Supplier Code of Conduct

1. INTRODUCTION

1.1 Our Commitments and Values

The company ECO RESOURCE aims to be a leader in sustainable development by integrating ethical business practices into all aspects of its operations and supply chains. We believe that responsible business is not only a requirement of the time, but also the key to long-term success and the creation of positive change for society and the planet.

This Code establishes mandatory minimum standards for all of our partners: suppliers, contractors, service providers, distributors, licensees and their sub-suppliers. It reflects our commitment to:

• International standards: the United Nations Universal Declaration of Human Rights, United Nations Guiding Principles on Business and Human Rights, UN Sustainable Development Goals (SDGs), ILO conventions, OECD Guidelines for Responsible Supply Chains.
• ESG Principles (Environmental, Social, and Corporate Governance): we systematically manage the related risks and opportunities.
• Creating transparent and sustainable supply chains capable of addressing global challenges such as climate change, social inequality and biodiversity loss.

1.2 Scope and Mandatory Nature

1. Who must comply: This Code is an integral part of any agreements with ECO RESOURCE and applies to all our business partners (hereinafter – “Suppliers”), including their own subcontractors, recruitment agencies, and raw material suppliers (“up to the source of origin”).

2. Who the standards apply to: All of the Code’s requirements apply to all workers in the supply chain, regardless of employment type (permanent, temporary, seasonal, migrant, or home-based).

3. Supplier Obligations: The Supplier must:

• Communicate the content of the Code to all of its employees and sub-suppliers.
• Implement the necessary systems to ensure continuous compliance.
• Immediately report any identified violations.
• Fully cooperate during inspections and audits.

1.3 Principles of Compliance

1. Legal basis: Suppliers must comply with all applicable national and local laws and regulations in the countries where they operate.

2. Priority of standards: If the standards of this Code are stricter than local legislation, the Supplier must comply with the higher standard. If local legislation is stricter, it must be observed.

3. Compliance assessment system: ECO RESOURCE reserves the right to assess the compliance of Suppliers through:

• Self-assessment (questionnaires, surveys).
• Document and on-site audits, including SMETA (Sedex) standards, with or without prior notice.
• Unannounced inspection visits to facilities.
• Requirements for membership in ethical data exchange platforms (e.g., Sedex).

 

• Critical and serious non-conformities must be remedied within deadlines agreed with ECO RESOURCE.
• Refusal of access for audit or lack of cooperation is considered a material violation of the Code.

1.4 Communication Channels and Reporting Violations

• For Suppliers and workers: Reports of violations related to the activities of ECO RESOURCE or its Suppliers can be submitted via the dedicated channel: er@eco-resource.com. Submissions are processed confidentially.
• Whistleblower protection policy: ECO RESOURCE guarantees protection from any forms of retaliation, intimidation, or unfair treatment against persons who report violations in good faith.

2. MANAGEMENT SYSTEM

2.1 Accountability and Leadership

• Appoint a senior leader responsible for overall compliance with the Code and ESG systems.
• Develop and publish public policies consistent with the principles of this Code (human rights, occupational health and safety, environmental policy, anti-corruption policy).

2.4 Grievance Mechanism and Whistleblower Protection

• Create a safe, accessible, and confidential mechanism for receiving and addressing complaints from workers and stakeholders.
• Adopt a policy that guarantees whistleblower protection and prohibits any reprisals for good-faith reporting.
• Regularly analyze incoming complaints to identify systemic issues and eliminate them.

2.5 Continuous Improvement and Transparency

• Set measurable ESG goals and report progress periodically.
• Strive for supply chain transparency: adoption of tracking and mapping technologies to determine raw material origin is encouraged.
• Participation in industry initiatives and collaboration with local communities for joint problem solving is recommended.

3. FUNDAMENTAL HUMAN RIGHTS

We require unconditional respect for human rights from all of our Suppliers.

3.1 Prohibition of Forced Labour and Modern Slavery

• All forms of forced, compulsory, or bonded labour are forbidden, including unfree recruitment, debt bondage, and human trafficking.
• Workers must:
• Voluntarily agree to work.
• Have the right to freely leave the workplace and accommodation.
• Retain their personal documents and passports.
• Not bear recruitment costs themselves.

