Supplier and Subcontractor Code of Conduct

Iskhak LLC d/b/a SalemWise Solutions

Version 1.1, adopted September 29, 2026, updated October 7, 2026. Owner: Founder and CEO. Reviewed at least once a year, and whenever a prime contract adds new flowdown requirements.

1. Purpose and scope

SalemWise is a small software and AI firm based in New Jersey. We buy cloud services, SaaS tools, computer hardware (such as GPUs and servers) and, from time to time, freelance or subcontract development work. We call the businesses and people who supply goods or services to us, and their own subcontractors, "Suppliers". This Code applies in full to subcontractors and freelancers who perform work for us or handle our or our customers' data. For cloud and software providers that serve us on their standard terms, we choose providers whose published terms and security practices are consistent with this Code. Where we work under a federal prime contract, the prime's flowdown clauses also apply and take precedence where they are stricter.

Suppliers must obey all laws that apply to them, including labor, employment, anti-corruption, export control, sanctions, privacy, environmental and tax law. Suppliers must not be excluded from federal contracting (SAM.gov) or listed on U.S. sanctions lists (OFAC), and must tell us promptly if that changes.

3. Anti-bribery and fair business

  1. No bribes, kickbacks or improper payments, directly or through others, to anyone, including government officials and prime contractor staff (U.S. FCPA, Anti-Kickback Act, and local law).
  2. No gifts, meals or hospitality meant to influence a decision. Modest, occasional courtesies are fine if they would not embarrass either party if made public.
  3. Disclose any conflict of interest with SalemWise, its customers or a prime contractor.
  4. Compete fairly: no price fixing, bid rigging or misuse of another party's confidential or source selection information.
  5. Keep accurate books, time records and invoices.

4. Human rights and labor

  1. No forced labor, child labor or human trafficking. Suppliers must comply with FAR 52.222-50 (Combating Trafficking in Persons) when it applies, including no recruitment fees charged to workers, no destroying or withholding identity documents, and no misleading recruitment.
  2. Workers are of legal working age and are legally authorized to work.
  3. Pay at least the legal minimum wage and any required overtime; follow legal limits on working hours; give workers written terms of work in a language they understand.
  4. No discrimination or harassment based on race, color, religion, sex, sexual orientation, gender identity, national origin, age, disability, veteran status or any other protected characteristic.
  5. No harsh or inhumane treatment, intimidation or coercion.
  6. Respect workers' right to freely associate, to join or not join a union, and to bargain collectively as allowed by law.

5. Health and safety

Provide a safe and healthy workplace, follow applicable occupational safety law, and handle hardware (heavy servers, electrical equipment, batteries) safely during delivery, installation and disposal. Anyone working on our premises or equipment, or at a customer location, follows the applicable safety instructions.

6. Environment

  1. Comply with environmental laws and permits.
  2. Prefer energy-efficient products and services. Hardware and cloud suppliers should be able to share basic energy efficiency or renewable energy information on request.
  3. Dispose of electronic waste only through certified e-waste recyclers (R2 or e-Stewards, or equivalent) and wipe or destroy storage media before disposal.
  4. Hardware suppliers should understand the origin of tin, tantalum, tungsten and gold in their products, have a responsible minerals sourcing policy and, on request, share a completed RMI Conflict Minerals Reporting Template (CMRT).
  5. Reduce packaging where practical.

Our own commitments are in our Environmental and Sustainability Policy.

7. Data security and confidentiality

  1. Protect SalemWise, customer and prime contractor information. Use it only for the work we contracted for, and return or delete it when the work ends, unless law or a contract requires it to be kept.
  2. When the work involves Federal Contract Information (FCI), apply the 15 basic safeguarding requirements of FAR 52.204-21 and flow them down to your own subcontractors.
  3. No customer or SalemWise confidential data may be entered into a third-party AI service (public chatbots, AI coding assistants with cloud processing, or similar) without our prior written consent. Approved tools and settings are agreed in writing.
  4. Use unique accounts and multi-factor authentication for any SalemWise system; never share credentials.
  5. Report any actual or suspected security incident involving our data to us within 24 hours of discovery.
  6. Hardware and software must not include covered telecommunications equipment or banned products (FAR 52.204-25, 52.204-23 and 52.204-27) when those clauses apply.

8. Reporting concerns and non-retaliation

Anyone (Supplier staff, their workers, or the public) can report a suspected breach of this Code to [email protected]. Anonymous reports are accepted. We use a report only to investigate it, share it only with those who need to know, and never add anyone who reports to a marketing list. If the concern involves our leadership, or you prefer an independent route, you can contact the relevant agency Inspector General or another appropriate authority. We will not retaliate, and we expect Suppliers not to retaliate, against anyone who reports in good faith. The whistleblower protections of 41 U.S.C. 4712 and, for Defense, NASA and Coast Guard work, 10 U.S.C. 4701, apply to employees of contractors and subcontractors where relevant.

9. Our right to request information and assess

We may ask Suppliers to complete a questionnaire, provide policies, certificates or evidence, or join a short review call. For higher-risk Suppliers, and where a prime contract requires it, we may ask to visit the Supplier's site or request a third-party assessment on reasonable notice. Suppliers must keep records needed to show compliance for at least three years, or longer if a contract requires it.

10. Consequences

If a Supplier falls short, we will normally agree a corrective action plan with a deadline. Serious breaches (for example, forced labor, bribery, sanctions violations, or misuse of customer data) or failure to correct issues may lead to suspension of orders, termination of the contract and, where the law or a prime contract requires, reporting to the prime or to authorities.

11. Supplier acknowledgment

Suppliers who sign our acknowledgment form confirm that they have read and understood this Code, that they will comply with it, that they will flow down its relevant parts to their own subcontractors on SalemWise work, and that they will tell SalemWise promptly of any breach. We ask each Supplier to sign the form when an engagement starts. To request it, email [email protected].

12. About this Code

This Code states what we expect of our Suppliers. It is not itself a contract, creates no rights for third parties and does not change any agreement. If it conflicts with a signed agreement or with a prime contract's flowdown clauses, that agreement or clause governs. A Supplier is bound by this Code only once it signs our acknowledgment form or the Code is incorporated into its contract. We may update this Code at any time, and the version on this page is the current one.