Supplier code of conduct

1. Purpose and Application

2. Performance Evaluation & Remediation

3. The foundational responsibilities

3.1   People workers’ rights and well being

3.1.1 Employment Practices and Documentation

3.1.2 Fair Wages

3.1.3 Child labour is prohibited

3.2   Environmental Responsibility and Sustainability

3.3   Ethics Transparency & Integrity

3.4   Conflicts of Interest

3.5   Discrimination

3.6   Data Protection

4. Summary and Acceptance

1. Purpose and Application

The following guidelines set out the framework of acceptable conduct that Zenobē expects from its suppliers, vendors, and all other third-party companies that comprise the Zenobē supply chain (“Supplier(s)”). These guidelines are based on our commitment to integrity, and we regard our Supplier base as a critical and necessary extension of our operations and future success.

All work performed for Zenobē by a Supplier must be in full compliance with this Supplier Code of Conduct and all applicable laws, rules, and regulations.

2. Performance Evaluation & Remediation

At the point of engagement with Zenobē, suppliers commit to meeting the foundational responsibilities set out in section 3 and confirm that they have plans in place to work toward these best practices of responsible operations that Zenobē expects from its suppliers.

Zenobē may conduct assessments of suppliers to monitor how they are following the practices set out in this supplier code of conduct or as part of supplier qualification. The result of such assessment may result in Zenobē not selecting supplier for future or new opportunities or requirements to put in place improvement plans.

3. The foundational responsibilities

3.1. People workers’ rights and well being

Zenobē’s approach is derived from international human rights frameworks, including the Universal Declaration of Human Rights, the ILO’s Fundamental Principles and Rights at Work, the UN Guiding Principles on Business and Human Rights, and the UN Convention on the Rights of the Child.

Suppliers must ensure that:

• All forms of modern slavery or forced labour are prohibited.
• Bonded or prison labour is not used.
• Workers have unrestricted freedom of movement and access to essential facilities.
• Overtime is voluntary.
• Workers can terminate their contracts in accordance with local laws.
• Workers are not required to deposit identification documents as a condition of employment.
• No recruitment fees are charged to workers.
• Workers are not pressured to live in employer-owned residences.
• Training on modern slavery risks is provided to line managers.
• Adequate due diligence is conducted in sourcing raw materials to avoid forced labour involvement.

Zenobē applies the principle that businesses have a responsibility to respect human rights and to avoid complicity in human rights abuses. We expect the health, safety and well-being of workers to be protected at all times and for workers to be treated equally and with respect including that:

3.1.1. Employment Practices and Documentation

Suppliers must:

• Provide all workers with a written contract in an understandable language, detailing employment terms.
• Ensure all workers have the legal right to work.
• Avoid excessive use of temporary or casual labour to bypass labour obligations.
• Maintain transparent disciplinary policies with documented escalation processes.
• Clearly document and maintain employment policies and records.

3.1.2. Fair Wages

Suppliers must ensure:

• A transparent and reliable wage calculation system.
• Wages meet or exceed national legal minimum levels or collective bargaining agreements.
• Timely wage payments, including overtime pay.
• Provision of legally required benefits, such as pensions and leave entitlements.

3.1.3. Child labour is prohibited

Zenobē follows international labour standards prohibiting child labour. Suppliers must:

• Ensure that no child labour is used directly or indirectly.
• Employ workers only above the legal minimum age (15 years or older).
• Conduct and document age verification checks.
• Develop a remediation plan if child labour is identified.

Our approach is based on the Universal Declaration of Human Rights, UN Guiding Principles on Business and Human Rights, the Convention of the Rights of the Child, The Children’s Rights and Business Principles and other applicable UN and ILO conventions.

3.2. Environmental Responsibility and Sustainability

Zenobē expects business to be conducted in a way that minimizes environmental impact and promotes sustainability, in line with the UN Global Compact and the Sustainable Development Goals.

Suppliers must:

• Comply with all applicable environmental laws and maintain necessary permits.
• Implement environmental management systems to monitor and reduce impacts.
• Establish strategies and targets for reducing greenhouse gas emissions.
• Monitor and prevent the use of illegally or unethically sourced minerals.
• Use renewable energy where possible.
• Eliminate hazardous substances from supply chains, or maintain records of their use.
• Avoid adverse impacts on vulnerable ecosystems or endangered species.

3.3. Ethics Transparency & Integrity

Zenobē adheres to the UN Convention Against Corruption and the UK Bribery Act. We expect all business to be conducted lawfully, transparently, and with integrity.

Suppliers must:

• Avoid misleading practices or coercion in business dealings.
• Adhere to all anti-bribery and anti-corruption laws.
• Establish policies to prevent bribery and corruption.
• Refrain from offering or accepting bribes or facilitation payments.

3.4. Conflicts of Interest

Suppliers must avoid conflicts of interest, including situations where:

• A Supplier employs or is partially owned by a Zenobē employee or their family member.
• A Supplier or its employees gain improper benefits from the Zenobē relationship.

Suppliers must report all conflicts of interest to Zenobē immediately.

3.5. Discrimination

Zenobē promotes a diverse and inclusive workplace. Suppliers must:

• Provide equal opportunities for all workers.
• Prohibit discrimination based on age, gender, sexual orientation, race, disability, religion, political affiliation, or marital status.
• Proactively put systems in place to prevent workplace harassment or threats of harassment.

3.6. Data Protection

Suppliers must:

• Comply with all applicable data protection laws.
• Implement appropriate security measures to protect personal data.
• Immediately report any data breaches or security incidents to Zenobē.

4. Summary

This Supplier Code of Conduct serves as a commitment to ethical, fair, and responsible business practices. Suppliers must ensure that these standards are upheld throughout their operations and supply chains.