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Code of Conduct

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SunTrust Vendor Code of Conduct and Ethics

SunTrust is committed to Lighting the Way to Financial Well-Being for our teammates, clients, and shareholders. The SunTrust Vendor Code of Conduct and Ethics (“Code”) lays out SunTrust's expectations for environmental, human rights, anti-corruption, and diversity and inclusion policies and practices for vendors with whom SunTrust engages.

The Code is representative of the SunTrust Code of Business Conduct and Ethics governing all SunTrust teammates, and is guided by the Universal Declaration of Human Rights and the International Labour Organization's Fundamental Conventions. SunTrust expects its vendors to conduct their operations in accordance with any applicable professional standards, laws and regulations, as well as this Code and to enact and enforce policies in support of these values.

While the Code provides general guidance about the standards of integrity and business conduct, no code can address every situation. As a result, this Code is not a substitute for individual responsibility and accountability to exercise good judgment and obtain guidance on proper business conduct.

Applicable laws, legal requirements and contractual agreements with vendors inform the specific applications of this Code, and the specific terms of a vendor's contract with SunTrust will override any conflicting provisions of this Code.

Respect the Environment

SunTrust seeks to engage suppliers and service providers who are environmentally conscious and demonstrate a holistic sustainability perspective to better serve clients and communities. To that end, vendors should comply with all applicable environmental laws. Vendors should document and post safety practices to reduce the risk of injury or death; take proactive measures to mitigate any environmental impacts; promote environmental responsibility in the course of business and through the production of goods or services provided to SunTrust; and encourage the development and diffusion of environmentally friendly technologies.

Ethical Business Practices

Ethical business practices are at the forefront of the internal SunTrust Code of Business Conduct and Ethics that SunTrust teammates follow. SunTrust believes that anti-corruption practices, labor and human rights are essential to Lighting the Way to Financial Well-being for clients and communities. In respect of human rights, vendors should comply with all applicable employment laws; ensure against the use of child or forced labor in any operations or facilities; and maintain policies and protections against workplace discrimination, violence, abuse and harassment.

To support anti-corruption regulations and ethics, vendors should not directly or indirectly provide or give money, gifts (valued over $100), or other compensation benefiting SunTrust or SunTrust teammates in efforts to influence business decisions. Vendors should not make payments or donations to political campaigns to gain favor or to influence SunTrust business decisions, to benefit SunTrust, or to increase the likelihood of working with SunTrust.

Value Inclusion and Diversity

SunTrust believes it takes a well-rounded combination of people and ideas to foster creativity and a more competitive company. SunTrust is committed to fostering an inclusive environment where we acknowledge, respect and employ all dimensions of diversity and where all teammates have the opportunity to maximize their contributions to clients and communities. SunTrust also believes institutions achieve optimal performance by establishing diversity in business practices --including developing relationships with high-quality diverse suppliers.

Vendors are expected to value and incorporate diversity and inclusion policies and practices in operations and their supply chain.

Vendor Name

Effective Date

Authorized Signature

Title

Compliance Acknowledgement

Enter text✕

What the Code of Conduct Is and Why It Matters

A Code of Conduct is a formal, written policy that defines acceptable behavior, ethical standards, and compliance obligations for employees, contractors, and representatives. It explains responsibilities, conflict-of-interest rules, reporting channels for suspected violations, and disciplinary steps. Organizations use it to set consistent expectations, support regulatory compliance, and document training and acknowledgments that demonstrate due diligence in governance and risk management.

Purpose and Main Advantages of a Clear Code of Conduct

A well-drafted Code of Conduct reduces legal and reputational risk, supports regulatory compliance, and provides a consistent framework for decision-making across the organization. It clarifies reporting procedures and helps document employee acknowledgment for audits or investigations.

Purpose and Main Advantages of a Clear Code of Conduct

Who Typically Adopts and Signs a Code of Conduct

Document distribution and signature responsibilities typically rest with HR, legal, or compliance teams depending on organizational structure.

  • Employees at all levels — required for onboarding and annual reaffirmation.
  • Contractors and vendors — signed when access to systems or facilities is granted.
  • Board members and executives — to document governance and fiduciary expectations.

Core Elements Every Professional Code of Conduct Should Include

A practical Code of Conduct is concise, role-specific where needed, and includes clear reporting and investigation procedures alongside obligations related to confidentiality, conflicts of interest, and regulatory compliance.

Scope

Defines who the policy covers, which entities and job roles are included, and whether contractors and agents must comply.

