SUPPLIER CODE OF CONDUCT

1. INTRODUCTION

At Kalexius, we prioritize sustainable development across all dimensions, embedding it in our strategy, projects, and operations. Our commitment extends to becoming a benchmark in aligning with the Sustainable Development Goals (SDGs) as set forth by the United Nations. These goals aim to create a more sustainable and equitable world by 2030, covering areas such as poverty, hunger, health, education, gender equality, clean water, affordable and clean energy, and more.

By aligning with the SDGs, we affirm our dedication to contributing positively to these global objectives and promoting sustainable development on a broad scale.

This Supplier Code of Conduct serves as the foundation for enduring relationships with our suppliers, emphasizing our expectation that they, along with their suppliers, uphold these principles.

This Code of Conduct applies to all our suppliers while applying the concept of proportionality. We expect our largest suppliers to be exemplary on all aspects outlined in this code of conduct.

2. ROLES AND RESPONSIBILITIES

Kalexius places great emphasis on the pivotal role played by its dedicated employees that are engaged in the selection process and collaborate with suppliers. These individuals serve as the primary guardians, ensuring that our suppliers align with the expectations set out in our policy. Any concerns or issues encountered during this process shall be promptly discussed or reported to their respective managers, who will work together to find effective solutions.

It is the responsibility of Kalexius Management to ensure that the relevant employees are adequately trained and empowered to serve as the “1st line of defense.” This proactive stance allows for active monitoring of our suppliers’ ethical conduct, reinforcing our commitment to maintaining high standards throughout our supply chain.

Kalexius is firmly committed to supporting suppliers aiming to enhance their overall conduct, particularly in relation to smaller suppliers that face challenges in meeting these standards. By fostering a collaborative environment and helping where needed, we aim to promote ethical conduct across our entire network of suppliers.

3. RESPECT HUMAN RIGHTS AT WORK

3.1. PROHIBIT DISCRIMINATION AND HARASSMENT

• Prohibit discrimination based on race, gender, religion, nationality, age, disability, or any other protected characteristic.
• Prohibit workplace harassment and discriminatory practices, especially in recruitment, Compensation, benefits, or dismissal.

3.2. NO CHILD LABOR AND FORCED LABOR

• Prohibit the use of workers under 18 for hazardous or night work and under 15, except where local laws provide greater protection.
• Ensure no employee is forced to work against their will, using any form of coercion.
• Prohibit the confiscation of employee identity documents, ensuring immediate and automatic access.
• Ensure no recruitment costs are borne by an employee.

3.3. FAIR WORKING CONDITIONS AND REMUNERATION

• Establish clear employment contracts.
• Provide fair wages, comply with maximum working hours, and ensure adequate rest.
• Document compliance with these requirements.

3.4. HEALTH, SAFETY, AND SECURITY

• Provide a safe workplace and, if accommodation is provided, ensure it meets safety and living space standards.
• Implement a comprehensive system, including risk analysis, preventive measures, monitoring, incident response plans, and periodic reviews.

3.5. FREEDOM OF EXPRESSION, ASSOCIATION, AND COLLECTIVE AGREEMENT

• Allow employees to choose to join a collective bargaining organization.
• In restricted situations, ensure employees can participate in a dialogue regarding their collective work situation.

3.6. COMPLAINTS AND CONCERNS

• Ensure workers can express complaints and concerns without fear of reprisal.

4. PRESERVE THE ENVIRONMENT

4.1. ENERGY EFFICIENCY

• Implement an energy efficiency management system.
• Continuously work to reduce greenhouse gas emissions from operations, products, and services.

4.2. ENVIRONMENTAL PROTECTION

• Limit the impact of industrial activities on air quality, water resources, and soil.
• Establish measurable environmental objectives and implement a risk management system.

4.3. PROMOTION OF CIRCULAR ECONOMY AND RESPONSIBLE RESOURCE USE

• Efficiently use natural resources and reduce waste production.
• Apply the principles of “reduce, reuse, recycle, recover.”

4.4. PROTECTION OF BIODIVERSITY

• Avoid locating production sites in protected natural areas.
• Continuously reduce the impact on biodiversity by applying the Avoid-Reduce-Compensate mitigation hierarchy.

5. ACT WITH BUSINESS INTEGRITY

5.1. PREVENT CORRUPTION, CONFLICTS OF INTEREST, AND FIGHT FRAUD

• Reject all forms of corruption, both active and passive, private and public.
• Combat fraud.
• Avoid conflicts of interest, particularly when personal interests may interfere with professional interests.

5.2. RESPECT COMPETITION LAW

• Comply with the rules of applicable competition law.

5.3. PROMOTE ECONOMIC AND SOCIAL DEVELOPMENT

• Establish trust through dialogue with local communities.
• Encourage sustainable local development initiatives.
• Provide opportunities for local businesses to flourish.
• Pay appropriate Taxes and social contributions to support economies in which you operate.

5.4. INFORMATION SECURITY AND DATA PROTECTION

• Train staff on best practices to protect your business from attacks and misuse of data.
• Implement systems and technology such as anti-virus and firewalls to protect your digital assets.
• Abide by all applicable data protection laws & regulations.

6. COMPLIANCE AND AUDITS

Ensuring adherence to the stipulated principles is imperative, and as part of our commitment to transparency and accountability, audits may be conducted. Suppliers are expected to actively cooperate throughout the audit process.

In the event of non-compliance following the audit, corrective measures will be implemented to address the identified issues.

We retain the right to terminate business relationships in the event of persistent non-compliance.

7. CONTINUOUS IMPROVEMENT

We will review and update this policy periodically to reflect changing circumstances and emerging best practices.