GPM® Supplier and Partner Code of Conduct

 

GPM suppliers and partners are required to take reasonable steps to ensure that this Code of Conduct is communicated, understood, and followed throughout their organizations and to make this Code available to their employees and throughout their own supply chains.

1. Antitrust and Competition Laws

It is GPM’s policy that all suppliers and partners comply fully with competition laws (known as antitrust laws in the U.S.) applicable to them. Competition laws ensure that companies compete to get business by offering lower prices, innovative products, and better service and not by interfering with the market forces of supply and demand. GPM requires that all suppliers conduct their business in full compliance with all applicable laws intended to promote free and fair competition.

2. Confidential and Proprietary Information

Suppliers and partners must respect GPM's intellectual property, trade secrets, and other confidential, proprietary, or sensitive information and may not use or disclose any such information except in accordance with their agreement with GPM.

Any information or data regarding GPM’s operations shall be treated by suppliers and partners as confidential at all times unless that information enters the public domain through no fault of the supplier or partner. The supplier or partner’s obligations with respect to GPM’s confidential or proprietary information include, but are not limited to:

  • Not to disclose this information to other prganizations or individuals within the supplier’s or partner’s organization except on a strict “need to know” or “need to use” basis.
  • Not to disclose this information to other prganizations or individuals outside of the supplier's or partner’s organization.

3. Ethical Dealings

Honesty and integrity is essential to sustainable business relationships. GPM seeks to provide all potential suppliers and partners with equal and fair consideration. Decisions on procurement are based on objective criteria such as price, quality, and service capability—and also integrity.  We require all partners and suppliers to adhere to the UN Global Compact’s Ten Principles. We have zero tolerance for and prohibit bribery and kickbacks in all their forms.

Our partners and suppliers are required to demonstrate these same ethical standards and to conduct all business transactions with the highest integrity.

4. Anti-Bribery and U.S. Foreign Corrupt Practices Act

Call to action on anti-corruptionGPM is proud to have been signatory #107 to the UN Global Compact Anti-Corruption Call to Action and is committed to working against corruption in all its forms, including bribery and extortion.

GPM’s commitment to dealing legally and ethically with governments applies worldwide. Organizational policy, the U.S. Foreign Corrupt Practices Act, the UN Convention against Corruption, and similar anti-bribery laws around the world prohibit us from giving or offering to give money or anything of value – whether cash or not, or whether directly or indirectly through others – to any government official (e.g., any employee of any government or of any government-owned or operated enterprise, entity, or corporation) to induce that official to affect any governmental act or decision, or to assist the organization in obtaining or retaining business or securing any improper advantage.

GPM suppliers and partners may not act in any way, in their business relationship with GPM or otherwise, that violates the U.S. Foreign Corrupt Practices Act or any other anti-bribery law around the world. GPM suppliers and partners must only use suppliers that do not violate ethical standards through bribes, kickbacks, or other similar improper or unlawful payments.

Compliance with all relevant laws, including relevant anti-corruption laws, is a legal obligation and not an option for suppliers and partners. Noncompliance with laws places GPM at risk of reputational, administrative, civil, and criminal consequences, including internal costs, investigations, prosecutions, fines, loss of contracts, and possible blacklisting.

5. Health and Safety

Suppliers and partners who do business with GPM are encouraged to maintain a focus on health and safety that is consistent with ours and must provide a safe and healthy work environment for all employees working at their sites.

6. International Trade Regulations

GPM suppliers and partners must adhere to all applicable trade and import regulations that apply to their activities, including those issued by the U.S. government and countries into which they will be importing goods or materials.

7. Labor Practices and Decent Work

GPM adamantly opposes the use of illegal labor, forced child labor, involuntary servitude, the exploitation of children, and all other forms of abusive or exploitative labor practices. It is GPM’s policy not to work with any supplier or partner known to operate with unacceptable worker treatment such as physical punishment, female abuse, involuntary servitude, discrimination in any form, or other form of abuse. GPM expects its suppliers and partners to take appropriate steps to ensure that their suppliers do not engage in any of these practices.

8. Environmental Protection and Climate Change Mitigation

GPM suppliers and partners shall comply strictly with the letter and spirit of environmental stewardship and all applicable laws, regulations, and international goals in understanding the importance of averting, minimizing, and addressing loss and damage associated with the adverse effects of climate change and the need to cooperate and enhance the understanding, action, and support in different areas such as early warning systems, emergency preparedness, and risk insurance.

9. Management Systems

To the extent permitted by law, GPM expects its suppliers and partners to have in place reasonable and appropriate systems through which allegations of wrongdoing may be investigated and remediated.

GPM expects that its suppliers and partners will fully investigate any and all allegations of wrongdoing with regards to these tenets within their own organizations. In addition, a supplier or partner must immediately notify GPM in writing upon becoming aware of any negative or other adverse publicity concerning the supplier or partner or any product being supplied to GPM by the supplier or partner, or any event or circumstance related to the supplier or partner, that could be expected to cause negative or other adverse publicity concerning GPM.

10. Summary

It is the responsibility of each supplier and partner to ensure that its employees and representatives understand and comply with this Supplier and Partner Code of Conduct.

Failure to adhere to this Supplier and Partner Code of Conduct may be grounds for terminating the supplier or partner relationship depending on the seriousness of the violation and the particular circumstances.

If you have any questions about this Supplier and Partner Code of Conduct, please contact your GPM liaison.

 

Updated March 12, 2025