Vendors Code of Business Conduct and Ethics
Altisource Portfolio Solutions S.A. and its subsidiaries (collectively, “Altisource”, “we” or “our”) expect its vendors and suppliers to observe the highest standards of business practices, professional conduct and community stewardship. This Vendor Code of Business Conduct and Ethics (“Code”) sets forth fundamental principles and policies with which you are required to comply, to the extent applicable, while providing services for Altisource and its clients.
As an Altisource vendor, you, your employees and your agents (collectively, “you” or “your”) are required to conduct business in compliance with (a) all governing laws and regulations and (b) the terms of the Altisource Code of Business Conduct and Ethics that may apply to you as a vendor, and (c) with the following terms:
Ensure Quality in All Work
Altisource requires that you perform work of the highest quality, in a timely manner and that is in accordance with service level requirements, guidelines, local standards and best practices. We have a responsibility to our clients, our clients’ investors and the communities we serve to ensure that properties in our care are inspected, preserved and maintained to the highest standards. Your performance is critical to minimizing risks and preserving the value of the properties you service.
Proactively Identify and Reduce Risks
As our representatives, you are required to proactively identify, escalate and minimize safety, reputational and financial risks. To meet this requirement, you are required to implement best practices in your operations that address avoidable risks, including neighborhood blight, life safety hazards and illegal activity.
Proactively Implement Processes to Comply with Changing Regulatory Requirements
Due to the constant frequent change of regulatory requirements in our industry, Altisource requires that you are proactive in adopting and implementing process changes to comply with all applicable laws, regulations, codes, policies and procedures and contractual requirements. Your adjustments need to maintain pace and evolve with the industry to prevent you, Altisource, our Altisource’s clients, our client’s and investors, and the communities we serve from incurring unnecessary risk. While not intended as an exhaustive list of responsibilities, you are required to: (i) address regulatory requirements with the most reasonably conservative interpretation (i.e., that minimizes risk); (ii) monitor regulatory, local and community stakeholder feedback with vigilance; and (iii) implement policies to exceed the minimum requirements of laws, regulations and community standards. In addition, you shall: (ai) communicate to Altisource any changes in applicable legal requirements; and (bii) promptly pass through any communications received from any regulatory body regarding, or in any way related to, Altisource or the services provided to Altisource.
Maintain Strict Confidentiality
You are prohibited from disclosing any information regarding Altisource, our clients, mortgagors, the properties you serve and the work you perform to any third party or the general public. This limitation extends to representatives of the media, community stakeholders and public forums (e.g., social media). If you receive a court order or regulatory demand that seeks to compel the disclosure of such information, you must immediately inform Altisource pursuant to the means identified at the end of this Code.
Demonstrate Professional and Respectful Behavior At All Times
You represent Altisource when interacting with the public and external parties. As such, you are expected to act with integrity while maintaining the highest professional, ethical and respectful behavior. This requirement applies regardless of the situation or environment in which you are performing services.
Practice Equal Employment Opportunity and Nondiscrimination
Altisource is an equal opportunity employer in hiring and promoting practices, benefits and wages. Altisource does not tolerate discrimination against any person on the basis of race, color, creed, religion, national origin, ancestry, citizen status, age, sex or gender (including pregnancy, childbirth, or related medical conditions), gender identity or expression (including transgender status), sexual orientation, marital status, military service and veteran status, physical or mental disability, genetic information, or other characteristic protected by law in recruiting, hiring, placement, promotion or any other condition of employment. Altisource does not tolerate discrimination in the performance of your work in our communities or against Altisource, our clients, or any mortgagor. You are required to comply with these same standards and inform Altisource of any improper conduct pursuant to the means identified at the end of this Code.
Enforce a Zero-Tolerance Policy for Drugs and Alcohol Use Onsite
You are precluded from possessing or using alcohol, drugs or any other legal or illegal substance that may decrease your mental and/or physical capacity while providing services for Altisource and in transit to or from providing such services. You are required to comply with our zero tolerance policy and promote the same within your organization’s culture.
Avoid Conflicts of Interest
To avoid any potential conflicts of interest, you may not purchase any real property where you provide services for Altisource. This restriction also applies to your immediate family members.
Do Not Offer or Accept Entertainment, Gifts and Gratuities
You are prohibited from providing or offering any gifts, entertainment or other benefits to any person who could influence or have the perception of influencing Altisource’s business decisions as they relate to you. In addition, you are disallowed from accepting gifts, entertainment or other benefits from individuals or companies conducting business with Altisource. You are required to inform Altisource of any improper conduct pursuant to the means identified at the end of this Code.
Respect and Promote Human Rights
You shall embed respect for human rights into your business operations. You shall not: (i) employ any child labor; or (ii) use any compulsory, involuntary or forced labor which include slavery, forced contract, human trafficking and any other forms of work that are done against worker's will. You shall comply with the terms and spirit of the Altisource Human Rights Statement available at www.altisource.com/humanrights.
Respect Workers Rights
You shall: (i) comply with all applicable labor laws and regulations (including, but not limited to, any applicable wage, working hours, and benefits laws and regulatory requirements); (ii) ensure that workers are provided with a safe and healthy work environment and take necessary precautions to prevent accidents and injury; (iii) conform with any relevant conventions of the International Labour Organization; and (iv) respect workers’ rights to freedom of association and collective bargaining.
Be Thoughtful towards the Environment
You shall be duly committed to protect the environment and will comply with the standards and requirements of the applicable laws and regulations. You shall comply with the terms and spirit of the Altisource Environmental Policy available at https://www.altisource.com/environmental-policy and seek to minimize your impact on the environment in connection with your performance of services. Altisource may audit your environment management processes and practices.
You May Be Subject To Supply Chain Audits
Altisource may perform audits to its supply chain. You are responsible for fully cooperating with any audit or investigation that is related to the services you provide to Altisource. Unless otherwise precluded by law, you are required to immediately notify Altisource of any such audit or investigation.
Altisource reserves the right to: (i) assess your compliance with the requirements and expectations outlined in this document; and (ii) terminate or modify your engagement, in case you are not willing or able to implement reasonable improvements to align your operations and/or practices with this document.
Altisource Vendor Portal to Report Risks and Illegal and Improper Activities
You are encouraged to immediately report any activity that presents a potential safety, reputational or financial risk to Altisource, our clients, our clients’ investors and the communities we serve, including any violations of this Code, breaches of contractual obligations, fraud and violations any laws or regulations. All reporting is anonymous and confidential.