MarketOne Code of Conduct


Table of Contents

MarketOne’s Code of Conduct signifies commitment to ethical corporate citizenship. We demonstrate this commitment through transparent and responsible management of our social, environmental, and ethical programs and initiatives. MarketOne is a global company and we practice corporate social responsibility everywhere we conduct business. This code of conduct is not intended to replace or supersede employee handbooks issued within each office’s jurisdiction. Rather, the Code of Conduct is supplementary to local policies, and describes MarketOne’s corporate position on codes of conduct.

We expect our employees, representatives, agents, and suppliers (together “party” or “parties”) to be equally committed to the highest standards of business behavior. If a party fails to meet the requirements of this Code of Conduct, MarketOne will review the nature of the violation and proceed with an applicable disciplinary proceeding, or in the event of a supplier, may make a determination to not award new business or to terminate an existing agreement(s).

Parties, in all of their activities, will operate in full compliance to all laws, rules and regulations of the countries in which they operate and will conform to the following Code elements:

  • Values and Ethical Dealings
  • Human Rights
  • Anti-Corruption, Anti-Bribery
  • Disclosing/Avoiding Conflicts of Interest
  • Non-disclosure and Handling of Non-Public Insider Information
  • Environmental Impact
  • Non-Discrimination and Non-Retaliation
  • Employee Grievance and Concern Notification

This Code is not intended to create new or additional rights for any third party. In the event of any duplication with local laws and regulations, the tighter requirements will apply.


Values & Ethical Dealings

MarketOne’s own Code of Conduct requires our employees to uphold the highest ethical
standards. In addition, our procurement values encompass:

  • A customer service-oriented approach which focuses on understanding the wants and needs of the entire supply chain.
  • An innovative and entrepreneurial spirit that continually seeks to improve our responsible and sustainable sourcing.
  • Accuracy, honesty, fairness and true cross-functional participation in making business decisions that are based on carefully understood facts.
  • Trustworthiness and integrity in ensuring MarketOne, its employees, clients and suppliers keep to the letter and spirit of all agreements.
  • Teamwork, respect and excellence in building long-term relationships.
  • Strict compliance with all laws and regulations on bribery, corruption, anti- competition and any other prohibited business practices. No gift, favor or entertainment may be solicited, accepted or provided if it will obligate or appear to obligate the person who receives it.
  • Protection of MarketOne’s, clients’ and suppliers’ assets and reputations.


Human Rights

MarketOne is committed to respecting human rights in everything we do. We support universal human rights including those identified in the following:

  • United Nations Universal Declaration of Human Rights.
  • International Labor Organization (ILO) Declaration on Fundamental Principles and Rights at Work.
  • United States Federal Acquisition Requirements (FAR) on Combating Human Trafficking.

We manage our operations consistent with these standards. Parties are required to comply with all similar standards everywhere they operate or where our products are sold. We prohibit any party from any involvement relating to any human rights abuses including, but not limited to, the below:

  • Child labor, forced labor, coercion, involuntary servitude, slavery, debt bondage.
  • Conducting any form of sex trafficking or business activities involving or supporting commercial sex acts.
  • Destroying, concealing, confiscating, denying access to, etc. any employee’s
    identity or immigration documents.
  • Using misleading or fraudulent recruitment practices which fail to disclose all key terms of employment or using recruiters who do not comply with local laws.
  • Charging recruitment fees to employees.
  • Failing to provide return transportation at the end of employment as required by regulation.
  • Providing housing that does not meet host country standards.
  • Failing to provide an employment contract or other work documents when required by law.

Additionally, MarketOne may require certain suppliers to develop a compliance plan with the following components and certify compliance as follows:

Compliance Plan

  • An awareness program to inform parties about MarketOne’s policy prohibiting human trafficking-related activities, the activities prohibited, and the actions that will be taken if violations occur.
  • A process for employees to report, without fear of retaliation, activity inconsistent with the policy prohibiting trafficking in persons, including a means to make available to all employees the phone number of the Global Human Trafficking Hotline, 1-844-888-FREE, and their email address,
  • A recruitment and wage plan that only permits the use of recruitment companies with trained employees, prohibits charging recruitment fees to the employee, and ensures wages meet applicable host-country legal requirements or explains any variance.
  • A plan, if housing is provided, that ensures host country housing and safety standards are met.
  • Procedures to prevent suppliers at any tier and at any dollar value from engaging in trafficking in persons and terminating offending suppliers if they have engaged in such activities.
  • Posting of the plan at the workplace.


Anti-Corruption, Bribery, Kickbacks

Employees, Contractors, and representatives of MarketOne communicate and transact with Customers, Prospects, Partners, Vendors and other 3rd parties every day. It is expected that all such interactions are free of corruption, bribery, and kickbacks. Relevant laws designed to control corruption, bribery and kickbacks include:

  • U.S. Foreign Corrupt Practices Act (“FCPA”)
  • UK Bribery Act
  • OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions

As a company, we will not tolerate, permit, or engage in any form of corruption, extortion, or bribery; whether we are working with government officials or individuals in the private sector. Each of us at MarketOne has a duty to ensure these laws are followed, and any real or suspected violation must be promptly disclosed to company management. Here are some definitions:

  • Bribery is offering or giving something of value in order to improperly influence the recipient’s actions. Bribery is illegal everywhere MarketOne does business, and the consequences for offering or accepting a bribe are severe. You may never offer, authorize, give, promise, or accept any form of a bribe, extortion payment, improper payment, gift, or benefit while working on MarketOne, its clients’ or Partners’ behalf.
  • A kickback is the return of a sum paid (or due to be paid) as a reward for fostering a business arrangement. Accepting or offering a kickback violates this Code of Conduct.
  • A facilitation payment is a tip or small payment made to a government official in order to expedite a routine government action—for example, issuing a permit or providing utility service. These payments are illegal in most jurisdictions and are not allowed under MarketOne’s policies.


Conflict of Interest

Conflict of interest is about transparency and disclosure. As part of our commitment to transparency, MarketOne must avoid conflicts of interest. All employees, Contractors, Suppliers and Partners should disclose actual or potential conflicts of interest relating to activities working for our clients or with our Partners, negotiating with prospects, and any other 3 rd Party. Some examples of situations that could create conflicts of interest include:

  • Loans or favors that we as a vendor, worker, or family member receives through a relationship with a Client or Partner
  • Improper advantages gained by acting on information learned through a relationship with a Client or Partner
  • Business opportunities that belong to Partners

If you believe you have, or may have, a conflict of interest with an outside Party, you must disclose this to HR or company management.


Non-disclosure and Handling of Non-Public Insider Information

As an employee, contractor, or supplier of MarketOne, you have signed a non-disclosure agreement (NDA) that protects confidential information of not just MarketOne, but also of Clients and Partners. It is vital that you adhere to the provisions of the agreement for the protection of all Parties.

As a MarketOne employee or contractor, you may have access to material, non- public information about MarketOne’s Clients or Partners. Information is material if a reasonable investor would consider it important in deciding whether to buy, sell, or hold a company’s securities. You must never buy or sell securities while in possession of material, non-public information or provide that information to others who might trade on it.


Environmental Impact

MarketOne expects employees to meet all applicable environmental requirements for all company activities and services, including legal requirements, standards, and voluntary commitments to which MarketOne subscribes. We are also committed to reducing environmental impacts and conserving natural resources by using sustainable business practices, and therefore employees are required to demonstrate environmental leadership in the following:


Employees are required to prevent pollution, manage water use and dispose of waste safely and responsibly. This includes programs to:

  • Minimize water use and maximize water recycling.
  • Minimize waste generation and maximize waste recycling and reuse.
  • Report program efforts and actuals per EICC or CDP protocols upon request.


Non-Discrimination and Non-Retaliation

MarketOne is an equal opportunity employer. As such, MarketOne offers equal employment opportunities without regard to race, color, gender, religion, age, nationality, social or ethnic origin, sexual orientation, gender identity or expression, marital status, pregnancy, disability, veteran status or any other characteristic protected by law. These opportunities include all terms, conditions, and privileges of employment, including but not limited to recruiting, hiring, job placement, training, compensation, benefits, discipline, advancement, and termination.

Our employees and suppliers are expected to adhere to both the spirit and the letter of this MarketOne policy. The exercise of rights protected by applicable country, state and local equal employment opportunities laws such as filing complaints, participating in investigations, compliance reviews and related administrative proceedings, and lawfully opposing unlawful practices under these laws is protected activity for which harassment, intimidation, threats, coercion or discrimination will not be tolerated.


Employee Grievance and Concern Notification

Employees are welcome to report questionable behavior or a possible violation of this Code of Conduct to MarketOne. Additionally, they may contact the Global Human Trafficking Hotline as noted below.

MarketOne Reporting

You are encouraged to work with your primary MarketOne contact in resolving your concern. If that is not possible or appropriate, please contact MarketOne via email at:

MarketOne will maintain confidentiality to the extent possible and will not tolerate any retribution or retaliation taken against any individual who has, in good faith, sought out advice or reported questionable behavior or a possible violation of this Code of Conduct.

Global Human Trafficking Reporting

Please contact the Trafficking Hotline at 1-844-888-FREE or its email address at

Additional Resources