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. 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 Code of Conduct sets forth the principles and standards that Kalexius, its employees, and all suppliers, along with their respective supply chains, are expected to uphold. It serves as the foundation for enduring relationships, emphasizing mutual accountability. Kalexius expects all parties to model exemplary conduct in alignment with this code, ensuring that our shared values are consistently maintained.

2. ROLES AND RESPONSIBILITIES

Kalexius and its employees, alongside our suppliers, are jointly responsible for maintaining the standards outlined in this Code of Conduct. Employees involved in supplier selection and engagement play a key role in upholding these standards, actively ensuring compliance and addressing concerns as they arise.

Kalexius Management is responsible for providing relevant employees with training and resources to serve as the “1st line of defense,” actively monitoring ethical conduct throughout our operations and supply chain. We are committed to supporting suppliers, especially smaller entities, in their efforts to meet these standards, fostering a collaborative environment for continuous improvement.

3. RESPECT HUMAN RIGHTS AT WORK

3.1. PROHIBIT DISCRIMINATION AND HARASSMENT

• Discrimination based on race, gender, religion, nationality, age, disability, or any other protected characteristic is strictly prohibited.
• Harassment and discriminatory practices, particularly in recruitment, compensation, benefits, or dismissal, are not tolerated.

3.2. NO CHILD LABOR AND FORCED LABOR

• The use of child labor is strictly prohibited, with protections ensuring no workers under 18 engage in hazardous or night work and no workers under 15, except where local laws provide greater protection.
• Forced labor in any form is prohibited. Employees must work voluntarily and without coercion, and their identity documents must not be confiscated.
• Recruitment fees must not be borne by employees to ensure fair employment practices.

3.4. MODERN SLAVERY

• Kalexius and its suppliers must actively ensure that their operations and supply chains are free from modern slavery, including forced labor, bonded labor, and human trafficking.
• Implement effective systems and controls to prevent, detect, and address risks of modern slavery within the business and supply chain.
• Provide training to the workforce on recognizing and combating modern slavery and support victims of such practices.
• Be transparent about efforts to combat modern slavery and report any identified risks or incidents promptly.

3.3. FAIR WORKING CONDITIONS AND REMUNERATION

• Clear employment contracts must be established.
• Fair wages must be paid, working hours must comply with legal maximums, and adequate rest periods must be provided.
• Compliance with these conditions must be documented and regularly reviewed.

3.4. HEALTH, SAFETY, AND SECURITY

• A safe and healthy working environment must be provided, with comprehensive systems for risk analysis, preventive measures, incident response, and continuous monitoring.
• If accommodation is provided, it must meet safety and living space standards.

3.5. FREEDOM OF EXPRESSION, ASSOCIATION, AND COLLECTIVE AGREEMENT

• Employees have the right to choose whether to join collective bargaining
• Where restricted, alternative means for employees to engage in dialogue about their work conditions must be provided.

3.6. COMPLAINTS AND CONCERNS

• A safe and confidential mechanism must be in place for employees to report concerns or complaints without fear of retaliation.

4. PRESERVE THE ENVIRONMENT

4.1. ENERGY EFFICIENCY

• An energy efficiency management system must be implemented, continuously working to reduce greenhouse gas emissions.

4.2. ENVIRONMENTAL PROTECTION

• Measures must be taken to limit the environmental impact of activities on air, water, and soil, with clear environmental objectives and a robust risk management system.

4.3. PROMOTION OF CIRCULAR ECONOMY AND RESPONSIBLE RESOURCE USE

• Efficient use of natural resources and the reduction of waste production are required, adhering to the principles of “reduce, reuse, recycle, recover.”

4.4. PROTECTION OF BIODIVERSITY

• Operations must not be in protected natural areas, and actions should continuously aim to reduce impacts on biodiversity using the Avoid-Reduce-Compensate mitigation hierarchy.

5. ACT WITH BUSINESS INTEGRITY

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

• All forms of corruption, fraud, and conflicts of interest, where personal interests conflict with professional duties, are strictly prohibited.

5.2. RESPECT COMPETITION LAW

• Compliance with applicable competition laws is mandatory.

5.3. PROMOTE ECONOMIC AND SOCIAL DEVELOPMENT

• Engage in open dialogue with local communities, support sustainable local development initiatives, and contribute fairly through taxes and social contributions.

5.4. INFORMATION SECURITY AND DATA PROTECTION

• Staff must be trained in the best practices for protecting business data, with the implementation of systems and technologies like anti-virus software and firewalls.
• Compliance with all applicable data protection laws and regulations is required.

6. COMPLIANCE AND AUDITS

6.1. INTERNATIONAL SANCTIONS AND TRADE LAWS

Kalexius is committed to full compliance with all applicable international trade and sanctions regulations. We do not engage in business with any country, organization, or individual subject to government sanctions or embargoes, including Iran, Syria, North Korea, Cuba, and the Crimea region of Ukraine, among others identified by relevant authorities. We also conduct due diligence and screening of our customers, suppliers, and business partners to ensure we do not engage with sanctioned or otherwise restricted parties.

6.2. MONITORING AND ENFORCEMENT

Regular audits may be conducted to ensure adherence to the principles outlined in this Code of Conduct. All parties are expected to cooperate fully during audits, and corrective measures will be implemented in cases of non-compliance. Persistent non-compliance may result in the termination of business relationships.

7. CONTINUOUS IMPROVEMENT

Kalexius will periodically review and update this Code of Conduct to reflect changing circumstances and emerging best practices, ensuring it remains relevant and effective.