Supplier Compliance Policy
CBS strives to maintain throughout its global operations a work environment that reflects the highest standards of business ethics and workplace behavior, and is committed to legal compliance and ethical business practices in all of its operations worldwide. “CBS” means CBS Corporation, or its Affiliate(s) (individually or collectively, as the context may require). In furtherance of these standards, CBS expects all of its suppliers, service providers, and business partners(“Suppliers”) to comply with all applicable laws and regulations in the places in which they do business, to take strong measures to ensure that their suppliers do so as well, and to maintain the highest degree of ethics in every aspect of their business with CBS and others. CBS is firm in its resolve to do business only with those Suppliers who share its commitment to integrity and ethical business practices. CBS also supports and encourages diversity among its Suppliers and expects its Suppliers to do the same. As such, Supplier agrees to provide to CBS, upon request, evidence that it has implemented or is working to implement a Supplier diversity program and/or Supplier diversity policy. If Supplier does not have a Supplier diversity program or policy in place, Supplier will provide a statement describing its current position regarding diversity.
Accordingly, CBS expects strict COMPLIANCE with:
- All applicable anti-corruption and anti-bribery laws, including in all cases the United States Foreign Corrupt Practices Act, the United Kingdom Bribery Act, the Organization for Economic Cooperation and Development Convention on Combating Bribery of Foreign Public Officials in International Business Transactions, and United States anti-boycott laws;
- All applicable laws regarding fair trade including free competition, anti-trust laws, and intellectual property rights;
- All applicable laws regarding political contributions and payments;
- Maintaining accurate financial reporting systems and records relating to each Supplier’s dealings with CBS;
- All applicable laws prohibiting discrimination, harassment, human rights abuse and retaliation;
- All applicable laws regarding government contracting;
- All applicable laws regarding privacy, data and information security, including but not limited to United States federal and state data privacy, information security and data breach notification laws, the European Union General Data Protection Regulation (where applicable), and the CBS Data Protection and Security Requirements;
- Maintaining security and anti-piracy measures consistent with the highest level of security and generally maintained in the U.S. media industry to prevent theft, unauthorized copying or exploitation of CBS’ intellectual property;
- All applicable laws regarding imports, exports and manufacturing, including those related to importation or exportation of technology, and responsible sourcing such as the Dodd-Frank conflicts minerals regulations, and regulations concerning the import or export of goods containing prohibited animal wildlife, plant product or by product;
- All applicable laws respecting fair and ethical employment practices including those relating to child and forced labor, human trafficking, immigration, wages, days of service, rest periods, hours, overtime, benefits, leaves, and occupational health and safety. Suppliers must also comply with all applicable laws regarding freedom of association rights of workers, including the right to join or form trade unions or works councils of the their own choosing or to refrain from any such activities and the right to collectively bargain if permissible under applicable law; and,
- All applicable laws regarding the environment.
CBS policy PROHIBITS all of the following conduct by its Suppliers:
- Direct or indirect improper payments or offers of payment to any domestic or foreign government official or employee, as well as their representatives, agents or family members;
- Actual or perceived unethical or compromising conduct in relationships, actions and communications, such as the offering or giving of discounts, entertainment, meals, transportation, gifts or other favors or personal benefits to CBS employees other than as expressly provided in CBS’s Business Conduct Statement (“BCS”) which can be found at www.cbscorporation.com. Printed copies of the BCS are available upon request;
- Anti-competitive business practices and non-adherence to applicable local and international antitrust laws;
- Use of CBS’s name, assets (including, without limitation, its intellectual property), facilities or services without prior written authorization or for any improper purpose;
- Disclosure of CBS’s confidential and proprietary information to any third party (including, without limitation, the press) without prior written authorization;
- Acts of sexual, physical, mental or any other form of harassment, retaliation, abuse or improper discrimination in the workplace and in any work-related setting outside the workplace, such as during business trips, business meetings and business-related social events;
- Employing workers in breach of applicable labor and wage laws, immigration laws, applicable minimum age of work laws or any other form of forced or compulsory labor, including unlawful child labor;
- Employing workers by means of force, threats of force or physical restraint, or by means of actual or threatened abuse of law or legal process, or by any other means of scheme, plan or pattern intended to cause the person to believe that if that person did not perform such labor or service, that person or another person would suffer serious harm or physical restraint; and,
- Behavior that violates import or export laws, United States sanctions laws as promulgated by the United States Department of Treasury Office of Foreign Asset Control, or is otherwise in violation of applicable global trading laws.
CBS cooperates with law enforcement authorities in the proper execution of their responsibilities. CBS also collaborates with its Suppliers on educational programs and other efforts to enhance legal compliance in their industries.
By contracting with CBS, each Supplier is representing and certifying to CBS that it is in compliance with the Policy set forth above. Should any Supplier discover that it or any of its subcontractors, employees or agents is not in compliance with this Policy, it must promptly provide written disclosure to CBS.
All subcontractors must be disclosed to CBS prior to their use and CBS reserves the right to object to the use of any such subcontractor at any time. Each CBS Supplier is responsible for ensuring its employees, agents and subcontractors comply with this Supplier Compliance Policy.
CBS also reserves the right to survey, inspect or audit its Suppliers with respect to CBS business. Such surveys, inspections or audits may be conducted by CBS or its authorized representative such as an outside law firm, accounting firm or other independent third party. Audits may entail on-site inspections (whether announced or unannounced), interviews of Suppliers’ employees or agents or examining third-party environmental certifications. If it is found that a Supplier has committed one or more violations of this Policy, CBS will take action as it determines is warranted. Such action may include oral or written reprimand, , suspension or immediate termination of contract or business relationship or any other disciplinary action or combination of actions as deemed appropriate under the circumstances, including commencing legal action against such Supplier.1
For any questions regarding CBS’s Supplier Compliance Policy, please contact a CBS Compliance Officer, call the CBS OpenLine, the compliance telephone line at 1-877-CBS-0888 or 1-212-975-9913 or send an e-mail from any location to CBSOpenLine@cbs.com. The BCS identifies, and contains instructions on, the various means of communicating with CBS’ Compliance Officers.
1 Nothing herein is intended to create an employment relationship with a Supplier’s employees or agents, to infringe upon the freedom of association rights of a Supplier’s employees or agents, or to create new or additional third party or Supplier employee rights.