients and Vendors must not require their employees to lodge “deposits” or their identity papers (government-issued identification, passports, or work permits) with Clients, Vendors, or another person or entity. 
• Employees must be free to resign in accordance with local and national laws or regulations without unlawful penalty.

Employee Records

• Clients and Vendors must keep employee records in accordance with local and national laws or regulations and provide in a timely manner, via pay stub or similar documentation, the basis on which employees are paid.

Environmental, Health, and Safety (EHS)

Vendors must develop and implement policies and procedures that are protective of human safety, health, and the environment, including the following:

Law and Compliance

• Clients and Vendors must comply with all EHS laws, regulations, ordinances, rules, product registrations, permits, license approvals, and orders.

Systems

• Clients and Vendors must have written EHS policies and systems to minimize work-related injury, illness, and environmental incidents.

Work Environment

• Clients and Vendors must maintain a healthy, clean, and safe work environment. This includes any residential facilities that a Client or Vendor provides its employees. 
• Clients and Vendors must construct and maintain all facilities in accordance with the standards set forth by applicable laws and regulations in the countries in which they operate.

Emergency Preparedness

• Clients and Vendors must be prepared for emergency situations. This includes worker notification and evacuation procedures, emergency training and drills, appropriate first aid and emergency response supplies, fire detection, and suppression equipment, and adequate exit facilities. 
• Clients and Vendors must regularly train employees on emergency planning, emergency exit procedures, and responsiveness.

Environmental Sustainability

Clients and Vendors are expected to operate in an environmentally responsible and efficient manner and seek to minimize adverse impacts on the environment. Vendors are expected to seek to conserve natural resources, avoid using hazardous materials where possible, and promote activities that reuse and recycle. Vendors are expected to develop and use climate-friendly products and processes to reduce power consumption, water consumption, waste, and greenhouse gas emissions.

Confidentiality, Data Protection, and Privacy

Confidentiality

• Clients and Vendors must not disclose to others and must not use for their own purposes or the purpose of others any trade secrets, confidential information, knowledge, designs, data, skill, or any other information or intellectual property considered by Moveit, Inc or Cross-Country Recruiting as “confidential” (“Moveit Information”).

Data Protection

• Clients and Vendors must take appropriate steps to safeguard Moveit Information, or any information that could lead to the identification of individuals, including information that identifies individuals in combination with other information (“Personal Information”). Clients and Vendors must securely handle, destroy, and return any documents or records, provided to them.

Privacy

• Clients and Vendors must implement administrative, technical, and physical safeguards to ensure that employees' and other third parties’ privacy rights are protected in accordance with all applicable laws and regulations.

Records Management

• Clients and Vendors are expected to maintain all business records and information in compliance with all applicable laws regarding data retention and accuracy. 
• Clients and Vendors must maintain policies and procedures to create, retain, handle, destroy, return, and dispose of business records in full compliance with all applicable legal and regulatory requirements.

Social Media

Clients and Vendors are expected to educate and train employees on the use of social media, which should be broadly understood to include blogs, wikis, microblogs, message boards, chat rooms, electronic newsletters, online forums, social networking sites, and other sites and services that permit users to share information with others in a contemporaneous manner. Although not an exclusive list, some specific examples of prohibited social media conduct include posting commentary, content, or images that are defamatory, pornographic, proprietary, harassing, libelous, or can create a hostile work environment.

Reporting and Investigations

Clients and Vendors must establish processes to enable their employees to report concerns or illegal activities through a formal reporting structure. Clients and Vendors must investigate reported incidents and take appropriate corrective action. Clients and Vendors may not take retaliatory action against any employee who in good faith reports a concern, questionable behavior, or illegal activity.

Training, Compliance Monitoring, and Vendor Policies and Procedures

Clients and Vendors must ensure that their relevant personnel understands the expectations and requirements of this Vendor Code of Conduct. Clients and Vendors are expected to educate and train their employees to ensure that they understand and comply with this Code of Conduct.

Questions

For questions regarding this policy, contact the Moveit Privacy Office by postal mail or by email at rob@xctr.net.

Moveit, Inc.

• Privacy Office
• 4133 Prado de las Cabras
• Calabasas, CA. 91302

Updates

We will communicate any significant updates to this policy. We will post the date this policy was last updated at the top of the policy. Please check periodically for changes.