Supplier Code of Conduct

Akcelo (the "Company") is committed to conducting business with integrity and in accordance with the highest ethical standards. We expect our suppliers (the "Suppliers") to share this commitment and adhere to the principles outlined in this Supplier Code of Conduct (the "Code").

1. Ethical Business Practices

When conducting business with Akcelo you can expect that we will:

• comply with applicable laws, regulations, policies and procedures
• act with integrity and openness
• conduct business in an ethical and safe manner
• demonstrate fairness and transparency in our dealings with individuals and organisations
• disclose any perceived or real conflicts of interest
• protect and prevent the release of commercial-in-confidence information
• not seek, or accept, any financial or non-financial benefits from potential, current or past suppliers

We expect our suppliers and their supply chains to commit to the highest ethical standards. When conducting business with Akcelo we expect that you will:

• comply with applicable laws, regulations, policies, procedures and good business practices
• ensure third parties acting on your behalf comply with this code
• act with integrity and openness
• conduct business in an ethical and safe manner
• disclose any perceived or real conflicts of interest
• pay your suppliers / contractors on time
• protect and prevent the release of commercial-in-confidence information
• not offer Akcelo employees/contractors any financial or non-financial benefits
• respond to reasonable requests for advice and information

2. Labour Practices

No Forced Labour

The Supplier and its subcontractors shall employ workers who choose to be employed. All work shall be voluntary, and workers shall be free to leave upon reasonable notice. There shall be no use of forced labour, including prison labour, indentured labour, bonded labour or other forms of forced labour.

Minimum Age of Employment

The Supplier shall not utilise child labour in any stage of manufacturing or provision of services. No persons shall be employed under the age of 15 (or 14 where the law of the country of manufacture or service allows) or younger than the age for completing compulsory education in the country of manufacture or service, whichever is higher. Workers under the age of 18 shall not perform work that is likely to jeopardise the health or safety of young workers. The use of younger workers enrolled in legitimate workplace apprenticeship programs which comply with all laws and regulations of the applicable country are permitted as an exception to the minimum age requirements set out above.

Wages and Benefits

Compensation paid to workers shall comply with all applicable wage laws, including those relating to minimum wages, overtime hours and legally mandated benefits. Employees shall be compensated for overtime hours at such premium rate as is legally required in the country of manufacture or provision of services or, in those countries where such laws do not exist, at a rate at least equal to their regular hourly compensation rate. Deductions from wages as a disciplinary manner is not permitted and payment shall occur in a timely manner with pay stub or similar documentation. Suppliers shall ensure the application of the principle of equal remuneration for all workers, regardless of gender, for work of equal value.

Non-Discrimination

The Supplier shall promote cooperation, individual responsibility and acceptance of diversity among its employees and subcontractors. Hiring and employment practices such as compensation, advancement, promotions, rewards, access to training, discipline, termination or retirement must be made solely on the basis of knowledge, skill, efficiency and ability to do the job and meet its requirements. The Supplier, its employees, and subcontractors shall not engage in discrimination and no person shall be discriminated against on the basis of race, colour, age, gender, sexual orientation, ethnicity, nationality, disability, place of origin, ancestry, source of income, pregnancy, religion, political affiliation, union membership, family status or marital status. In addition, workers or potential workers should not be subjected to medical tests that could be unlawfully used in a discriminatory way.

Employee Treatment, Harassment and Abuse

The Supplier’s employees shall be treated with respect and dignity and the Supplier’s disciplinary policies and procedures shall be clearly defined and communicated to employees before application. There shall be no harsh and inhumane treatment, including any physical, sexual, psychological, verbal harassment or abuse, or corporal punishment; nor is there to be the threat of any such treatment.

3. Health, Safety, and Environment

Health and Safety

The Supplier will ensure that all workers involved in any stage of manufacturing or provision of services will be provided with a safe and healthy work environment. Conditions in all work and residential facilities shall be safe, clean and consistent with all applicable laws and regulations regarding occupational health and safety. The Supplier shall adequately inform employees of their health and safety guidelines in terms of equipment, training, management and work practices.

Environmental Responsibility

The Supplier shall be responsible to reduce the environmental impact of their products and services as well as their overall operations or ‘in-house’ practices. The Supplier must not be in violation of any national or provincial environmental regulations.

Confidentiality and intellectual property rights

Information provided by or collected by Akcelo is provided on a confidential basis, unless otherwise explicitly indicated, or the information is already in the public domain. Akcelo and our suppliers will respect and honour each other’s confidentiality and intellectual property rights.

Privacy

Akcelo expects Suppliers to protect personal privacy and comply with applicable privacy laws as well as secure data against unauthorised access or use in accordance with

4. Human Rights

Labour and human rights

We expect our suppliers to provide a fair and ethical workplace free from workplace bullying, harassment, victimisation and abuse. Our suppliers are expected to make all reasonable efforts to ensure that businesses within their supply chain are not engaged in, or complicit with, human rights abuses, such as forced or child labour, human trafficking or modern slavery.

5. Continuous Improvement

Our approach at Akcelo is to assess suppliers’ compliance with this Code on an ongoing basis, to drive continuous improvement for Akcelo and people and communities along our supply chain.

By conducting business with the Company, Suppliers acknowledge that they have read, understood, and agree to comply with this Code.

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