Supply Chain Member Code of Conduct


The CBO Code of Conduct is one of the ways we put values into practice. It's built around the recognition that everything we do in connection with our work will be, and should be, measured against the highest possible standards of ethical business conduct. Our commitment to the highest standards helps us hire great people, build great products, and attract loyal users. Respect for our users, for the opportunity, and for each other are foundational to our success, and are something we need to support every day.  Our users value CBO not only because we deliver great products and services, but because we hold ourselves to a higher standard in how we operate and treat users.

Who Must Follow Our Code?

We expect all employees and Board members to know and follow the Code.  Failure to do so can result in disciplinary action, including termination of employment.  Moreover, while the Code is specifically written for CBO employees and Board members, we expect CBO vendors, contractors, consultants, and others who may be temporarily assigned to perform work or services for CBO to follow the Code in connection with their work for us.  Failure of a CBO vendor, contractor, consultant, or other covered service provider to follow the Code can result in termination of their relationship with CBO.

As a member of The Cannabis Business Opportunities’ supply chain network, I will:

I. Enhance and protect the standing of the recreational,medicinal and agricultural Cannabis Sativa L. programs, by:

  • never engaging in conduct, either professional or personal, which would bring the transaction, Cannabis Business Opportunities or my employer  into disrepute

  • not accepting inducements or gifts (other than any declared gifts of nominal value which have been sanctioned by my employer)

  • not allowing offers of hospitality or those with vested interests to influence, or be perceived to influence, my business decisions

  • being aware that my behaviour outside my professional life may have an effect on how I am perceived as a professional

II. Maintain the highest standard of integrity in all business relationships, by:

  • rejecting any business practice which might reasonably be deemed improper.

never using my authority or position for my own financial gain.

  • declaring any personal interest that might affect, or be seen by others to affect, my impartiality in decision making.

  • ensuring that the information I give in the course of my work is accurate and not misleading.

  • never breaching the confidentiality of information I receive in a professional capacity.

  • striving for genuine, fair and transparent competition.

  • being truthful about my skills, experience and qualifications.

III. Promote the eradication of unethical business practices, by:

  • fostering awareness of human rights, fraud and corruption issues in all of [my] business relationships.

  • responsibly managing any business relationships where unethical practices may come to light, and taking appropriate action to report and remedy them.

  • undertaking due diligence on appropriate supplier relationships in relation to forced labour (modern slavery) and other human rights abuses, fraud and corruption.

  • continually developing my knowledge of forced labour (modern slavery), human rights, fraud and corruption issues, and applying this in my professional life.

IV. Enhance the proficiency and stature of the profession, by:

  • continually developing and applying knowledge to increase my personal skills and those of the organi[z]ation I work for.

  • fostering the highest standards of professional competence amongst those for whom I am responsible.

  • optimising the responsible use of resources which I have influence over for the benefit of my organi[z]ation.

V. Ensure full compliance with laws and regulations, by:

  • adhering to the laws of the countries in which I practise, and in countries where there is no relevant law in place I will apply the standards inherent in this Code

  • fulfilling agreed contractual obligations

  • following Cannabis Business Opportunities guidance on professional procurement and contract management practice

Membership Policy.

(a) CBO vendors and contractors must conduct themselves with the highest degree of integrity and honesty.

(b) Vendors and Contractors should have a written code of business ethics and conduct. To promote compliance with such code of business ethics and conduct, contractors should have an employee business ethics and compliance training program and an internal control system that—

(1) Are suitable to the size of the company and extent of its involvement in doing business with Cannabis Business Opportunities procurement and contracting;

(2) Facilitate timely discovery and disclosure of improper conduct in connection with CBO contracts; and

(3) Ensure corrective measures are promptly instituted and carried out.

Vendor and Contractor Requirements.

(1) A contractor may be suspended and/or debarred for knowing failure by a principal to timely disclose to Cannabis Business Opportunities, in connection with the award, performance, or closeout of a CBO contract performed by the contractor or a subcontract awarded thereunder, credible evidence of a violation of Federal criminal law involving fraud, conflict of interest, bribery, or gratuity violations found in Title 18 of the United States Code or a violation of the civil False Claims Act.

(2) If the contractor becomes aware that CBO or its client has overpaid on a contract financing or invoice payment, the contractor shall remit the overpayment amount to the Cannabis Business Opportunities. A contractor may be suspended and/or debarred for knowing failure by a principal to timely disclose credible evidence of a significant overpayment, other than overpayments resulting from contract financing payments.

(a) Notification of possible contractor violation. If Cannabis Business Opportunities, specifically the contracting officer is notified of possible contractor violation of Federal criminal law involving fraud, conflict of interest, bribery, or gratuity violations found in Title 18 U.S.C.; or a violation of the civil False Claims Act, the procurement specialist shall—

(1) Coordinate the matter with legal counsel; or

(2) Take action in accordance with buyers procedures.

