Rubicon Communications expects all employees and suppliers to comply with our Code of Conduct regardless of local business practices or social customs. We take compliance by our employees and suppliers with our Code of Conduct very seriously.


International Corruption Law and EICC

Our employees are required to abide by the U.S. Foreign Corrupt Practices Act (FCPA) guidelines. We expect our suppliers to abide by these same guidelines. Rubicon Communications expects its suppliers to meet the standards of the Electronics Industry Supply Chain Code of Conduct (EICC) and suppliers will be periodically audited with respect to their compliance. Any such persuasive tactics not in compliance with such policies by any supplier with our employees will result in immediate termination of our business relationship.

Supply Chain Security

Rubicon Communications is committed to assessing, managing, and improving its supply chain security. It is Rubicon Communications intent to work with their business partners as a team to improve supply chain security practices. We expect your company will comply with the U.S. Customs “Customs Trade Partnership Against Terrorism” (C-TPAT) minimum security requirements. Further information and updates to these requirements can be found at U.S. Customs C-TPAT Program.

Trade Compliance

It is Rubicon Communications policy to fully comply with all applicable import, export, customs and trade control and regulations, licensing requirements and other relevant U.S. and international laws. Suppliers are required to adhere to all governmental trade compliance import and export regulations involving Rubicon Communications shipments.

Human Rights In Minerals Mining in Central Africa (Conflict Metals)

Human rights violations related to the trade in minerals from the conflict zones in the Democratic Republic of Congo (DRC) and surrounding countries are a focus of Rubicon Communications supply chain and environmental responsibilities. Rubicon Communications asks its suppliers not to source gold, tin, tantalum and tungsten metals from the conflict zones in the Democratic Republic of Congo (DRC) or surrounding countries. We expect suppliers to conduct their worldwide operations in a manner that does not result in labor or human rights violations, including operations that contribute to the direct financing of armed conflict.

Reporting Concerns

To place a report with Rubicon Communications concerning questionable behavior or possible violation of this Code of Conduct or of any applicable U.S. Law, please call us at +1 (512) 646 4100 and ask for the Company Compliance Manager or the Managing Partner.

Revised November 1, 2012