3.2 Prohibition of Child Labour and Protection of Young Workers

• Child labour is prohibited. A “child” is defined as anyone under the age of 15 (or 14 in countries allowed under ILO conventions), unless national law sets a higher age.
• If child labour is found, the Supplier must ensure its safe cessation and facilitate the child’s return to education.
• Workers under 18 (young workers) must not perform hazardous, night, or health-endangering work. Their employment must not impede education.

3.3 Freedom of Association and Collective Bargaining

• Workers have the right to form trade unions, join them, and engage in collective bargaining without discrimination, retaliation, or interference.
• In countries where freedom of association is restricted by law, the Supplier must encourage alternative lawful forms of worker representation (e.g., worker councils).
• The right to lawful strike must be respected.

3.4 Non-Discrimination and Harassment

• Discrimination in hiring, pay, promotion, dismissal, or access to training on the basis of race, sex, age, religion, disability, sexual orientation, political views, etc., is forbidden.
• A work environment free from harassment, intimidation, mistreatment, and sexual harassment must be ensured.

3.5 Respect for Local Communities and Land Rights

• Supplier activities must respect traditional and lawful rights of local communities to land, territory, forest, and water resources.
• Any operations affecting land use must be based on Free, Prior, and Informed Consent of affected communities.
• Activities involving unlawful or unjust land grabbing are forbidden.

4. FAIR WORKING CONDITIONS

4.1 Working Hours and Rest

• The working week, including overtime, shall not exceed 60 hours. The standard working week shall not exceed 48 hours.
• Overtime work must be voluntary, paid at a premium rate, and must not be regular.
• Workers are guaranteed at least one rest day in every seven-day period, or two rest days in a two-week period.

4.2 Wages and Social Benefits

• Wages for a standard working week must be at least the official minimum wage or the relevant industry standard, whichever is higher. ECO RESOURCE recommends striving to pay a living wage.
• Wages must be paid on time, in full, and in a form that is understandable to workers. Unjustified deductions are prohibited.
• Workers must receive all legally required social benefits (paid leave, sick leave, pension contributions).

4.3 Employment Contracts and Job Security

• All workers must have a clear written employment contract in their native language before starting work, specifying conditions of employment, wages, working hours and grounds for termination.
• Use of arrangements that mask the true nature of employment (e.g., excessive use of informal temporary contracts to evade legal obligations) is not permitted.
• Investment in professional development and training of employees is recommended.

5. OCCUPATIONAL HEALTH AND SAFETY

The highest priority is zero harm in the workplace.

5.1 Proactive Occupational Safety Management

• A health and safety management system must be implemented, including the appointment of responsible persons at the highest level.
• Regular assessment of occupational risks (including psychosocial risks) must be conducted and measures taken to eliminate them (following the hierarchy of controls).
• Personal protective equipment (PPE) must be provided free of charge and workers trained in its use.
• All incidents and accidents must be recorded and investigated.

5.2 Accommodation Conditions (if provided)

• Worker housing or accommodation must be safe, hygienic, and provide personal space.
• Fire safety, sanitation and ventilation standards must be met.
• Accommodation charges must not be excessive or deprive workers of fair income.

5.3 Handling of Hazardous Substances

• Hazardous chemicals must be identified, labelled, and safety data sheets must be available to workers.
• Procedures for safe storage, handling, disposal and, where possible, substitution with less hazardous alternatives must be implemented.

5.4 Emergency Preparedness

• Emergency response plans (fire, natural disasters, chemical releases) must be developed and tested.
• Clear evacuation routes, working alert systems and trained first aid personnel must be in place.

6. ENVIRONMENTAL PROTECTION AND CLIMATE ACTION

We expect Suppliers to be partners in combating climate change and environmental degradation.

6.1 Environmental Management System

• Implement an environmental management system aligned with ISO 14001 or equivalent.
• Identify significant environmental aspects and impacts, set targets for reduction, and regularly report progress.
• Immediately report serious environmental incidents to ECO RESOURCE.

