FOR SUPPLIERS AND THIRD PARTY INTERMEDIARIES OF HEURISTIX GROUP¹

This Code of Conduct² defines the basic requirements placed on Disprz’ suppliers and third party intermediaries concerning their responsibilities towards their stakeholders and the environment. The supplier and/or third-party intermediary, by contracting with Disprz, whether directly or indirectly, in oral or in writing, or by their performance of obligation in the form of a supplier, business partner, intermediary, consultant, shall undertake to:

Legal Compliance:

• comply with the laws and regulations of the applicable legal systems, including applicable export control and customs regulations.
• ensure respect of all internationally proclaimed human rights by avoiding causation of and complicity in any human rights violations, heightened attention shall be paid to ensuring respect of human rights of specifically vulnerable rights holders or groups of rights holders such as women, children or migrant workers, or of (indigenous) communitie;
• promote equal opportunities and treatment of employees, irrespective of skin color, race, nationality, ethnicity, political affiliation, social background, disabilities, gender, sexual identity and orientation, marital status, religious conviction, or age.
• refuse to tolerate any unacceptable treatment of individuals such as mental cruelty, sexual harassment or discrimination including gestures, languages, and physical contact, that is sexual, coercive, threatening, abusive or exploitative and comply with the principles of non-discrimination with regard to supplier selection and treatment;
• recognize the legal rights of workers to form or join existing trade unions and to engage in collective bargaining; neither disadvantage nor prefer members of employee organizations or trade unions;
• adhere to all applicable working-hours regulations and pay fair wages for labor and adhere to all applicable legal requirements in respect of minimum wages and compensation laws globally, including in the event of cross-border personnel deployment;
• act in accordance with the applicable statutory and international standards regarding occupational health and safety and provide safe working conditions and provide training to ensure employees are educated in health & safety issues;
• establish a reasonable occupational health & safety management system;
• provide access to a protected mechanism for their employees to report possible violations of the principles of this Code of Conduct;
• act in accordance with the applicable statutory and international standards regarding the environment and minimize environmental pollution and make continuous improvements in environmental protection by establishing a reasonable environmental management system;
• tolerate no form of and do not engage directly or indirectly in any form of corruption or bribery and do not grant, offer or promise anything of value to a government official or to a counterparty in the private sector to influence official action or obtain an improper advantage. This includes to renounce from giving or accepting improper facilitation payments;
• act in accordance with national and international competition laws and do not participate in price fixing, market or customer allocation, market sharing or bid rigging with competitors;
• respect the intellectual property rights of others;
• avoid and/or disclose internally and to Disprz all conflicts of interest that may influence business relationships, and to avoid already the appearance thereof;
• process personal data confidentially and responsibly, respect everyone’s privacy and ensure that personal data is effectively protected and used only for legitimate purposes;
• treasonable efforts to avoid in its products the use of raw materials which originate from Conflict-Affected and High-Risk Areas and contribute to human rights abuses, corruption, the financing of armed groups or similar negative effects; and
• use reasonable efforts to make its suppliers comply with the principles of this Code of Conduct.

The supplier and/or third-party intermediary, shall not to:

• directly or indirectly, facilitate money laundering or terrorism financing;
• use or contribute to slavery, servitude, forced or compulsory labor and human trafficking;
• employ workers under the age of 15 or, in those countries subject to the developing country exception of the ILO Convention 138, not to employ workers under the age of 14; and
• employ workers under the age of 18 for hazardous work according to ILO Convention 182.

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1. Heuristix Group shall mean Heuristix Digital Technologies Private Limited, a private limited company incorporated under the laws of the Republic of India and shall include its affiliates, group companies and subsidiaries (whether present or future).  Heuristix Group shall also be referred with its brand name “Disprz.”

2. Disprz reserves the right to reasonably change the requirements of this Code of Conduct from time to time. In such event Disprz expects the supplier to accept such changes.