Standards

Lists expected behaviors such as honesty, nondiscrimination, anti-harassment rules, conflicts-of-interest guidance, and use-of-assets limits.

Reporting

Describes reporting channels, anonymous hotlines, escalation paths, and protections against retaliation for good-faith reports.

Compliance

Notes applicable laws and regulations (for example, HIPAA or FERPA for healthcare/education) and responsibilities for regulatory reporting.

Enforcement

Explains investigation steps, corrective actions, disciplinary measures, and appeal rights to ensure fair treatment.

Acknowledgment

Includes a signed acknowledgement section capturing signer identity, date, and any required attestations or training completion.

Step-by-Step: Issuing and Collecting Acknowledgments

Follow a simple workflow to publish the Code of Conduct and collect acknowledgments efficiently while preserving an audit trail.

  • 01
    Prepare Document: Finalize content and version number before distribution.
  • 02
    Assign Roles: Identify required signers and approvers in the workflow.
  • 03
    Send for Signature: Distribute electronically with required fields and authentication.
  • 04
    Record and Store: Capture audit trail and save signed records to secure storage.

Typical Online Workflow Settings for a Code of Conduct

Configure your digital workflow to require identity verification, capture signatures, and notify compliance teams automatically.

Template Lock the final version to prevent edits after publishing.
Signer Roles Define employee, manager, and compliance approver roles for routed signing.
Authentication Use email access plus optional SMS code or SSO for stronger identity assurance.
Conditional Fields Display role-specific attestations only when relevant to the signer.
Notifications Send reminders at preset intervals until acknowledgment is completed.

Where to Send and How Signatures Are Collected

Decide delivery channels and acceptable authentication methods based on the policy sensitivity and regulatory needs.

  • Email Link: Send a secure signing link to the recipient's work email address.
  • SSO Integration: Allow signers to authenticate via corporate single sign-on when available.
  • In-Person Kiosk: Use kiosk mode for facility-based signings or onboarding stations.
  • Guest Signing: Permit external contractors to sign via verified email or SMS code.

Digital Signature and Submission Considerations

Ensure the solution supports retention, role-based access controls, and any industry-specific security addenda such as a HIPAA BAA where necessary.

  • Authentication: Email, SMS code, or SSO options.
  • Audit Trail: Timestamps, IP, and action history.
  • Export Formats: PDF and PDF/A for archival.

Typical Timelines and Deadlines to Manage

Set clear deadlines for acknowledgment, remediation, and periodic review to maintain compliance and records integrity.

New Hire Acknowledgment:

Complete within 30 days of hire date.

Annual Re-Certification:

Require signed reaffirmation every 12 months.

Policy Update Notice:

Provide employees a minimum 30-day notice before effective date.

Investigation Timeline:

Complete internal investigations within 90 days where practical.

Record Availability:

Make signed records available for audits on request.

Common Mistakes to Avoid When Preparing a Code of Conduct

  • Using vague language that leaves responsibilities undefined and invites inconsistent interpretation.
  • Failing to configure role-specific fields, causing irrelevant sections to appear to some signers.
  • Not capturing a complete audit trail or signer authentication, complicating enforcement.
  • Distributing a draft version instead of the final, approved policy, creating version-control issues.

Principal Risks and Consequences of an Incomplete or Incorrect Code

Regulatory Fines: Civil penalties or agency enforcement.
Contract Loss: Breach of contractual compliance terms.
Reputational Harm: Public disclosure of misconduct.
Employment Claims: Increased litigation risk from unclear policies.
Operational Disruption: Confusion over reporting and responsibilities.
Data Exposure: Improper handling of confidential information.

Security and Compliance Items to Include with the Code

Encryption: TLS 1.2/1.3 in transit; AES-256 at rest.
Audit Trail: Capture timestamps, IP, and event history.
Access Control: Role-based permissions and SSO support.
Certifications: SOC 2 Type II and ISO 27001 controls.
HIPAA Options: BAA available when required.
Retention: Support export to PDF/A for archiving.

Comparing eSignature Pricing and Basic Capabilities

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Starting Price $8/user/mo $15/user/mo $14/user/mo $19/user/mo $15/user/mo
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Bulk Send Yes Yes Yes Yes No
Audit Trail Yes Yes Yes Yes Yes
HIPAA Compliant Yes Yes Yes No No
Envelope Cap No envelope cap 100 envelopes/user/year limit Varies by plan Varies by plan Varies by plan

Frequently Asked Questions About Using and Signing a Code of Conduct

Answers address common technical, legal, and process questions encountered when preparing, distributing, and signing a Code of Conduct.


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