Supplier Code of Conduct

Introduction
Sourceability has a strong commitment to ethics and integrity, and all employees are expected to perform their jobs honestly, diligently and responsibly. Observing the laws in every country where we do business is the fundamental principle of Sourceability.

This Sourceability Supplier Code of Conduct (“Supplier Code”) establishes the standards for conducting business with Sourceability. We expect our Suppliers to share in our culture, values and business practices, and expect our Suppliers to act in a manner consistent with our Supplier Code.

In this Supplier Code, “Supplier” means any individual, company, or other entity that provides, or seeks to provide, goods or services to Sourceability.

Sourceability also expects our Suppliers to ensure that their suppliers follow and comply with this Supplier Code, and fully understand the content and obligations set forth. The Supplier must offer assistance and training when required to fulfill the set of obligations.

Legal Compliance 
Compliance with applicable law goes without saying at Sourceability. As a global company, Sourceability has to respect diverse social, policy and legal conditions in all its business processes, market activities and relations with Suppliers and third parties. Accordingly, Sourceability adheres to the fundamental principle that it must consistently conduct all its business, whether domestically or abroad, in the parent company or in a subsidiary, in line with the statutory regulations, standards, industry standards and its own internal provisions. We expect our Suppliers as well as their suppliers to similarly align and promote such practices to its supply chain.

Human rights 
It is important for Sourceability that all people related to our business are treated with respect and dignity. We expect our suppliers to respect human rights. 

Discrimination 
In Sourceability, we welcome diversity and value individual differences. Discrimination of any form is not tolerated, which includes discrimination based on sex, race, colour of skin, religion and beliefs, political opinion, sexual orientation, age, handicap or national, social and/or ethnic origin. Likewise, we expect our Suppliers and suppliers to treat employees fairly without discrimination. 

Employees must have equal opportunities and treatment in employment and when hiring new employees. 

Forced labor and human trafficking 
Sourceability will not conduct business with suppliers that are associated with any form of bonded labor, forced labor, labor with a fear of punishment or any form of human trafficking. Employees must work at their own will and employees should be free to leave and change their employment when they wish.

Prohibition of Child Labor
Supplier shall not employ workers who are under the age of 15 or the minimum age requirement stipulated in local labor laws and regulations or under the age for completing compulsory education, whichever is lower. Workers under the age of 18 (Young Workers) shall not perform work that is likely to jeopardize their health or safety, including night shifts and overtime. Supplier shall ensure proper management of student workers through proper maintenance of student records, rigorous due diligence of educational partners, and protection of students’ rights in accordance with applicable law and regulations. Supplier shall provide appropriate support and training to all student workers. In the absence of local law, the wage rate for student workers, interns and apprentices shall be at least the same wage rate as other entry-level workers performing equal or similar tasks.

Anti-Harassment
We expect our suppliers to ensure that their employees are afforded an employment environment that is free from physical, psychological, and verbal harassment, or other abusive conduct.

Employees
At Sourceability, our employees form the basis of our success. We are committed to provide a motivating and inspiring work environment for our employees. Likewise, we expect our suppliers to focus on employee well-being and provide a safe work environment with proper terms of employment. 

Working conditions 
Employees must be treated within the applicable national or local laws as well as industry practice and collective bargaining agreements regarding employment.

Working conditions, hours, rest periods, leave and wages should be in accordance with local regulations and industry practice, and should be at a level that enables a decent living standard according to local conditions. 

Wages may not be withheld as a disciplinary sanction.

Health and safety 
Suppliers must provide a healthy and safe working environment for all employees. We expect suppliers to: 

Follow all applicable local laws and regulations to prevent accidents and injury to health. 

Continuously improve working conditions and reduce workplace related risks and hazards by e.g. having a health and safety management system in place, ensuring management responsibilities, providing necessary safety training and equipment to employees, setting targets and conducting training. 

