Supplier Conformance with XIMNET’s Supplier Code of Conduct:

• Underlying Obligations. In addition to these responsibilities, suppliers must comply with all applicable laws; legal regulations, directives and guidelines; and all obligations in any contract that a supplier may have with us.
• On-Site Work. Suppliers using our properties or facilities will comply with all of our applicable policies and requirements.
• Certifications. If XIMNET requests additional certifications, suppliers will make good faith efforts to obtain such certifications in a timely manner.
• Information Disclosure. Suppliers will accurately disclose information regarding their labour, health and safety, environmental practices, business activities, structure, financial situation and performance, in accordance with prevailing industry practices.
• Cooperation. Suppliers will cooperate with any information requests or audits that we may initiate to confirm their fulfilment of these responsibilities. Though we seek to work with suppliers to improve conditions, we may terminate our relationship with any supplier that fails to meet these responsibilities.

LABOUR AND HUMAN RIGHTS

XIMNET is committed to upholding the human rights of workers and treating them with dignity and respect. This applies to all workers, including temporary, migrant, student, contract, direct employee and any other type of worker. As a result, suppliers must manage their own workforce in order to achieve the following results:

• Suppliers will not use or permit any form of forced, bonded or indentured labour. All work must be voluntary, and all workers must be free to terminate their employment at any time. Suppliers will not hold workers’ identity, immigration or work permit documents longer than reasonably necessary for administrative processing. Suppliers are expected not to require workers to pay recruitment fees or other fees for their employment, either directly or through third parties, and are expected to repay any worker that has paid such fees. Suppliers will not unreasonably restrict workers’ freedom to move into, out of or at working facilities. As part of the hiring process, suppliers are expected to give each worker a written agreement describing the worker’s terms of employment in a language understood by the worker and, if internationally relocating, the written agreement will be provided before they leave their country of origin.
• Suppliers will not use child labour. Workers under the age of 18 will not perform work that is likely to jeopardise their health or safety, including night shifts and overtime. Suppliers may use legitimate, properly managed apprenticeship programmes, such as student internships. Unless otherwise addressed by local law, suppliers are expected to pay student workers, interns and apprentices at least the same wage rates as other entry-level workers performing equal or similar tasks.
• Suppliers will pay legally mandated wages and benefits, will comply with the law regarding wage deductions and will provide workers with the basis on which workers are paid via pay stub or similar documentation. Suppliers are expected not to deduct from wages as a disciplinary measure.
• Except in emergency or unusual situations, for suppliers’ workers paid hourly, workweeks are expected not to exceed 60 hours per week (including overtime) or, if less, the maximum set by local law. Workers should be allowed at least one day off every seven days.
• Suppliers will not permit harassment, abuse, corporal punishment or inhumane treatment. Suppliers will not subject workers or potential workers to unlawful medical tests or physical exams. Suppliers will not discriminate in screening, hiring or employment practices based on race, colour, age, sex, gender, gender identity, gender expression, sexual orientation, marital status, ethnicity, national origin, caste, disability, genetic information, medical condition, pregnancy, religion, political affiliation, union membership, covered veteran status or body art. Workers’ religious practices will be reasonably accommodated. Suppliers will not enquire about potential workers’ criminal histories on employment applications or before initial interviews, or, if no interview is conducted, before making conditional offers of employment. In addition, suppliers will demonstrate a commitment to identify, measure and improve a culture of diversity and inclusion through all aspects of workplace management.
• Workers will be permitted to associate freely, bargain collectively and seek representation in accordance with local laws. Suppliers are expected to permit workers to openly communicate and share grievances with management about working conditions without fear of reprisal or harassment.

HEALTH AND SAFETY

Suppliers will integrate the following health and safety management requirements into business processes to provide workers with a healthy and safe work environment:

• Occupational Safety and Health. Suppliers will comply with all applicable safety and health laws and regulations, and identify, evaluate and control worker exposure to safety and health hazards, including chemical, biological, physical and ergonomic stressors, through proper design, engineering controls, maintenance, safe work procedures and ongoing health and safety guidance. Where these means cannot adequately control hazards, suppliers will protect workers with appropriate personal protective equipment and provide them with information about risks to them from these hazards. Suppliers will implement procedures to prevent, manage, track and report occupational injury and illness, including encouraging worker reporting, classifying and recording cases, providing medical treatment, investigating cases, implementing corrective actions and facilitating workers’ return to work.
• Emergency Preparedness. Suppliers will identify and plan for potential emergencies, and will implement emergency plans and provide guidance to workers on emergency response procedures, including emergency reporting, worker notification and evacuation, drills, fire detection and suppression equipment, exit facilities and recovery plans.
• Sanitation, Food and Housing. Suppliers will provide workers with ready access to clean toilet facilities, potable water, and sanitary food preparation, storage and eating facilities. If suppliers provide workers with residential facilities, those facilities will be clean and safe, with adequate personal space, entry and exit privileges, emergency egresses, heat and ventilation, and hot water for bathing and showering.

