Supplier Code of Conduct Policy

1. POLICY PURPOSE

The purpose of this Supplier Code of Conduct (“Code”) is to establish UniUni’s expectations for ethical, legal, and responsible business conduct by all suppliers and third-party partners. Suppliers are criticalto UniUni’s success, and we expect them to operate in a manner that reflects our core values of integrity, fairness, sustainability, and compliance.

2. POLICY SCOPE

This Code applies to all companies, entities, individuals, subcontractors, and agents who provide goods or services to UniUni globally, regardless of geography or contract value.

3. THE CODE

CODE 1 – FORCED LABOUR
UNI Suppliers will not use forced or involuntary labour (e.g., forced, bonded, indentured, involuntary prison labour, human trafficking, or any modern form of slavery). UNI Suppliers will not use child labour, which refers to work performed by any person under the minimum age for employment in the country where work is performed. We support using legitimate workplace apprenticeship programs that comply with all applicable laws and regulations. UNI Suppliers should adhere to the higher standards set out in the applicable labour laws or the Conventions of the International Labour Organization that strive to eliminate forced labour and child labour.
 
Critical Benchmarks
UNI Supplier Code of Conduct bans forced or illegal child labour by suppliers. All employment must be voluntary and legal. Suppliers must comply with all applicable child labour laws, including minimum age limits, limitations of hours worked, and prohibitions against certain types of work.
 

Forced or prison labour
Forced or prison labourers are prohibited from employment if they are constrained to work as a requirement of their sentence and without compensation or otherwise in contravention of applicable law or international standards.

Indentured and bonded labour
UNI Supplier Code of Conduct prohibits any indentured or bonded labour. Indentured labour refers to situations where workers are contracted to work for a set period in exchange for certain benefits such as housing or transportation and often subject to exploitative labour conditions. Bonded labour refers to situations where workers are forced to work to pay off a debt.


CODE 2 – WAGES AND WORKING HOURS

UNI Suppliers will comply with all applicable wage and hour laws and regulations, including those relating to minimum wages, overtime hours, piece rates, and other compensation elements, and provide legally mandated benefits.

Suppliers and their sub-contractors are expected to pay at least the legal minimum and overtime wages for hours worked. Wages are expected to be paid directly to the worker or to a worker-controlled account. Workers will not be charged any recruitment fees or related costs.


Critical Benchmarks

    • All employees are paid in accordance with the minimum wage law applicable in the country of operation
    • Workers must be compensated for overtime hours at the legally mandated premium rates, or where such rates do not exist, payment for overtime hours must be at least equal to the regular hourly wage
    • Employees should receive all statutory benefits mandated by law, including but not limited to pension benefits, annual leave, and holidays. (Note: Unless specified otherwise by local legal requirements, this provision may not apply to exempt employees, including those in executive, managerial, or professional positions)
    • Establish a weekly work schedule compliant with local legal limits on regular working hours, as applicable.

CODE 3 – NON-DISCRIMINATION

UNI Suppliers will not discriminate in hiring and employment practices based on race, religion, age, nationality, social or ethnic origin, sexual orientation, gender, gender identity or expression, marital status, pregnancy, political affiliation, disability, or any other characteristics protected by law.


Critical Benchmarks

UNI Supplier Code of Conduct stipulates that job candidates and employees be judged solely based on their ability to perform the job they are applying for or currently engaged in. This provision applies to all employment decisions, including recruitment, hiring, training, promotion, and termination.


CODE 4 – RESPECT AND DIGNITY

UNI Suppliers will treat all employees respectfully and will not use corporal punishment, threats of violence, or other forms of physical coercion or harassment. Suppliers should have a policy that prohibits inappropriate conduct and a process for employees to report such conduct for Supplier investigation and resolution.


Critical Benchmarks

UNI Suppliers must not:
    • Engage in harassing or physically abusive discipline
    • Act in a threatening way towards employees
    • Submit employees to demeaning conditions

CODE 5 – HEALTH AND SAFETY

Suppliers will provide their employees with a safe and healthy workplace in compliance with all applicable laws, regulations and sound industry practices. Consistent with these obligations, UNI Suppliers must have and implement effective programs that encompass life safety, incident investigation, chemical safety, ergonomics, and other relevant protective elements.

 

Critical Benchmarks
UNI Suppliers are required to:
    • Comply with all applicable laws regarding health and safety in the workplace

    • Comply with all legal regulations regarding health and safety in residential facilities, where provided

    • Provide employees with a safe and healthy work environment, with appropriate health and safety training provided to employees

    • Effectively implement any program necessary to identify and mitigate workplace hazards


CODE 6 – ENVIRONMENTAL SUSTAINABILITY
UNI Suppliers will operate in a manner that is protective of the environment. Suppliers must comply with all applicable environmental laws, regulations and sound industry practices, such as chemical and wastemanagement and disposal requirements, recycling, industrial wastewater treatment and discharge, air emissions controls, environmental permits and environmental reporting. Suppliers must also comply with any additional environmental equirements in UNI’s design, product specifications, and contract documents and partner with UNI in sustainability efforts where possible.
 

Critical Benchmarks
The UNI Supplier Code of Conduct requires suppliers to conduct their operations in environmentally responsible ways and in compliance with all applicable environmental laws, regulations, and standards. Suppliers must also meet any additional requirements specific to their work with UNI and collaborate with UNI in its sustainability efforts where possible. The applicability of compliance will vary depending on the product or service being provided to UNI and the associated operations.
 

CODE 7 – DATA SECURITY AND PRIVACY
UNI is committed to protecting the data and privacy of all stakeholders, including its customers, consumers, employees, partners, and shareholders. UNI Suppliers must fully comply with all applicable data protection laws, as well as any additional obligations imposed by the data processing agreements entered with UNI, to ensure the integrity and confidentiality of information.
 

Critical Benchmarks
Suppliers must implement appropriate data security measures to safeguard personal and sensitive information from unauthorized access, loss, or disclosure. This includes conducting regular security audits and ensuring that all employees are trained in data handling best practices. Suppliers are required to establish clear protocols for data collection, storage, processing, and sharing, as well as to promptly report any data breaches or incidents.
 

CODE 8 – LEGAL AND ETHICAL DEALINGS
UNI Suppliers will comply with all applicable laws and regulations in all locations where they conduct business, especially concerning strict compliance with all laws and regulations on bribery, corruption and prohibited business practices. UNI expects suppliers to conduct their business following the highest ethical standards.
 

Critical Benchmarks
UNI Supplier Code of Conduct requires that Suppliers:
    • Know and comply with all applicable legal requirements, including U. S. import, export and trade laws and similar laws of the countries in which the Supplier operates
    • Review internal processes and procedures for legal compliance and ethics issues
    • Not offer or provide cash or non-cash gifts to any UNI employee, or to anyone else on UNI’s behalf, to influence them to take or not take a course action or for any other improper purpose
    • Avoid any conflict of interest between the Supplier and UNI and disclose all such actual or potential conflicts to UNI promptly.
    • Comply fully with all anti-bribery laws, including the Canadian Corruption of Foreign Public Officials Act and U.S. Foreign Corrupt Practices Act, where applicable
    • Maintain adequate physical and electronic security for all confidential information relating to UNI
    • Only use subcontractors that do not violate ethical standards through bribes, kickbacks or other similar improper or unlawful activity
    • Must not represent themselves as agents or representatives of UNI without UNI’s prior written consent
 
GENERAL
Notwithstanding anything in this Code, Supplier shall comply with all terms of contracts between Supplier and UNI and all applicable laws. Nothing herein shall excuse Supplier from such obligations.

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