Code of conduct for suppliers

The purpose of the Netgroup Energy Code of Conduct for Suppliers is to define the general requirements of our suppliers.

The Code of Conduct for Suppliers is based on Netgroup Energy's Code of Conduct for employees and international conventions and standards such as the United Nations Global Compact and International Labour Organisation's (ILO) eight fundamental conventions.

We expect our suppliers to abide by the laws and regulations of the countries in which they operate and the guidelines in this code of conduct.

Working conditions and human rights

We see the Ten Principles of the United Nations Global Compact as necessary to create sustainable and successful businesses. We expect our suppliers, and their suppliers in turn, to follow the Ten Principles, i.e. support and respect the protection of internationally proclaimed human rights and make sure that they are not complicit in human rights abuses. We expect our suppliers, and their suppliers in turn, to:
- Abide by the laws and regulations in the countries in which they operate.
- Uphold the freedom of association and the effective recognition of the right to collective bargaining.
- Avoid all forms of forced and compulsory labour, including child labour.
- Work against discrimination based on sex or gender, transgender identity or expression, ethnicity, religion or other belief, disability, sexual orientation, or age, within the company and in recruiting new employees.
- Ensure a safe and healthy work environment for all employees.
- Offer terms of employment that meet or exceed legal minimum requirements or collective agreements.
- Ensure that all employees have valid employment contracts and that they understand the terms of their contracts.

Environmental performance

We, our suppliers, and their suppliers, in turn, shall comply with the laws and regulations that apply to our environment. In addition, we must protect the environment and limit our total environmental impact throughout the value chain by working proactively to reduce the environmental footprint of our operations, products, and services, such as reducing our emissions and making choices that save our resources, for example by reusing and working for a circular economy.

We expect our suppliers, and their suppliers in turn, to:

- Apply a precautionary approach to environmental challenges, i.e., take precautionary measures when there is reason to believe that a potential measure may affect the health or safety of a person, society, or the environment.
- Continuously work with risk management.
- Actively work to reduce the environmental impact of their operations, products, and services.
- Encourage the development and diffusion of environmentally friendly technologies.
- Handle chemicals and other potentially harmful products safely and substitute them with less harmful products when possible.
- Use minerals and metals that have been extracted and traded in such a way that it does not contribute to human rights violations, unethical business practices (e.g. corruption), environmental damage, or conflict financing.
- Offer complete transparency and traceability for the entire supply chain if conflict minerals (3TG - tin, tantalum, tungsten, and gold) are handled.

Anti-corruption

We, our suppliers, and their suppliers in turn, must conduct our business and transactions in compliance with applicable laws and regulations related to bribery and corruption. In line with our zero-tolerance for bribery and corruption, suppliers must never engage in, or tolerate, any act that may be construed as bribery or corruption.

Protection of confidential information and intellectual property

The confidential information and/or intellectual property rights that we share with our suppliers during a business relationship are always confidential unless there is a written decision saying otherwise. The information shall only be shared with those who need it to perform their tasks, and only to the extent necessary.

Should any unauthorized person become aware of confidential information and/or intellectual property rights, the parties concerned shall be informed immediately and the incident shall be investigated.

Data protection

We and our suppliers, and their suppliers in turn, are obligated to comply with applicable data protection laws and regulations when we process personal data in connection with our operations.

In addition, suppliers performing a processing activity on our behalf are required to comply with the agreed-upon specific contractual provisions. Our suppliers, and their suppliers in turn, have a responsibility to protect personal data from improper disclosure, theft, or misuse, and must immediately report any incident to all parties concerned.

Compliance and audits

Netgroup Energy has the right to revise or audit suppliers to check compliance with our requirements, the quality of a service/product, etc. To make the audits successful, both parties must work together and provide the relevant information.

We and our suppliers agree that it is a crime not to follow agreements, laws, and other requirements that affect us. This applies at all levels. Violations can have consequences, such as taking measures to correct the error and ensuring that it does not happen again, damages, termination of ongoing business, or other relevant action. This must be done in writing so that no ambiguities arise.