ENVIRONMENTAL

XIMNET recognises that environmental responsibility is integral to producing world-class products. In manufacturing operations and construction, suppliers will strive to create regenerative processes and will minimise adverse effects on the community, environment and natural resources while safeguarding the health and safety of the public. In addition:

• Environmental Permits and Reporting. Suppliers will obtain and keep current all required environmental permits, approvals and registrations, and follow their operational and reporting requirements.
• Resource Efficiency and Clean Energy. Throughout their operations, suppliers will work to reduce consumption of resources, including raw materials, energy and water. Suppliers will track, document and seek to minimise energy consumption and greenhouse gas emissions, and seek ways to improve energy efficiency and use cleaner sources of energy.
• Hazardous and Restricted Substances. Suppliers will identify and manage chemicals and other materials that pose a hazard to the environment, to ensure their safe handling, use, storage and disposal. Suppliers will identify, monitor, control, treat and reduce hazardous air emissions, wastewater and waste generated from its operations. Suppliers will adhere to our requirements restricting use of specific substances, including labelling for recycling or disposal.
• Waste Mitigation: Suppliers will work to reduce or eliminate waste of all types. Where waste cannot be eliminated, suppliers will manage and control all waste streams to comply with applicable laws and regulations, and in an environmentally responsible and secure way; this includes, but is not limited to, preventing illegal discharges and spills from entering storm drains, and treating as required prior to discharge or disposal of all wastewater and solid waste from operations, industrial processes and sanitation facilities.

ETHICS AND COMPLIANCE

Suppliers will uphold the highest standards of ethics to promote honesty and integrity in business operations, including:

• Business Integrity. Suppliers will avoid even the appearance of conflicts of interest in their work with us, and will immediately disclose any known family or other close personal relationships with our employees who have an influence over their engagements with us. If suppliers extend any business courtesies to our employees, they will do so infrequently and the courtesies must be of no more than moderate value. Suppliers will also accurately reflect their business dealings in their books and records. Suppliers will not offer or accept any form of bribery, corruption, extortion or embezzlement. Suppliers will not make illegal payments directly or indirectly. Suppliers will implement monitoring and enforcement procedures to ensure compliance with anti-corruption laws.
• Intellectual Property. Suppliers will respect intellectual property rights, and will conduct technology and know-how transfers in a manner protecting intellectual property rights.
• Responsible Materials Sourcing. Suppliers will maintain a policy reasonably assuring that any tantalum, tin, tungsten and gold in products that they manufacture does not directly or indirectly benefit armed groups that commit human rights abuses in or near the Democratic Republic of the Congo. Suppliers will exercise, and will make available to us upon request, due diligence on the source and chain of custody of these minerals.
• Privacy and Information Security. Suppliers will protect the privacy of personal information of everyone with whom they do business, including suppliers, customers, consumers and workers.
• Accessibility. Suppliers will embed relevant web accessibility standards, innovation and best practices to deliver inclusive products and services for our users and stakeholders.

MANAGEMENT SYSTEM

Suppliers are expected to adopt or establish a management system to carry out these responsibilities. The management system will be designed to ensure suppliers’ operations: (a) comply with our requirements and applicable laws and regulations; (b) conform to these responsibilities; and (c) identify and mitigate operational risks related to these responsibilities. It should also facilitate continual improvement:

The management system should contain the following elements: executive level commitment and accountability; processes to identify, monitor and comply with all applicable laws, regulations, standards and requirements; risk management processes; communications and training for all workers and suppliers as determined by suppliers; ongoing assessments, monitoring and continued improvement, including corrective action processes; a programme that provides workers with a means to report grievances anonymously and without fear of retaliation, unless prohibited by law; and a programme to ensure that suppliers will continuously monitor these reporting processes, record issues raised and take appropriate action. We recognize that concerns or grievances may arise from time to time, and we are committed to addressing them promptly, fairly, and confidentially through our grievance mechanism.

Confidentiality: All grievances submitted through our grievance mechanism will be treated with the strictest confidence. We are committed to protecting the privacy and anonymity of individuals who raise concerns. Information related to grievances will only be disclosed to those directly involved in the investigation process on a need-to-know basis.

Non-Retaliation: The company prohibits any form of retaliation against individuals who raise grievances in good faith. We are committed to creating a safe and supportive environment where individuals feel empowered to raise concerns without fear of reprisal. Retaliation against complainants will not be tolerated and may result in disciplinary action.

Acknowledgment and Initial Response: Upon receipt of a grievance, The company will acknowledge the submission within [specified timeframe] and provide an initial response outlining the next steps in the grievance process. This may include gathering additional information, conducting an investigation, or scheduling a meeting with the complainant to discuss the grievance in more detail.

Investigation and Resolution: Grievances will be investigated promptly, fairly, and impartially by designated individuals or teams with the necessary expertise. The investigation process will adhere to the principles of natural justice and due process. Once the investigation is complete, [Company Name] will take appropriate actions to address the grievance and prevent recurrence.

Appeals Process: Individuals dissatisfied with the outcome of their grievance may have the opportunity to lodge an appeal within [specified timeframe]. The appeals process will be fair, transparent, and conducted by impartial parties not involved in the initial investigation.

Documentation and Reporting: All grievances, investigations, outcomes, and remedial actions will be documented and recorded in accordance with company policies and applicable laws. Regular reports on grievance trends and outcomes will be provided to senior management for review and action as necessary.