Supplier Code of Conduct

---

Introduction

Our Supplier Code of Conduct establishes minimum environmental, social, and governance standards for all third-party suppliers. We expect suppliers to adhere to relevant legislation and adopt progressive policies that benefit clients, staff, suppliers, and the wider community. This applies to direct suppliers and any subcontractors or third parties involved in the supply chain.

Ethics

Firstly, we partner with organizations that share our values of fairness, ethics, and legal compliance. Suppliers are expected to:

• Adhere to Legal and Ethical Standards: Comply with all relevant anti-bribery and corruption laws.
• Implement Robust Controls: Maintain effective policies, procedures, and controls to prevent bribery, corruption, money laundering, and other financial crimes.
• Maintain Ethical Conduct: Refrain from offering, giving, or receiving bribes, gifts, or advantages of any kind.
• Avoid Conflicts of Interest: Avoid any situations that could create a conflict of interest or improperly influence business decisions.
• Ensure Fair Business Practices: Maintain fair and lawful payment terms with suppliers and subcontractors.

Human rights

Secondly, our suppliers shall support and respect the UN Universal Declaration of Human Rights, the 10 Principles of the UN Global Compact, and other internationally proclaimed human rights standards. This means that suppliers are expected to embrace the following principles:

1. Zero Tolerance for Modern Slavery and Human Trafficking:
   • We demand that our suppliers adhere to strict ethical standards and prohibit any form of modern slavery, human trafficking, or forced labor.
   • We require suppliers to ensure that their workers are employed freely, paid fairly, and work in safe and healthy conditions.
2. Ethical Recruitment and Employment:
   • Suppliers must recruit workers ethically, ensuring fair recruitment practices and transparent employment contracts.
   • No fees should be charged to workers for recruitment or employment, and workers should have the freedom to leave their employment without undue restrictions.
3. Fair Labor Practices:
   • Suppliers must comply with all applicable labor laws and regulations, including those related to minimum wages, overtime pay, and maximum working hours.
   • Workers should be provided with adequate rest periods and opportunities to take time off.
4. Safe and Healthy Working Conditions:
   • Suppliers must maintain safe and healthy working environments, free from hazards and risks.
   • Adequate safety measures, including personal protective equipment, should be provided to workers.
5. Environmental Responsibility:
   • Suppliers should minimize their environmental impact and comply with environmental regulations.
   • Sustainable sourcing practices should be encouraged to protect natural resources.
6. Transparency and Accountability:
   • Suppliers must maintain transparent and accountable business practices, including accurate record-keeping and financial reporting.

Diversity and inclusion

Thirdly, we expect that our suppliers ensure that all staff in their organisation feels included and valued, regardless of their background and that the suppliers:

• comply fully with any applicable legislation and regulation on diversity and inclusion, equal opportunities, or unfair discrimination
• promote internally diversity and inclusion and prohibit unfair and unlawful discrimination, bullying, and harassment based on sexual orientation, race, ethnicity, gender, age, religion, martial/civil partnership status or disability
• have measures in place ensuring a working environment which is welcoming of the values set out above

Information security

Furthermore, our policy is to ensure that confidential data belonging to us or to our clients is secure and managed appropriately. We expect out suppliers to have measures in place that ensure:

• ongoing protection of our information through relevant cyber and information security controls
• data is managed according to the applicable data protection laws, regulations and record retention standards
• potential breaches impact our data are brought to our attention immediately
• a safe working environment for all our staff, customers, and visitors

Sustainability

Moreover, our suppliers are expected to support XBV`s environmental sustainability goals by complying with all applicable environmental laws, rules and regulations while also avoiding wasting resources and striving to have a positive environmental impact, with a focus on:

• Carbon Reduction
• Energy Efficiency
• Reduced Water Usage
• Air Quality Improvement
• Recyclability and Waste Reduction
• Hazardous Material and Chemical Management and Control
• Protecting Biodiversity
• Employee and Supplier Training

Monitoring and violations

Finally, XBV may conduct compliance surveys with our suppliers to confirm compliance with this Supplier Code of Conduct on an annual or whenever needed.

We expect suppliers to familiarise themselves with this code and ensure they comply with it while doing business with us.

XBV reserves the right to review and update this code whenever necessary.

Suppliers violating this code will be expected to rectify and address any infringement of standards within a reasonable time period. If suppliers are unable to do so, this may result in terminating the business relationship with XBV.

Should you have any questions, please reach out to us: