Introduction
Anthology Inc. and its subsidiaries and affiliates (including Blackboard Inc., Edcentric Inc., and their respective subsidiaries worldwide) (collectively, referred to herein as “Anthology”) is committed to business ethics and regulatory compliance as described in Anthology’s Code of Business Conduct and Ethics. We emphasize integrity, respect, and fairness in all interactions. This dedication builds strong relationships with customers, partners, and employees- fostering a positive corporate culture and enhancing the company's reputation. The Anthology Supplier Code of Conduct (“Code”) applies to all third parties providing products and services to Anthology including subcontractors and agents, collectively termed "Suppliers.", and sets out Anthology’s expectation for its Suppliers.
General Business, Legal & Ethical Conduct
Suppliers must understand and comply with applicable laws. They must refrain from fraudulent behavior and maintain appropriate business ethics. Suppliers are expected to implement and maintain appropriate legal and compliance frameworks (including policies, procedures and training) that facilitate compliance with applicable laws and regulations and management of legal and compliance risks.
Financial crime
Suppliers must comply with all applicable sanctions, anti-money laundering, anti-corruption, and anti-bribery laws and regulations (e.g., U.S. Foreign Corrupt Practices Act). Suppliers must understand the financial crime risks applicable to them and ensure they have appropriate controls to manage and minimize these risks.
Conflicts of Interest
Suppliers are required to implement appropriate frameworks (including policies, procedures, and training) to avoid any conflicts of interest and manage any conflicts of interest appropriately.
Gifts and Entertainment
Suppliers must implement appropriate frameworks (including policies, procedures, and training) to manage the giving and receiving of gifts, entertainment, and hospitality, particularly related to dealings with government officials. Generally, Suppliers should not offer Anthology staff (or their families) gifts, entertainment, or hospitality valued at over $ 100 per gift.
Accessibility
Suppliers must understand and comply with applicable accessibility laws (e.g., Americans with Disabilities Act, Section 508 of the Rehabilitation Act of 1973, EN 301 549) and guidelines (Web Content Accessibility Guidelines). Suppliers must have appropriate frameworks (including people, policies, procedures, and training) in place to adequately respond to accessibility issues and stay up to date with regulations.
Labor Related
Modern Slavery
Suppliers must not tolerate any form of slavery, forced labor, or human trafficking within their business. Suppliers are expected to have standards equivalent to those in Anthology’s Modern Slavery Statement and have appropriate processes for managing the risks associated with modern slavery within their businesses. Suppliers are expected to inform Anthology immediately should they become aware of any actual or suspected slavery, forced labor, or human trafficking in their business or supply chain with respect to respect of any products and/or services supplied to Anthology.
Equal Opportunity/Anti-Discrimination
Suppliers are expected to show commitment to the principles of equal employment opportunity, inclusion and respect. Suppliers are required to avoid discrimination based on legally protected characteristics such as race, color, religion/religious creed, national origin, ancestry, sex (including pregnancy), age, physical or mental disability, sexual orientation, gender identity/expression, marital status, genetic information, protected military/veteran status.
Suppliers must comply with laws regarding employment of immigrants and noncitizens and provide equal employment opportunity to everyone who is legally authorized to work in the applicable country. Suppliers are expected to provide accommodation for individuals with disabilities as required by applicable law and remove any artificial barriers to success.
Fair Wages
Suppliers must follow all applicable wages and hourly laws and regulations.
Workplace Environment
Suppliers are required to establish policies and procedures and require their staff to adhere to all environmental, health, safety, and security policies and procedures. The supplier is expected to promptly address or report any threats related to providing products or services to Anthology. Suppliers must ensure that workplace violence is prohibited. Workplace violence includes not only physical acts or threats but also any behavior that is severe, offensive, or intimidating enough to make someone fearful for their own safety or that of their family or property.
Harassment
Suppliers are expected to provide a work environment free from harassment based on any protected category, regardless of whether the harasser is a co-worker, supervisor, manager, customer, supplier, contractor/consultant, or visitor. Harassment can include any behavior (verbal, visual, or physical) that creates an intimidating, offensive, abusive, or hostile work environment.
Environmental Safety
Suppliers are expected to implement an appropriate framework to meet their legal and ethical obligations regarding the protection of the environment, including adopting a responsible environmental policy that complies with applicable local, national, and global environmental laws. This includes adherence to regulations regarding greenhouse gas emissions, hazardous materials, waste management and disposal, recycling, industrial wastewater treatment and discharge, air emissions controls, and any necessary environmental permits and reporting.
Confidentiality, Privacy, AI, and Security, Supply Chain Risk Management
Confidentiality
Suppliers are required to be knowledgeable about and comply with any specific confidentiality terms in their agreements with Anthology. Confidential information must be protected appropriately and only be used or disclosed for legitimate business purposes and as permitted in the agreement with Anthology.
Privacy, AI, and Security
Suppliers must implement and maintain appropriate privacy, responsible AI and security programs to facilitate compliance with applicable privacy / data protection, AI and security laws and regulations and management of privacy, responsible AI and security risks.
Supply Chain Risk Management
Suppliers are expected to develop their own policies, codes and procedures to ensure that their suppliers meet the obligations in this Code and to ensure that supply chain risk is managed appropriately. Suppliers are expected to conduct appropriate due diligence before engaging new Suppliers and to monitor their Suppliers as appropriate.
Reporting Concerns and Violations
You can report any violation or suspected violation of this Code by reaching out directly to the company’s General Counsel at [email protected] or the company’s Compliance Officer at [email protected].
Additionally, you may utilize the company’s ethics hotline at https://bbethicshotline.ipm.starcompliance.com/#landing to report any violation of this Code, report potential fraud, abuse, corruption, or to report any other ethical concern. While it is preferred that you identify yourself when reporting violations through the ethics hotline — as this allows for necessary follow-up and additional information gathering — you have the option to report anonymously in accordance with local laws applicable to your location.
Anthology prohibits any form of retaliation against individuals who, in good faith, report violations or suspected violations of this Code, company policies, applicable laws, or who assist in the investigation of reported violations. Suppliers are expected to meet the obligations in this Code and to act in good faith while conducting business with Anthology or its partners. Acting in good faith entails that all reports of potential violations are made sincerely and honestly.
Suspension and Termination
If a Supplier is unable to meet the standards of this Code or fails to comply with applicable laws and regulations, Anthology reserves the right to suspend or terminate its relationship with the Supplier in accordance with the contractual agreement with the Supplier, and/or disclose the matter to the appropriate authorities.
Created Date: 01-22-2025