GPM Global · Policy Document · Updated April 15, 2026

GPM® Supplier and Partner Code of Conduct

GPM suppliers and partners are required to take reasonable steps to ensure that this Code of Conduct is communicated, understood, and followed throughout their organizations. It must be made available to their employees and applied throughout their own supply chains. This Code applies to all organizations that supply goods or services to GPM, participate in GPM’s partner programs, or engage with GPM or the PMI-GPM Joint Venture on behalf of clients.

1. Antitrust and Competition Laws

All suppliers and partners must comply fully with competition laws applicable to them, including antitrust laws in the United States and equivalent laws in all jurisdictions where they operate. GPM requires that all suppliers and partners conduct their business in full compliance with laws intended to promote free and fair competition. This includes refraining from price-fixing, market allocation, bid-rigging, and any other arrangements that interfere with market forces.

2. Confidential and Proprietary Information

Suppliers and partners must respect GPM’s intellectual property, trade secrets, and other confidential, proprietary, or sensitive information, and may not use or disclose any such information except in accordance with their agreement with GPM. This obligation extends to assets of the PMI-GPM Joint Venture where applicable.

Information regarding GPM’s operations must be treated as confidential unless it enters the public domain through no fault of the supplier or partner. Obligations include:

Not disclosing GPM confidential information to individuals within the supplier’s or partner’s organization except on a strict need-to-know basis.
Not disclosing GPM confidential information to organizations or individuals outside of the supplier’s or partner’s organization.
Not using GPM content — including standards, guides, course materials, templates, or website content — to train, fine-tune, or otherwise develop any artificial intelligence or machine learning system, without prior written permission from GPM.
Not using AI tools to reproduce, generate, or imitate the GPM logo, GPM trademarks, or PMI-GPM Joint Venture marks in any form.

3. Ethical Dealings

Honesty and integrity are conditions of doing business with GPM. Procurement decisions are based on objective criteria including price, quality, service capability, and demonstrated ethical conduct. GPM requires all partners and suppliers to adhere to the UN Global Compact’s Ten Principles and to conduct all business transactions with integrity.

GPM has zero tolerance for bribery and kickbacks in any form. Suppliers and partners are required to enforce the same standards within their own organizations and supply chains.

4. Anti-Bribery and Anti-Corruption

GPM is signatory #107 to the UN Global Compact Anti-Corruption Call to Action and is committed to working against corruption in all its forms, including bribery and extortion. This commitment applies in every country where GPM and its suppliers and partners operate.

GPM’s policy, the US Foreign Corrupt Practices Act (FCPA), the UN Convention Against Corruption, the UK Bribery Act, Canada’s Corruption of Foreign Public Officials Act (COFPA), and equivalent laws worldwide prohibit giving, offering, or promising money or anything of value — directly or indirectly — to any government official to influence any governmental act or decision, or to assist in obtaining or retaining business.

GPM suppliers and partners must:

Not act in any way that violates the FCPA or any other anti-bribery or anti-corruption law in any jurisdiction.
Use only sub-suppliers that do not engage in bribes, kickbacks, or other unlawful payments.
Maintain internal controls adequate to detect and prevent corrupt conduct within their own organizations.

Compliance with anti-corruption laws is a legal obligation. Non-compliance exposes GPM to reputational, administrative, civil, and criminal consequences, including investigations, fines, loss of contracts, and blacklisting. Supplier or partner non-compliance will be treated as grounds for contract termination.

5. Health and Safety

Suppliers and partners must provide a safe and healthy work environment for all employees at their sites. This includes complying with all applicable occupational health and safety laws, identifying and mitigating workplace hazards, and maintaining processes for employees to report safety concerns without fear of retaliation.

6. International Trade Regulations

GPM suppliers and partners must adhere to all applicable trade, export, and import regulations covering their activities, including those issued by the US government and by the governments of all countries into which they import goods or materials. Where trade compliance questions arise in connection with a GPM engagement, contact This email address is being protected from spambots. You need JavaScript enabled to view it..

7. Labor Practices and Decent Work

GPM does not do business with any supplier or partner known to use forced labor, child labor, involuntary servitude, or any form of exploitative or abusive labor practice. GPM’s Human Rights and Anti-Trafficking Policy applies to all suppliers and partners as a condition of engagement.

Suppliers and partners must:

Ensure their own operations are free from forced labor, child labor, discrimination, and physical punishment or abuse.
Uphold freedom of association and the right to collective bargaining for all workers.
Take appropriate steps to ensure their own sub-suppliers do not engage in any of these practices.
Complete and return GPM’s annual Human Rights and Anti-Trafficking Policy affirmation as a condition of continued engagement.

8. Environmental Protection and Climate

GPM suppliers and partners must comply with all applicable environmental laws and regulations in the jurisdictions where they operate. This includes requirements related to emissions, waste management, water use, and hazardous materials.

GPM’s Environmental Regeneration Policy establishes commitments to net positive carbon impact, water stewardship, biodiversity protection, and circular economy practice. Suppliers and partners are expected to align with these commitments to the extent applicable to their operations:

Maintain a zero-deforestation procurement policy across their own supply chains where applicable.
Disclose material environmental risks and incidents that may affect GPM or joint project engagements.
Engage with GPM’s P5 Standard-based environmental assessment process for major project engagements where GPM is acting as a consulting or delivery partner.
Comply with circular economy standards as a condition of supplier engagement, including responsible procurement and material recovery practices.

9. Data Privacy

Suppliers and partners who process personal data on behalf of GPM, or who have access to GPM systems or customer data, must do so in accordance with GPM’s instructions and in compliance with applicable data protection laws, including the EU GDPR, UK GDPR, PIPEDA, and the CCPA/CPRA.

Suppliers and partners processing personal data on GPM’s behalf must:

Enter into a data processing agreement with GPM before any personal data processing begins.
Implement appropriate technical and organizational measures to protect personal data against unauthorized access, disclosure, or loss.
Not use GPM personal data to train, develop, or improve any artificial intelligence or machine learning system.
Notify GPM at This email address is being protected from spambots. You need JavaScript enabled to view it. immediately upon becoming aware of any personal data incident or breach involving GPM data.

10. Management Systems and Incident Reporting

GPM expects its suppliers and partners to have in place reasonable and appropriate systems through which allegations of wrongdoing may be investigated and remediated. Suppliers and partners must fully investigate allegations of wrongdoing with respect to this Code within their own organizations.

A supplier or partner must notify GPM in writing immediately upon becoming aware of any adverse event, investigation, or publicity concerning the supplier or partner, any product being supplied to GPM, or any circumstance that could reasonably be expected to cause negative publicity or reputational harm to GPM. Notification should be sent to This email address is being protected from spambots. You need JavaScript enabled to view it..

11. Compliance and Enforcement

It is the responsibility of each supplier and partner to ensure that its employees and representatives understand and comply with this Code of Conduct. Compliance is a condition of the supplier or partner relationship with GPM.

Failure to adhere to this Code may be grounds for terminating the supplier or partner relationship, depending on the seriousness of the violation and the particular circumstances. GPM reserves the right to audit supplier and partner compliance with this Code as a condition of continued engagement.

For questions about this Code of Conduct or to report a concern:

General This email address is being protected from spambots. You need JavaScript enabled to view it.
Data privacy This email address is being protected from spambots. You need JavaScript enabled to view it.
Ethics concerns This email address is being protected from spambots. You need JavaScript enabled to view it.

GPM Global · Supplier and Partner Code of Conduct · Updated March 12, 2025