1. Purpose

Call Simulator Inc. (“Call Simulator,” “Company,” “we,” “our”) is committed to ethical, legal, and responsible business practices. This Ethical Sourcing Policy outlines our expectations for all suppliers, vendors, contractors, and service providers who support our operations. Our goal is to ensure that every product or service procured aligns with our values—particularly in upholding human rights, promoting environmental sustainability, and actively preventing fraud and corruption throughout the supply chain.

2. Scope

This policy sets forth minimum expectations and standards and applies to all Call Simulator, Inc. personnel engaged in procurement, vendor management, and strategic sourcing, as well as to all suppliers, vendors, contractors, and business partners globally.

3. Ethical Sourcing Principles

3.1. Labor and Human Rights

Suppliers are expected to:

• Comply with all applicable labor laws and international human rights standards;
  
• Prohibit all forms of forced, bonded, or indentured labor;
  
• Prohibit the use of child labor;
  
• Provide safe and healthy working conditions;
  
• Pay wages and benefits in compliance with legal requirements;
  
• Respect the rights of workers to organize, form unions, and collectively bargain.
  

3.2. Environmental Responsibility

Suppliers must:

• Operate in compliance with applicable environmental regulations;
  
• Work to minimize carbon emissions, pollution, and resource waste;
  
• Promote the sustainable use of natural resources;
  
• Avoid the use of hazardous substances wherever possible and ensure proper handling and disposal when necessary.
  

3.3. Business Integrity and Anti-Corruption

We expect all suppliers to conduct business with integrity and in compliance with all anti-corruption and anti-bribery laws. Specifically, suppliers must:

• Prohibit and prevent bribery, kickbacks, embezzlement, and any form of corruption;
  
• Avoid offering gifts, entertainment, or payments that could improperly influence decision-making;
  
• Disclose any actual or potential conflicts of interest with Call Simulator personnel;
  
• Maintain accurate books and records that reflect actual transactions and comply with applicable accounting standards.
  

3.4. Fraud Prevention

Fraud prevention is essential to maintaining the integrity of our supply chain. We require that suppliers:

• Establish and maintain internal controls to detect and prevent fraudulent activities, including false invoicing, misrepresentation of goods or services, and financial misreporting;
  
• Accurately represent their capabilities, qualifications, and certifications;
  
• Do not substitute products, materials, or components without prior written authorization;
  
• Do not conceal subcontracting relationships or reassign contracted work without disclosure and approval;
  
• Cooperate fully with audits and investigations related to suspected fraud or misconduct;
  
• Notify Call Simulator immediately upon discovering any fraudulent or potentially fraudulent activity connected to our relationship.
  

Call Simulator reserves the right to investigate any suspicious activity, terminate contracts for cause, and pursue legal remedies where fraud is discovered.

3.5. Transparency and Accountability

All suppliers are expected to:

• Provide transparency regarding their sourcing practices and supply chains;
  
• Accurately disclose the origin of materials and components;
  
• Participate in compliance reviews, audits, or assessments upon request;
  
• Cascade ethical standards to their own subcontractors and suppliers.
  

4. Implementation and Compliance

4.1. Supplier Due Diligence

Prior to engagement, suppliers may be required to complete a due diligence process, including:

• Self-assessment questionnaires;
  
• Background checks (as legally permissible);
  
• Review of past litigation, regulatory actions, or fraud incidents;
  
• Verification of ethical sourcing certifications or policies.
  

4.2. Contracts and Enforcement

All suppliers must agree to this policy and related compliance terms as part of their contractual obligations. Violations of this policy, including instances of fraud, may result in:

• Termination of the business relationship;
  
• Withholding of payments;
  
• Legal action or referral to law enforcement;
  
• Disqualification from future business with Call Simulator.
  

4.3. Reporting Violations

Suspected violations of this policy, including fraud or unethical behavior, should be reported immediately. Reports may be submitted confidentially and anonymously to: Ethics@CallSimulator.com. 

Call Simulator strictly prohibits retaliation against individuals who report concerns in good faith.

5. Review and Revisions

This policy is reviewed annually and may be revised as laws, risks, or operational needs evolve. Suppliers are responsible for staying up to date with the current version of this policy and ensuring continued compliance.

Updated April 20, 2025