
This Business Partner Code of Conduct (the “Code”) summarizes Paychex Europe’s expectations of its Business Partners with respect to environmental protection, ethical conduct, anti-corruption, the protection of human rights, the integration of diversity and inclusion, the promotion of occupational health and safety the safeguarding of financial integrity, compliance with trade control requirements, and protection against retaliatory measures.
For purposes of this Code, “Business Partners” means all third parties (other than customers) with which Paychex Europe maintains a business relationship, regardless of the form of that relationship. Business Partners include, in particular, joint venture partners, consortium partners, contractors, consulting firms, suppliers, vendors, service providers, commercial agents, other sales intermediaries, distributors, or resellers. The Code is guided by the Universal Declaration of Human Rights and the fundamental principles of the International Labour Organization (ILO). Paychex Europe expects its Business Partners to conduct their business competently and professionally and in accordance with applicable legal requirements, professional standards, and this Code.
In the event of any conflict or inconsistency, the applicable provisions of a contract entered into between a Business Partner and Paychex Europe shall prevail over the provisions of this Code.
Environmental Protection
Paychex Europe seeks to work with Business Partners that operate in an environmentally responsible manner and endeavor to reduce the environmental impact of their products or services. Business Partners are expected to comply with all applicable environmental laws; document and publish safety practices designed to reduce the risk of injury or death and the risk of damage to property or the environment; take precautionary measures to reduce the environmental impact of their business activities; support environmental responsibility; conduct supply chain audits relating to environmental management; and promote the development of sustainable and environmentally friendly technologies.
Ethical Business Practices
Paychex Europe believes that implementing appropriate anti-corruption practices and appropriate practices to ensure the observance of labor rights and human rights is in the best interests of its customers, shareholders, employees, and partners and serves the interests of the community. Out of respect for human rights, Paychex Europe expects its Business Partners to comply with Paychex Europe’s principles on human rights and occupational health and safety; comply with all applicable labor laws, including laws governing wages, working hours, and collective bargaining; prohibit the use of child labor and forced labor; promote freedom of assembly and association; and follow policies that protect against discrimination, violence, abuse, and harassment in the workplace.
To promote anti-corruption efforts and ethical conduct, Paychex Europe’s Business Partners are prohibited from directly or indirectly offering any sum of money, gift, or other benefit of more than nominal value to Paychex Europe or any Paychex Europe employee in order to influence Paychex Europe’s business decisions. Business Partners must not make any payment or donation to a political campaign either on behalf of Paychex Europe or for the purpose of influencing Paychex Europe’s business decisions, conferring an advantage on Paychex Europe, or increasing the likelihood of doing business with Paychex Europe.
Diversity and Inclusion
Paychex Europe believes that a diverse mix of people and ideas fosters creativity and makes Paychex Europe a stronger company. Paychex Europe is committed to providing an inclusive work environment in which all aspects of diversity are recognized, respected, and promoted. Paychex Europe expects its Business Partners to implement measures and practices that promote diversity and inclusion in their own operations and supply chains.
Supply Chain Audits
Where necessary, Paychex Europe may require its Business Partners to provide information, as mutually agreed by the parties, concerning supply chain audits relating to product safety.
Occupational Health and Safety
Paychex Europe places great importance on occupational health and safety and expects its Business Partners to establish safety and health management practices throughout all areas of their business activities.
Paychex Europe expects its Business Partners to comply with all applicable occupational health and safety laws, including those relating to occupational safety, emergency preparedness, occupational injuries and illnesses, industrial hygiene, physical strain, machine safety, sanitary facilities, food safety, and business premises. Paychex Europe further expects its Business Partners to minimize potential safety risks to which employees and visitors are exposed by appropriately identifying and assessing such risks and reducing them accordingly.
Financial Integrity
Business Partners are expected to ensure that all business activities, corporate structures, assets and liabilities, and performance are transparently and accurately reflected in their books and business records in accordance with applicable laws, regulations, and customary business practices. Paychex Europe expects its Business Partners to maintain a zero-tolerance policy against corruption, misrepresentation, extortion, embezzlement, bribery, kickbacks, and any other corrupt act intended to obtain or retain business or secure an unfair or improper advantage.
Conflict Minerals
Business Partners are expected to ensure that products and goods they supply to Paychex Europe do not contain metals or substances derived from minerals originating in conflict-affected areas or conflict regions (“Conflict Minerals”). Conflict Minerals are minerals and their derivatives that directly or indirectly finance or otherwise support armed groups.
Trade Controls
International trade control laws and regulations, as well as country-specific trade sanctions, apply to international transactions involving goods, services, or technology and to international financial transactions. All Business Partners are expected to comply fully with applicable international trade control requirements.
Protection Against Retaliatory Measures
Paychex Europe is committed to creating a work environment that fosters continuous and open discussion of ethical issues, compliance, and related matters and that encourages employees to report violations or potential violations of Paychex Europe’s principles, professional standards, or applicable laws and regulations without fear of retaliation. Business Partners are expected to ensure that their employees are not subjected to harassment, intimidation, threats, coercion, discrimination, or other retaliatory acts because they have, in good faith, raised concerns relating to ethical issues or compliance matters or participated in related investigations.


