Singularity University is committed to building a community of inclusion, collaboration, and deep connection while adhering to the highest standards of ethical, social and environmental responsibility. We do no harm and refuse to compromise others for our own benefit. We are creating a future of abundance that respects the health, safety and dignity of humanity. We strive to provide safe working conditions, treat others with dignity and respect, act fairly and ethically, and use environmentally responsible practices. We believe that our community is integral to joining us to set an example for changing the world. We must collectively commit to doing no harm and refuse to compromise others for our own benefit.

Businesses that associate themselves with Singularity University’s brand, including suppliers, subcontractors, channel partners, program participants and affiliates (“You” or “Your”) are partners within the Singularity University ecosystem and must operate in accordance with this Community Code of Conduct (“Code”). This Code outlines Singularity University’s expectations for Your conduct regarding labor and human rights, health and safety, environmental protection, ethics, and management practices. You are responsible for ensuring that all employees, independent contractors, consultants and all others who do business for You or on Your behalf understand and comply with all provisions of this Code. It applies to those providing goods or services to SU and those marketing, selling or participating in SU
programs, events and products.

1. Compliance and Laws. Code goes beyond mere compliance with the law by drawing upon internationally recognized standards to advance social and environmental responsibility. When differences arise between standards and legal requirements, the stricter standard shall apply, in compliance with applicable law. SingularityU will assess Your compliance with this Code, and any violations of this Code may jeopardize Your business relationship with SingularityU, up to and including termination of our relationship.

2. Labor and Human Rights. We believe Your employees, and affiliates in our community deserve a fair and ethical workplace. Workers must be treated with the utmost dignity and respect, and You will uphold the highest standards of human rights.

3. Anti-Discrimination. You shall not discriminate against any worker based on age, disability, ethnicity, gender, marital status, national origin, political affiliation, race, religion, sexual orientation, gender identity, union membership, or any other status protected by applicable national or local law, in hiring and other employment practices. You shall not require pregnancy or medical tests, except where required by applicable laws or regulations or prudent for workplace safety, and shall not improperly discriminate based on test results.

4. Anti-Harassment and Abuse. You shall commit to a workplace free of harassment and abuse. You shall not threaten workers with, or subject them to, harsh or inhumane treatment, including but not limited to verbal abuse and harassment, psychological harassment, mental and physical coercion, physical assault, and sexual harassment.

5. Prevention of Involuntary Labor and Human Trafficking. You shall ensure that all work is voluntary. You shall not traffic persons or use any form of slave, forced, bonded, indentured, or prison labor. Involuntary labor includes the transportation, harboring, recruitment, transfer, receipt, or employment of persons by means of threat, force, coercion, abduction, fraud, or payments to any person having control over another person for the purpose of exploitation. You shall ensure that workers’ contracts clearly convey the conditions of employment in a language understood by the workers. Workers shall not be required to pay employers’ or their agents’ recruitment fees or other similar fees to obtain their employment. If such fees are found to have been paid by workers, such fees shall be repaid to the worker. You shall ensure that the third-party recruitment agencies it uses are compliant with the provisions of this Code and the law.

6. Juvenile Worker Protections. You may employ juveniles who are older than the applicable legal minimum age but are younger than 18 years of age, provided they do not perform work that might jeopardize their health, safety, or morals, consistent with ILO Minimum Age Convention No. 138. You shall not require juvenile workers to work overtime or perform nighttime work.

7. Student Worker Protections. You shall ensure proper management of student workers through proper maintenance of student records, rigorous due diligence of educational partners, and protection of students’ rights in accordance with applicable law and regulations. You shall provide appropriate support and training to all student workers.

8. Working Hours. You shall follow all applicable laws and regulations with respect to working hours and days of rest, and all overtime must be voluntary.

9. Wages and Benefits. You shall pay at least the minimum wage and provide any benefits required by law and/or contract. You shall compensate workers for overtime hours at the legal premium rate. All use of temporary and outsourced labor shall be within the limits of the local law.

10. Health and Safety. Worker health, safety, and well-being is important to SingularityU. You shall provide and maintain a safe work environment and integrate sound health and safety management practices into its business. Workers shall have the right to refuse unsafe work and to report unhealthy working conditions.

11. Environment. SingularityU is committed to protecting the environment, and environmental responsibility is at the core of how we operate. You shall develop, implement, and maintain environmentally
responsible business practices.

12. Wastewater Management,Stormwater Management,Air Emissions Management. You shall implement a systematic approach to identify, control, and reduce wastewater produced by Your operations. You shall conduct routine monitoring of the performance of its wastewater treatment systems.You shall identify, manage, reduce, and responsibly control air emissions emanating from its operations that pose a hazard to the environment. You shall conduct routine monitoring of the performance of its air emission control systems.

13. Ethics. SingularityU expects the highest standards of ethical conduct in all of our endeavors. You shall always be ethical in every aspect of its business, including relationships, practices, sourcing,
and operations.

14. Business Integrity. Corruption, extortion, bribery or embezzlement, in any form, are strictly prohibited.

15. Money Laundering. You may not engage in or assist others in concealing illicit funds or money laundering activities. The following are sample indicators of money laundering that merit further investigation by You:

• Attempts to make large payments in cash
• Payments by (or to) someone who is not a party to the contract
• Requests to pay more than provided for in the contract
• Payments made in currencies other than those specified in the contract
• Payments from an unusual, non-business account

21. Anti-Corruption. You agree to comply with all applicable laws and regulations enacted to combat bribery and corruption, including the United States Foreign Corrupt Practices Act, the UK Bribery Act, the principles of the OECD Convention on Combating Bribery of Foreign Public Officials, and any corresponding laws of all countries where business will be conducted or Services performed pursuant to this Agreement. You shall not, and shall ensure that You Personnel do not, directly or indirectly, pay, offer, promise to pay, or give anything of value (including any amounts paid or credited by SingularityU to You) to any person or entity, including an employee or official of a government, government controlled enterprise or company, or political party, with the reasonable knowledge that it will be used to obtain any improper benefit or to improperly influence any act or decision by such person or entity. You shall not, and shall ensure that your personnel do not, offer or accept bribes or kickbacks in any form.

