Updated: September 9, 2026
J.S. Held’s commitment to the highest ethical standards begins with our CEO and Corporate Leadership and extends to every employee. J.S. Held’s continued success depends on a culture in which Third Party Partners (as defined below) reinforce our values, and operate in accordance with this Third Party Code of Conduct (the “Third Party Code”), as well as internationally recognized standards such as the United Nations Global Compact, the U.N. Guiding Principles on Business and Human Rights, and the OECD Guidelines for Multinational Enterprises. This Third Party Code sets out our expectations for suppliers, manufacturers, service providers, business partners, affiliates, distributors, resellers, agents, consultants or consulting firms, and all other third parties that provides goods or services to, for, or on behalf of, J.S. Held LLC, its subsidiaries and/or affiliates (“J.S. Held”). These parties are referred to in this Third Party Code as “Third Party Partners.
This Third Party Code applies to all Third Party Partners. Each Third Party Partner is expected to be aware of, understand and build processes to comply with applicable laws in jurisdictions where it operates or conducts business. Where the provisions of law and this Third Party Code address the same subject, to the extent legally permitted, Third Party Partner should apply the provision which furthers the intent of this Third Party Code to the greater degree. All Third Party Partners are expected to meet these standards in connection with the operation of their business. Third Party Partners should establish and enforce policies that comply and align with the expectations of this Third Party Code, and maintain effective compliance programs to ensure these standards are upheld. Third Party Partners shall also ensure that their own subcontractors and suppliers adhere to standards consistent with this Third Party Code.
The requirements of this Third Party Code supplement those contained in any agreement between a Third Party Partner and J.S. Held. J.S. Held may request that Third Party Partners acknowledge this Third Party Code and, where appropriate, periodically confirm compliance with its requirements. J.S. Held may also request information, documentation, or other reasonable evidence of compliance and may require Third Party Partners to address identified concerns. Where applicable, Third-Party Partners should communicate standards consistent with this Third-Party Code to subcontractors, suppliers, or agents that perform work for or on behalf of J.S. Held.
Violations of this Third Party Code are taken seriously and should be reported immediately upon discovery by the Third Party Partner. Where compliance concerns are identified, J.S. Held may request corrective action or take other appropriate steps, including restricting access, suspending work, or ending the relationship, consistent with applicable agreements and law.
Failure to comply with this Third Party Code may jeopardize a Third Party Partner’s relationship with J.S. Held and may result in the suspension or termination of some or all goods or services provided by the Third Party Partner to J.S. Held, consistent with applicable agreements and law.
Human Rights. Third Party Partners shall: (i) treat all of their workers fairly and with dignity; (ii) adopt an approach to human rights consistent with the United Nations Universal Declaration of Human Rights and the U.N. Guiding Principles on Business and Human Rights; (iii) support and respect the protection of internationally proclaimed human rights; and (iv) ensure that they are not complicit in human rights abuses.
Forced Labor. Third Party Partners shall ensure that all employment is voluntary and free from forced labor, including prison labor, bonded labor, slavery, or human trafficking. Third Party Partners are prohibited from conducting any form of recruitment that involves coercion, deception, or confiscation of identity documents. Third Party Partners shall conduct due diligence to ensure employees are not subjected to any form of exploitation or abuse. Third Party Partners must also comply with all applicable laws prohibiting modern slavery and human trafficking (e.g., the UK Modern Slavery Act).
Harassment, Discrimination and Diversity. Third Party Partners shall provide equal employment opportunities to all individuals regardless of race, color, gender, religion, age, disability, sexual orientation, nationality, pregnancy, parental status, or any other characteristic protected by law. Discrimination in hiring, promotion, or any other aspect of employment is prohibited. Third Party Partners shall maintain a work environment free from harassment, abuse, or intimidation, including sexual harassment, physical abuse, or verbal abuse. Policies and procedures should be in place or developed to address complaints and grievances promptly and effectively.
Child Labor. Third Party Partners shall adhere to legal minimum working age requirements and ensure that no person below the legal age is employed, in accordance with local law and international standards. Third Party Partners shall implement age verification procedures and comply with regulations concerning the employment of young workers, ensuring their work does not interfere with their education, health, or overall well-being.
Employment Status. Third Party Partners shall employ only workers who are legally authorized to work in their location. Third Party Partner is responsible for validating employees’ work eligibility status.
Wages and Working Hours. Third Party Partners shall comply with applicable wage, benefit and working hour, break and overtime laws. Overtime work should be voluntary and compensated in accordance with all applicable labor laws. Third Party Partners shall implement scheduling practices that prioritize employee well-being and work-life balance.
Third Party Partners must also provide employees with wages and benefits that meet or exceed legal requirements, including minimum wage standards and overtime compensation. Compensation should be sufficient to meet basic needs and provide a decent standard of living. Third Party Partners should conduct regular reviews to ensure fair and equitable compensation and cannot deduct wages for disciplinary purposes.
Freedom of Association and Collective Bargaining. Third Party Partners shall respect the rights of workers to freely form, join labor unions or similar organizations, and bargain collectively in accordance with local laws. Third Party Partners shall not interfere with or retaliate against workers who choose to organize or engage in collective bargaining activities and shall allow employees to communicate openly with management about working conditions without fear of intimidation or reprisal.
