Supplier Code of Conduct

1. Purpose and scope

BONDAP LTD ("BONDAP") is a UK technology consulting and SaaS company (products including B-SAFE, B-CRM, Freibaum and Hovix, plus e-commerce, hosting, development, help desk, training and systems support) serving clients worldwide, together with our BONDAP consortium partner BONDAP Sp. z o.o. (Gdańsk, Poland). Under the UK Modern Slavery Act 2015 and our published Modern Slavery Statement, we are committed to ensuring that modern slavery and human trafficking have no place in our business or supply chains.

This Code sets out the minimum standards we require of every supplier, contractor, subcontractor, agency and labour provider we engage ("Supplier"). It applies to your direct relationship with BONDAP and flows down: you must apply equivalent standards to your own subcontractors, agencies and suppliers, and you remain responsible for their compliance as if it were your own.

By accepting a purchase order, signing a contract, or continuing to trade with BONDAP after receiving this Code, you agree to abide by it.

2. Labour and human rights standards

Suppliers must ensure, throughout their own operations and those of their subcontractors and labour providers, that:

• No forced, bonded, or trafficked labour. All work is performed voluntarily. Workers may terminate their employment with reasonable notice and are not subject to threats, debt bondage, or physical or psychological coercion.
• No child labour. No worker is employed below the applicable legal minimum working age, and in no case below 15 (14 where permitted by ILO Convention 138 exceptions), with additional protections for workers under 18.
• Freely chosen employment. Employment is based on a genuine offer accepted by the worker, not on deception about the nature, location or terms of the work.
• Employer Pays Principle. No worker is charged, directly or indirectly, any fee, deposit or cost associated with securing employment (recruitment, placement, visa, transport or administrative fees). Any such costs are borne by the employer or the recruitment agency it engages.
• Identity and travel documents. Workers retain possession of their own passports, identity documents and work permits at all times. These must never be retained or confiscated by the employer or a recruitment agency.
• Written contracts. Every worker receives a written contract or statement of terms, in a language they understand, before starting work, setting out pay, hours, deductions and notice periods.
• Fair pay. Wages meet or exceed the applicable legal minimum wage (or industry benchmark where higher), are paid regularly, and deductions are lawful, transparent and disclosed to the worker in advance.
• Working hours. Working hours, overtime and rest periods comply with applicable law and, as a baseline, do not exceed ILO/international norms for regular and overtime hours; overtime is voluntary and compensated.
• Freedom of association. Workers are free to join, or not join, a trade union or worker representative body and to bargain collectively, without fear of reprisal.
• No discrimination, harassment or inhumane treatment. No physical punishment, threats of violence, sexual or other harassment, or discrimination on grounds such as race, sex, religion, disability, age or migration status.
• Health and safety. A safe working environment is provided, consistent with applicable law and, at minimum, ILO occupational safety standards, including for temporary, agency and migrant workers.

These standards reflect the ILO core labour conventions and apply in particular to our identified higher-risk categories — construction and land development, cleaning, catering, promotional goods and temporary labour — and to the protection of workers most at risk of exploitation, including migrant and foreign workers, agency and temporary staff, refugees, young or student workers, and women in low-paid roles.

3. Management expectations

Suppliers are expected to:

• Comply with the higher standard. Follow applicable local, national and international law and this Code, whichever sets the stricter requirement.
• Be transparent about their supply chain. Disclose, on request, the use of subcontractors and recruitment or labour agencies, and the countries in which work is performed.
• Complete BONDAP's Modern Slavery Questionnaire when asked, accurately and within 10 business days of the request, unless the request specifies a longer period.
• Notify BONDAP promptly. Report any actual or suspected instance of modern slavery, human trafficking, forced labour or child labour touching BONDAP's supply chain — whether within the supplier's own operations or further down its supply chain — to BONDAP within 5 business days of becoming aware of it, using the contact details in Section 5.
• Maintain records sufficient to demonstrate compliance with this Code, and retain them for at least 3 years for review.
• Take corrective action promptly where a gap against this Code is identified, and cooperate with BONDAP in agreeing a remediation plan.

4. BONDAP's rights

To manage modern slavery risk in our supply chain, BONDAP reserves the right to:

• Request information, documentation or completion of our Modern Slavery Questionnaire at any point in the relationship, including at contract commencement and renewal.
• Require a written remediation plan, with agreed timescales, where a compliance gap or incident is identified.
• Conduct an audit or site visit, on 10 business days' written notice, for suppliers assessed as higher risk (including those in the categories listed in Section 2) or where a concern has been raised.
• Suspend or terminate the contract, in whole or in part, where a Supplier commits a material breach of this Code that is not remedied within the timescale agreed with BONDAP, or where the breach involves an actual instance of modern slavery or trafficking, in which case BONDAP may terminate immediately.

Use of these rights will be proportionate to the supplier's size, risk profile and the nature of the relationship, consistent with BONDAP's Supply Chain Management Policy.

5. Raising a concern

Any worker in BONDAP's supply chain — including a Supplier's own employees, subcontractors or agency workers — can raise a modern slavery concern directly with BONDAP, in confidence and without going through their employer, by contacting:

• Email: speakup@bondap.com
• UK Modern Slavery & Exploitation Helpline: 08000 121 700 (24 hours, free, confidential)

Concerns raised in good faith will be handled in line with BONDAP's Whistleblowing and Modern Slavery Reporting Policy and Modern Slavery Incident Response and Remediation Procedure. No worker or Supplier will be penalised by BONDAP for raising a genuine concern.

6. Acknowledgement

By signing below, the Supplier confirms that it has read, understood and agrees to comply with this Supplier Code of Conduct, and to apply equivalent requirements to its own subcontractors and labour providers.

© BONDAP LTD. This document is the property of Bondap and is published for information only. It may not be copied, reproduced, adapted, distributed or used for any purpose without our prior written consent.