Environment, Social & Governance 
In Sourceability, it is important for us that we conduct business in a sustainable way with care for the environment. We are aware that acting responsibly goes beyond our own activities, and we therefore expect our suppliers to carry out operations with care for the environment and to strive to minimize adverse impacts on the environment, such as disproportionately large amounts of CO2 emissions and waste. 

Suppliers must comply with local environmental regulation and maintain the necessary registrations, permits and licenses. 

We expect suppliers to handle air emissions and appropriately handle waste, attempt to minimize waste and to reuse and recycle resources and materials. 

Suppliers must monitor and continuously strive to improve environmental performance, e.g. by having an environmental management system in place. 

Anti-corruption and business ethics 
In Sourceability, we ensure that business decisions are made with high ethical standards and in compliance with the law. We work against corruption in all its forms, including bribery and facilitation payments. Likewise, it is important for us that our suppliers do not engage in any form of corrupt practices, and we expect suppliers to maintain adequate procedures for preventing employees, suppliers etc. from undertaking any illegal behavior regarding corruption. 

Anti-corruption: 
Suppliers are prohibited from offering Sourceability employees money in any amount, gifts, loans, discounts or valuables that could incite the employees to act in breach of their duties. Gifts and invitations that fall within the scope of normal business hospitality, custom and courtesy and are therefore within the permitted range of gifts and gratuities at Sourceability are exempt.

In its anti-corruption program, Sourceability undertakes to advance business through quality and integrity alone. Sourceability therefore follows a zero-tolerance policy regarding the offering or acceptance of bribes, conflicts of interest and all other forms of corruption.

We also expect our Suppliers to prohibit, and where appropriate to sanction, all forms of corruption, bribery and other immoral conduct of this nature.

Fair competition
We expect our suppliers to act in compliance with applicable national and international competition legislation and regulation. 

Confidential information 
We expect our suppliers to keep all confidential and proprietary information in strict confidence, except when authorized or legally required to disclose information and data.

Conflict of Interest
Business and private interests are strictly separated at Sourceability. No individual may abuse their own position in the company for their own benefit or for the benefit of their family or friends. All employees of the business partner are required to disclose any actual or suspected conflicts of interest in relation to Sourceability.

Sourceability expects its Suppliers to reach decisions relating to their business activities with Sourceability solely on the basis of objective, material criteria.

Reporting of Ethical Concerns
We expect our suppliers to report any ethical concerns or violations they may encounter within their own organization or during their business dealings with Sourceability.

Responsible Supply Chain Management
Suppliers are encouraged to extend ethical behavior expectations to their own suppliers and subcontractors, promoting responsible and ethical supply chain management.

Global Trade Compliance 
Security
Suppliers are encouraged to implement the World Customs Organization framework of standards to secure and facilitate global trade to ensure the security of their supply chains. Global supply chain security programs such as the Customs-Trade Partnership Against Terrorism and Authorized Economic Operators are examples of supply chain security programs that have adopted the framework standards. 

Import and Export
Suppliers must ensure that their business practices are in accordance with all applicable laws, directives, and regulations governing the import, export, and re-export of parts, components, technical data, and provision of services.

Anti-Boycott
Suppliers must not participate in, cooperate with, or further the cause of any unsanctioned foreign economic boycott, in accordance with the applicable laws and regulations.

Record Keeping and Information Protection 
Maintain Accurate Records 
We expect our suppliers to create and maintain fully accurate, auditable records, and not alter any record entry to conceal or misrepresent the underlying transaction represented by it. Records should be retained based on the applicable retention requirements. 

Data Privacy and Security 
We expect our suppliers to comply with all applicable data privacy laws including but not limited to the confidentiality agreements and must protect any personal or sensitive data with utmost confidentiality and security, in compliance with relevant data protection laws.

Intellectual Property Rights 
Suppliers must comply with all laws and regulations, as well as any contractual provisions between the parties, that protect the intellectual property rights of Sourceability and its customers across all jurisdictions in which Sourceability and/or the supplier operates. 

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