Business Integrity. Third Party Partners shall conduct business with integrity and honesty, adhering to high ethical standards, and avoiding bribery, extortion, corruption, fraud, and other unethical practices. Third Party Partners maintain accurate financial records, avoid conflicts of interest, and promote transparency and accountability. Third Party Partners must also comply with all applicable anti-bribery and anti-corruption laws (such as the U.S. Foreign Corrupt Practices Act and the UK Bribery Act 2010) and maintain adequate procedures or internal controls to prevent, detect, and address any form of corruption.
Intellectual Property and Software. Third Party Partners shall respect all intellectual property rights and software licensing obligations and use technology only in a manner that protects, and is in compliance with, the owner’s intellectual property rights.
Confidentiality, Data Protection, Information Security and AI. Third Party Partners shall protect and use confidential and personal information relating to their customers, J.S. Held, its clients, and employees, for authorized purposes and in accordance with applicable contractual obligations and data protection and privacy laws, including the GDPR and similar regulations. They shall maintain appropriate safeguards to prevent unauthorized access, use, disclosure, loss, or alteration and promptly respond to and notify J.S. Held of relevant security incidents as required by contract or law. Third Party Partners shall not input confidential or personal information into an artificial intelligence system unless expressly authorized and appropriately protected and shall disclose material use of artificial intelligence when requested or required by contract or law.
Gifts, Meals and Entertainment. Third Party Partners shall not offer, accept or solicit any gifts, meals or entertainment to J.S. Held personnel in any situation which might improperly influence, or appear to improperly influence, such personnel’s decision in relation to the Third Party Partner.
Conflict of Interest. Third Party Partners shall not allow bias, conflict of interest, or inappropriate influence of others to override its professional judgments and responsibilities. Third Party Partners shall proactively disclose any actual or potential conflicts of interest involving J.S. Held’s personnel.”
Whistleblower Protection and Anonymous Complaints. Third Party Partners shall protect the confidentiality of whistleblowers, strictly prohibit any form of retaliation, and, where legally permitted, provide an anonymous complaint mechanism for their employees to report concerns, in line with applicable whistleblower protection laws and regulations.
Anti–Money Laundering and Sanctions. Third Party Partners shall comply with all applicable anti–money laundering and counter–terrorist financing laws and regulations and ensure that their business operations are not used for illicit financial activities. They must also adhere to all relevant export control and economic sanctions laws (including U.S., EU, and United Nations sanctions programs) and shall not conduct business with any sanctioned individuals, entities, or countries in violation of such laws.
Fair Competition and Antitrust. Third Party Partners shall conduct their business in full compliance with applicable competition and antitrust laws. They must not engage in anti-competitive practices such as collusion, price-fixing, bid-rigging, market allocation, or abuse of market dominance.
Health and Safety. Third Party Partners shall comply with relevant safety standards, regulations and laws and provide a safe and healthy work environment and implement measures to prevent accidents, injuries, and occupational illnesses. Such measures include conducting risk assessments, providing safety training, and ensuring access to necessary protective equipment and medical care. Third Party Partners should regularly monitor workplace conditions and address any hazards or safety concerns promptly to minimize risks to employee health and well-being.
Environment. Third Party Partners shall comply with all applicable local environmental laws and regulation and strive to operate in an environmentally responsible manner beyond mere compliance. Third Party Partners support aiming to minimize their environmental impact through resource conservation, waste reduction, and pollution control measures. Third Party Partners should apply the precautionary principle to environmental challenges and strive for continuous improvement across impact areas including but not limited to climate, water resources, energy resources, pollution, land-use, and extraction and consumption of other natural resources.
Environmental and Social Due Diligence. Third Party Partners are expected to conduct appropriate due diligence on human rights and environmental risks in their own operations and supply chains. This includes identifying, preventing, and mitigating any adverse impacts on people or the environment, in line with internationally recognized frameworks such as the OECD Due Diligence Guidance for Responsible Business Conduct and the UN Guiding Principles on Business and Human Rights, and in anticipation of emerging legal requirements on corporate sustainability and supply-chain due diligence.
Access to Facilities. Third Party Partners may only access J.S. Held locations when necessary to perform the work requested. J.S. Held may limit such access, in its sole discretion. Third Party Partners personnel may not possess weapons, firearms, illegal drugs or alcohol of any kind at any J.S. Held location. Third Party Partners’ personnel must possess an identification card and/or security card while in J.S. Held locations. Third Party Partners shall use their best efforts to minimize any interference with the use and occupancy by J.S. Held, its tenants and guests at the facility at which work is performed. Third Party Partner must immediately stop work if J.S. Held notifies the Third Party Partner that their activities constitute a nuisance or interfere with use and occupancy of the facility. In such case, Third Party Partner shall promptly contact J.S. Held to reschedule the work for a mutually agreeable time.
Third Party Partners are encouraged to promptly notify their primary J.S. Held contact initially of any known or suspected violation of this Third-Party Code, conflict of interest, sanctions concern, legal violation, or other material compliance issue that may affect J.S. Held. If that is not possible or appropriate, you may report the issue to the J.S. Held Ethics Hotline at jsheld.ethicspoint.com. J.S. Held will maintain confidentiality to the extent possible and strictly prohibits any form of retaliation against
anyone who raises a concern in good faith.”
Third Party Partner hereby confirms that it will adhere to and apply the requirements specified in this Third Party Code.