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Supplier Code of Conduct

Introduction

At ACC we are guided by student success. Our on-campus and off-campus communities are more than wonderful places to live. Our communities are purpose-built to provide the environment, amenities, and resources students need to succeed, both academically and personally.

To achieve this goal, ACC is committed to upholding the highest standards of integrity, responsibility, and ethical behavior in all aspects of our operations. This Supplier Code of Conduct outlines the core values we expect all our suppliers to uphold, based on principles of respect for human rights, ethical business practices, and environmental sustainability. ACC is committed to protecting human rights and strives to develop sustainable responsibility in our sphere of influence.

Compliance with All Laws and Regulations

ACC requires our suppliers, consultants, vendors, and contractors and any subcontractors, agents, or providers that they use (collectively referred to herein as “suppliers”) to follow this Supplier Code of Conduct and all applicable local, national, and international laws, regulations, and standards in the countries where they operate. This includes, but is not limited to, environmental laws, labor laws, anti-corruption laws, and any other relevant regulations.

Labor Practices and Human Rights

We condemn all forms of human trafficking, modern slavery, and child labor and are committed to doing business only with those who have the same standards for human dignity. We are committed to ensuring fair treatment of all workers. We expect our suppliers to also uphold the dignity and rights of workers. Suppliers must follow these principles:
No Child, Slave, or Prison Labor
ACC condemns human trafficking and forced labor and will not work with suppliers who engage in these practices. Suppliers must ensure that they do not use involuntary prison labor and do not employ anyone against their will. Suppliers must not use forced, bonded, or indentured labor, and must not employ underage workers. The minimum age for employment should comply with all applicable laws, rules, and regulations. Additionally, suppliers must ensure that employees are free to resign their employment in accordance with applicable law, so that all work is voluntary.
Freedom of Association and Collective Bargaining
Open communication and direct engagement between workers and management are effective ways to resolve issues. Suppliers must respect workers’ rights to freely associate and bargain collectively without fear of retaliation or harassment.
Non-discrimination and Equal Opportunity
Suppliers must foster a work environment free from discrimination, harassment, or intimidation based on race, gender, age, religion, sexual orientation, disability, or any other protected status.
Fair Compensation and Benefits
Suppliers must provide fair compensation in line with minimum wage laws. Suppliers must ensure workers receive legally mandated benefits, and provide reasonable working hours and condition, including overtime pay and benefits.
Grievance Procedures
Suppliers must offer reasonable procedures for employees to bring workplace concerns to management.

Environmental Responsibility and Sustainability

We are committed to serving the communities where we live and work. We do this by exploring ways to address the broader challenges in society and minimizing our environmental footprint.

In alignment with ACC’s commitment to sustainability, suppliers should:
Sustainable Materials
Seek opportunities to utilize environmentally friendly and sustainable building materials in construction, renovation, and maintenance.
Waste Reduction
Reduce consumption, recycle, and responsibly dispose of waste materials, especially hazardous waste, during all phases of construction and operation.
Energy Efficiency
Implement practices that reduce energy consumption and carbon emissions. This includes incorporating energy-efficient systems and technologies into building designs and renovations.
Water Conservation
Explore and utilize water-saving technologies and practices in both construction and building operations.

Health, Safety, and Security

We foster a culture where health and safety are a daily priority. It is the right thing to do, and it promotes a caring and supportive work environment where all can thrive.

Suppliers must share in this commitment and provide a safe and healthy working environment, including appropriate safeguards against workplace hazards.

Suppliers must follow applicable workplace safety standards. Additionally, suppliers are required to ensure proper training for employees, and implement measures to prevent accidents, injuries, and occupational illnesses.

All construction activities must comply with OSHA (Occupational Safety and Health Administration) standards, or the equivalent local safety regulations, ensuring safe working conditions for all employees. All housing units and facilities must be designed and built to meet or exceed safety codes, fire safety standards, and security measures to protect student tenants.

Ethical Business Practices

We win and retain business due to the strength of our people, products, and community. We never bribe anyone at any time, or anywhere. We never accept or give anything of value to obtain preference or improperly influence others. Suppliers must share that commitment and adhere to the highest standards of integrity and business ethics.
No Bribery or Corruption
Suppliers must not engage in bribery, corruption, or unethical practices. All interactions must be conducted with honesty, fairness, and integrity.
Transparency
Suppliers must maintain transparent and accurate financial records and business dealings, avoiding any form of fraud or misrepresentation.
Gifts and Entertainment
Suppliers must avoid offering or accepting gifts or entertainment that could influence business decisions or create conflicts.
Conflicts of Interest
ACC expects suppliers will avoid conflicts of interests and situations that may have the appearance of a conflict of interest. Suppliers must disclose to ACC any material transaction or relationship that could give rise to an apparent or actual conflict of interest regarding its relationship with ACC.
International Trade and Export Controls
ACC expects suppliers to comply with all applicable import, export, customs, sanctions, embargoes, boycotts, and other trade compliance laws and regulations.
Confidentiality
We understand our responsibility to safeguard confidential information entrusted to us. This is critical to maintaining the confidence and trust of our employees, residents, and partners place in us. Suppliers must ensure that all confidential information shared by ACC is protected and not disclosed to unauthorized parties.
Data Protection
Suppliers must comply with data protection laws to safeguard personal information related to employees, contractors, and residents. This includes safeguarding sensitive data in compliance with applicable privacy laws, such as GDPR or CCPA.

Quality, Safety of Materials and Manufacturing Facilities

Suppliers must provide high-quality materials, services, and products that meet or exceed industry standards for durability, safety, and sustainability. All materials must meet or exceed quality and safety certifications (e.g., fire resistance, environmental sustainability standards, etc). Suppliers must ensure that all operations in the agreed upon manufacturing facilities comply with this Supplier Code of Conduct, particularly regarding labor standards, environmental impact, and safety.

Monitoring, Auditing, and Reporting

Suppliers must implement internal monitoring systems to ensure compliance with the law, regulations and with this Supplier Code of Conduct. ACC reserves the right to review supplier records or facilities to verify adherence to the Supplier Code of Conduct. Suppliers must take immediate corrective actions if any violations are identified during audits or through reported concerns. We have the right to terminate business with a supplier who fails to follow the Supplier Code of Conduct. A supplier must correct any actions to ensure compliance. Employees, customers, and suppliers can address any issues on a confidential and anonymous basis through our Ethics Hotline at 1-800-517-4032. Suppliers should report any known or suspected violations of the Supplier Code, laws, or regulations to legalservices@americancampus.com.

Continuous Improvement and Collaboration

ACC is committed to collaborating with suppliers who share our values and goals. Suppliers are encouraged to continuously improve their practices in alignment with evolving industry standards and legal requirements. We expect suppliers to engage with us to improve sustainability, labor conditions, operational efficiency, and ethical practices.
Innovation and Sustainability
Suppliers are encouraged to innovate and introduce innovative solutions that improve efficiency, sustainability, and quality in the development and maintenance of student housing.
Collaboration for Better Practices ACC encourages
ACC encourages dialogue with suppliers to address challenges and identify opportunities for improvement, fostering a culture of continuous learning and development.

Conclusion

By engaging with ACC, suppliers agree to uphold the principles outlined in this Supplier Code of Conduct. We are committed to creating safe, sustainable, and ethical student housing, and we value our suppliers as partners in this mission. Together, we will work to ensure that all aspects of our operations meet the highest ethical, environmental, and legal standards.