6.2 Climate Change and Energy Efficiency

• Calculate and begin tracking your carbon footprint.
• Develop and implement a low-carbon transition plan with goals for improved energy efficiency and increased use of renewable energy.
• ECO RESOURCE recommends that Suppliers consider setting science-based targets.

6.3 Water and Wastewater Management

• Take measures to reduce water consumption, reuse and treat water, especially in water-scarce regions.
• Wastewater must be treated at the level required by law before discharge.
• Activities must not interfere with local communities’ access to clean water.

6.4 Waste Management and Circular Economy

• Apply the waste hierarchy: avoid → reduce → reuse → recycle → dispose.
• Hazardous waste must be disposed of by licensed organizations in compliance with all regulations.
• Strive to reduce packaging waste using recyclable, secondary or biodegradable materials.

6.5 Biodiversity Protection and Deforestation Prevention

• Suppliers must not participate in destruction or degradation of natural forests.
• Activities must not lead to destruction of protected areas or habitats of rare species.
• Agricultural and forest raw materials must be fully traceable to the place of origin.

7. BUSINESS ETHICS AND CORPORATE GOVERNANCE

We conduct business honestly, transparently, and in strict compliance with the law.

7.1 Anti-Corruption and Bribery

• Offering, giving, promising, or accepting bribes or illegal inducements in any form is strictly prohibited.
• Suppliers must comply with all applicable laws.

7.2 Gifts, Entertainment and Conflicts of Interest

• Gifts, business entertainment, and other benefits to ECO RESOURCE employees are allowed only if they are modest, transparent, business-related, and do not create a sense of obligation. Gifts to procurement staff are prohibited.
• Situations of conflict of interest (e.g., employment of relatives of ECO RESOURCE personnel, ownership stakes in competitor firms) must be avoided.

7.3 Fair Competition and Trade

• Participation in price-fixing, market-sharing, or other activities violating competition laws is prohibited.

7.4 Accuracy of Environmental Claims

• Any environmental claims (“green”, “eco”, “carbon-neutral”) must be accurate, demonstrable, and verifiable, according to recognized standards (e.g., ISO 14021).
• Misleading consumers is prohibited.

7.5 Information Security, Data Protection and Responsible AI

• Suppliers must protect ECO RESOURCE’s confidential information and personal data in accordance with applicable laws.
• Use of ECO RESOURCE data (including personal and commercial) for training artificial intelligence or other purposes is prohibited without direct written consent.
• AI systems must be developed and used ethically, considering risks of discrimination, bias, and transparency.

7.6 Compliance with International Sanctions and Export Control

• Suppliers must strictly comply with all applicable international sanctions, embargoes, and export control laws.
• Appropriate checks of counterparties against relevant sanction lists are required.

8. CONSEQUENCES OF VIOLATIONS AND COLLABORATION INCENTIVES

8.1 Consequences of Violations

Non-compliance with this Code is considered a breach of contractual obligations. Depending on the severity and nature of the violation, ECO RESOURCE may apply the following measures (sequentially or selectively):

1. Corrective action requirement: Identification of non-conformity and agreement of a Corrective Action Plan with clear deadlines.

2. Enhanced monitoring: Increased frequency of inspections and reporting.

3. Temporary restrictions: Suspension of new orders or expansion of cooperation until violations are corrected.

4. Review of relationship: Reduction of purchase volumes or refusal to renew the contract.

5. Immediate termination: Termination of all active contracts without compensation in cases of severe or repeated violations (e.g., use of forced or child labour, corruption, intentional concealment of information, refusal of audit).

8.2 Support from ECO RESOURCE

We aim for partnership and are ready to support Suppliers on their path to improvement:

• Sharing best practices: organising training webinars, providing policy templates and methodological materials.
• Consultations: during audits and regular interaction our specialists can provide advice on implementation of requirements.
• Recognition: Suppliers demonstrating outstanding results and innovation in sustainability may receive public recognition, long-term contracts and priority partner status.

Effective Date: 25.12.2025