22. Disclosure of Government Related Parties. If, at any time in the course of representing your affiliation with SingularityU, You interact with a government entity, You represent and warrant that You have, to the best of your knowledge and to the extent permitted by law, provided SingularityU with complete and accurate information regarding any of your majority owners, partners, officers, directors, or managers of, and of any subcontractor performing any portion of the services on your behalf (collectively, “Your Authorized Parties”) that is, has been or will become, an official or employee of a governmental entity or political party or a candidate for political office (each, a “Government Related Party”). If at any time during the Term of this Agreement, You become aware, or otherwise have reason to believe, that any of Your Authorized Parties is, has been or will become, a Government Related Party, then, to the extent permissible by law, You shall promptly notify SingularityU in writing.

23. Trade Restrictions, Export Controls and Customs. All transactions must comply with U.S. export and customs laws and additional export and customs laws in the countries where business is being conducted. If Your business activities involve the sale of SU products, technologies, or services across international borders You must understand and ensure compliance with all laws or restrictions that apply in connection with those activities.

24. Disclosure of Information. You shall accurately record information regarding Your business activities, labor, health and safety, and environmental practices and shall disclose such information, without falsification or misrepresentation, to SU and all appropriate parties and as required by law.

25. Protection of Intellectual Property. You shall respect intellectual property rights and safeguard customer information. You shall manage technology and know-how in a manner that protects intellectual property rights.

26. Whistleblower Protection and Anonymous Complaints. You shall provide an anonymous complaint mechanism for Your managers and workers to report workplace grievances. You shall protect whistleblower confidentiality and prohibit retaliation.

27. Community Engagement. You are encouraged to help foster social and economic development and contribute to the sustainability of the communities in which it operates.

28. Company Statement. You shall develop a company statement affirming its commitment to high standards of social and environmental responsibility, ethical conduct, and continuous improvement. You shall post this statement in the primary local language at all of its facilities.

29. You will permit SingularityU and a third party designated by SingularityU to periodically evaluate Your facilities and operations, and those of Your subcontractors and next-tier suppliers, to the extent they are providing goods or services to SingularityU, for SingularityU’s benefit, or for use in SingularityU products.

30. Documentation and Records. Suppliers shall maintain appropriate documents and records to ensure regulatory compliance.

31. Training and Communication. You shall develop and maintain management and worker training programs to facilitate proper implementation of its policies and procedures and to fulfill Your continuous improvement objectives.

32. You shall have a process for communicating clear and accurate information about Your performance, practices, policies, and expectations of Your workers, next-tier supplier(s), and customers.

33. You shall have an ongoing process to obtain feedback on Your practices related to this Code and to foster continuous improvement.

34. Process to Receive and Investigate Reports of Violations. You must have in place a process whereby Your employees, independent contractors, consultants, and others who do business for or on Your behalf can safely and confidentially report violations of this Code to the Your management, and to do so anonymously (subject to local legal restrictions on anonymous reporting). You must promptly investigate any observed or reported violations of this Code.

35. Whistleblower Protection. You must create programs to ensure the protection of whistleblower confidentiality and to prohibit retaliation against workers who participate in such programs in good faith or refuse an order that is in violation of this Code.

36. Corrective Action Process. You must have a process for timely correction of any deficiencies or violations of this Code identified by any internal or external audit, assessment, inspection, investigation or review.

37. SU Program Participation. SingularityU is committed to the health, safety, and dignity of participants in SingularityU programs and to SingularityU employees and visitors. Accordingly, if You, Your employees, or Your customers participate in SingularityU programs and events, including during lectures, time spent in NASA accommodations, off site visits and transportation to and from events, you are prohibited from engaging (physically or digitally) in disruptive, threatening, violent, or discriminatory behavior, or unwelcome sexual advances.

• Disruptive behaviors include yelling, using profanity, waving arms or fists, verbally (or in writing) attacking or abusing others, and refusing reasonable requests to change your behavior when requested by a member of SingularityU staff.

• Threatening behavior includes physical actions short of actual contact or injury (such as moving aggressively into another’s personal space), as well as direct or implied oral or written threats to people or property.

• Violent behavior includes any physical assault, with or without weapons; behavior that a reasonable person would interpret as being potentially violent (throwing things, pounding your fist on a desk or door, or destroying property); or specific threats to inflict physical harm.

• Discriminatory behavior includes any type of harassment that creates an intimidating, hostile, or offensive environment for participants in SingularityU programs or events, or for SingularityU employees or guests, including, but not limited to, verbal, visual, or physical conduct that discriminates on the basis of sex, race, sexual orientation, national origin, color, religion, age, disability, or veteran’s status.

• Unwelcome sexual advances include: (i) graphic or degrading comments about an individual or his or her appearance; (ii) the display of sexually suggestive objects or pictures; (iii) subtle or overt pressure for sexual activity; and (iv) physical contact or blocking movements.

This Code references internationally accepted principles such as the Electronic Industry Code of Conduct, Ethical Trading Initiative, International Labor Organization’s (ILO) International Labor Standards, Social Accountability International, SA 8000, ILO Code of Practice in Safety and Health, National Fire Protection Association, OECD Guidelines for Multinational Enterprises, and OHSAS 18001.