Contract Clause.

(a) The following will shall be automatically added to all requests: Contractor Code of Business Ethics and Conduct, in solicitations and contracts if the value of the contract is expected to exceed $5,000  and the performance period is 14 days or more.

Contractor Code of Business Ethics and Conduct

(a) Definitions. As used in this clause

“Agent” means any individual, including a director, an officer, an employee, or an independent Contractor, authorized to act on behalf of the organization.

“Full cooperation”—

(1) Means disclosure to Cannabis Business Opportunities of the information sufficient for law enforcement to identify the nature and extent of the offense and the individuals responsible for the conduct. It includes providing timely and complete response to CBO auditors’ and investigators' request for documents and access to employees with information;

(2) Does not foreclose any Contractor rights arising in law, the FAR, or the terms of the contract. It does not require—

(i) A Contractor to waive its attorney-client privilege or the protections afforded by the attorney work product doctrine; or

(ii) Any officer, director, owner, or employee of the Contractor, including a sole proprietor, to waive his or her attorney client privilege or Fifth Amendment rights; and

(3) Does not restrict a Contractor from—

(i) Conducting an internal investigation; or

(ii) Defending a proceeding or dispute arising under the contract or related to a potential or disclosed violation.

“Principal” means an officer, director, owner, partner, or a person having primary management or supervisory responsibilities within a business entity (e.g., general manager; plant manager; head of a division or business segment; and similar positions).

“Subcontract” means any contract entered into by a subcontractor to furnish supplies or services for performance of a prime contract or a subcontract.

“Subcontractor” means any supplier, distributor, vendor, or firm that furnished supplies or services to or for a prime contractor or another subcontractor.

“United States,” means the 50 States, the District of Columbia, and outlying areas.

(b) Code of business ethics and conduct.

(1) Within 30 days after contract award, unless the CBO Head of Procurement establishes a longer time period, the Vendor and/or Contractor shall—

(i) Have a written code of business ethics and conduct;

(ii) Make a copy of the code available to each employee engaged in performance of the contract.

(2) The Contractor shall

(i) Exercise due diligence to prevent and detect criminal conduct; and

(ii) Otherwise promote an organizational culture that encourages ethical conduct and a commitment to compliance with the law.

(c) Business ethics awareness and compliance program and internal control system. This paragraph (c) does not apply if the Contractor has represented itself as a small business concern. The Contractor shall establish the following within 90 days after contract award, unless the Contracting Officer establishes a longer time period:

(1) An ongoing business ethics awareness and compliance program.

(i) This program shall include reasonable steps to communicate periodically and in a practical manner the Contractor’s standards and procedures and other aspects of the Contractor’s business ethics awareness and compliance program and internal control system, by conducting effective training programs and otherwise disseminating information appropriate to an individual’s respective roles and responsibilities.

(ii) The training conducted under this program shall be provided to the Contractor’s principals and employees, and as appropriate, the Contractor’s agents and subcontractors.

(2) An internal control system.

(i) The Contractor’s internal control system shall—

(A) Establish standards and procedures to facilitate timely discovery of improper conduct in connection with CBO contracts; and

(B) Ensure corrective measures are promptly instituted and carried out.

(ii) At a minimum, the Contractor’s internal control system shall provide for the following:

(A) Assignment of responsibility at a sufficiently high level and adequate resources to ensure effectiveness of the business ethics awareness and compliance program and internal control system.

(B) Reasonable efforts not to include an individual as a principal, whom due diligence would have exposed as having engaged in conduct that is in conflict with the Contractor’s code of business ethics and conduct.

(C) Periodic reviews of company business practices, procedures, policies, and internal controls for compliance with the Contractor’s code of business ethics and conduct and the special requirements of CBO contracting, including—

(1) Monitoring and auditing to detect criminal conduct;

(2) Periodic evaluation of the effectiveness of the business ethics awareness and compliance program and internal control system, especially if criminal conduct has been detected; and

(3) Periodic assessment of the risk of criminal conduct, with appropriate steps to design, implement, or modify the business ethics awareness and compliance program and the internal control system as necessary to reduce the risk of criminal conduct identified through this process.

(D) An internal reporting mechanism, such as a hotline, which allows for anonymity or confidentiality, by which employees may report suspected instances of improper conduct, and instructions that encourage employees to make such reports.

(E) Disciplinary action for improper conduct or for failing to take reasonable steps to prevent or detect improper conduct.

(d) Subcontracts.

(1) The Contractor shall include the substance of this clause, including this paragraph (d), in subcontracts that have a value in excess of $500,000 and a performance period of more than 60 days.                                                       

(End of clause)

Last Updated 12/1/18