Global Supplier Code of Conduct Policy

The Accion Labs Group comprises the following entities: Accion Labs US, Inc., Accion Labs Canada, Inc., Accion Technologies Pvt. Ltd, Accion Labs (UK) Ltd, Service-Berry Technologies Pvt. Ltd and its subsidiaries in Dubai, Singapore, USA, UK, and Australia, Accion Labs Pte Ltd Singapore, Accion Labs Sdn Bhd, Malaysia, Motifworks, Inc., Motifworks Pvt. Ltd., I2S Business Solutions Pte Ltd and its subsidiaries in Malaysia, the Philippines, UAE, and Thailand, e-Zest Digital Solutions Private Limited and its subsidiaries / Branches in UK, USA, Austria, Germany, Singapore, Accion Labs Romania, Accion Labs Mexico, Accion Labs Czech Republic. Throughout this global policy, the term “Company” shall be defined as the company for which you are providing services, which may include any of the Accion Group entities. This policy is indicative, and all suppliers are advised to be aware of the nuances that are applicable as per the local laws of the land. This policy applies to all suppliers globally to ensure consistent understanding and application of our policy while ensuring due respect for local customs and traditions. Each Supplier should carefully review this Supplier Code of Conduct and ensure all of the Supplier’s personnel dealing with the Company shall comply with it.

Scope

The Code of Conduct policy is applicable to all suppliers of the Company, and their stakeholders (employees, subcontractors, etc) engaged in providing services to Accion Labs, hereafter “Supplier”.

The Board of Directors of Accion has adopted this Global Code of Conduct policy as a testimony of their commitment to adhere to the standards of honesty, integrity, ethics, loyalty and to avoid any kind of conflicts of interest.

The rules and principles set forth in this policy are general in nature and compliance with the code shall be in conjunction with the applicable laws and regulations of the land where the company operates.

Ethics and Compliance

The policy at Accion Group is to comply strictly with all the laws governing its operations and to conduct its affairs keeping in view the highest moral, ethical, and legal standards. Supplier shall respect and obey the laws of the jurisdictions in which they operate and comply with all applicable laws and regulations. Supplier is expected to be aware of all relevant laws and regulations involving their responsibilities and refrain from any illegal or unethical practice. When in doubt, the Supplier should consult Accion Labs or legal counsel as appropriate.

• Anti bribery / Anti-Corruption Laws

Supplier shall not make, authorize, or offer any bribes, kickbacks, or payments of money or anything of value to anyone including Government Officials or to any other third party (public or private sector) for the purpose of obtaining or retaining business or influencing any other favorable business decision, that is related in any way to the Company. ‘Government Officials’ include employees of government organizations, public sector undertakings, departments, institutions, and officials. Supplier must be accurate in all invoices as per the terms in the contract with the Company and not make false or misleading entries on invoices or claims submitted for payment. Supplier is required to comply with the U.S. Foreign Corrupt Practices Act and all other foreign anti-bribery laws including but not limited to the UK Bribery Act 2010.

• Anti Money Laundering Laws

Supplier will comply with all applicable anti-money laundering (AML) and counterterrorism financing laws and will only accept funds received from reputable clients and third parties engaged in legitimate business activities with funds derived from legitimate sources. Supplier will not conduct business with individuals or entities on applicable “specially designated nationals”, “designated persons” or “blocked persons” lists. Supplier shall implement appropriate procedures, processes, and internal controls to ensure compliance with applicable AML laws.

• Anti-trust and competition Laws

Supplier’s stakeholders shall not take undue advantage of anyone through manipulation, misrepresentation, or abuse of privileged information. Because Antitrust and competition laws protect consumers and competitors against unfair business practices and promote healthy and fair competition, all suppliers of the Company are expected to follow and comply with the anti-trust and competition laws of all nations.

• Conflict of Interest

Supplier will avoid even the appearance of conflicts of interest in their work with us and will immediately disclose any known family or other close personal relationships with our employees who have an influence over their engagements with us. This also includes situations where an employee of the Company may have an interest of any kind in the supplier’s business whether through personal relationships, investments, directorships, or any kind of economic ties with the Supplier.

• Confidential Information, Data Privacy and Intellectual Property

Supplier must protect the intangible and tangible assets of the Company and its business partners entrusted to Supplier in the course of Supplier’s work with the Company such as confidential information, personal information protected by data privacy laws, and intellectual property (“Confidential Information”). Unauthorized release or use of Confidential Information can cause a loss of competitive advantage or create other financial and legal exposures. If personally identifiable information protected by data privacy laws is related to Supplier’s work with the Company, Supplier must comply with the data privacy laws and the Company’s policies and special handling requirements. Intellectual property rights, such as code, processes, procedures, copyrighted works, ideas, trade secrets, patents, and know-how are core to the Company and its business partners’ business. Supplier must not misuse or fail to secure the needed IP ownership rights for the Company and its business partners. Supplier must respect the intellectual property rights of third parties.

• Use of Company Resources

In the event a Supplier or its stakeholder has access to or utilizes Company resources, including time, material, equipment, and information, the Supplier understands that it is provided for legitimate business use only. In order to protect the interests of the Company's network, the Company's reserves the right to monitor or review all data and information contained on the company-issued computer or electronic device, the use of the Internet, or the Company's intranet. We will not tolerate the use of company resources to create, access, store, print, solicit or send any materials that are harassing, threatening, abusive, sexually explicit or otherwise offensive or inappropriate.

Labor Practices and Human Rights

• Employment Laws

The policy of the company is to provide equal opportunities to all employees without any bias to their race, region, caste, religion, color, ancestry, marital status, gender, sexual orientation, age, nationality ethnic origin or disability. The company strives to eliminate overt and covert bias in recruiting, promoting and separating male and female employees. The company strives to hire people on the basis of their qualifications, experience, expertise and skills, and is determined to provide a work environment free from any form of unlawful discrimination.

• Wages

Supplier is expected to comply with all applicable wage and hour laws and regulations. Wage compliance includes, without limitation, the timely and accurate payment of all legally-mandated wages and benefits, minimum wage laws, wage deductions, and paystub requirements, each as applicable to Supplier’s operations. All legally mandated benefits like vacation time, social security, insurance etc. shall be provided by the Supplier to its employees. Supplier is expected not to deduct from wages as a disciplinary measure.

• Working Hours

Supplier shall comply with prevailing applicable laws and regulations on working hours and minimum wages, overtime and maximum hours. Supplier shall carry out its business in a manner that limits overtime to a level that ensures humane and productive working conditions.

• Harassment

Supplier is expected to provide an environment where everyone is treated with dignity and respect. Creating such an environment brings out the full potential in each of us, which, in turn, contributes directly to business success. Supplier is expected to provide a workplace that is free of discrimination of all types and from any kind of abusive, offensive or harassing behavior.

• Whistleblower protection

Supplier shall encourage its personnel and agents to bring their concerns regarding compliance with this Supplier Code of Conduct to our attention so that issues can be prevented or resolved in a timely manner. Supplier is responsible for creating a safe and confidential environment and legally compliant method for such reports and a policy to not retaliate against those who make reports.

• Prohibition of Child Labor

The Supplier will not use child labor. “Child” means any person under age 15, under the age for completing compulsory education, or under the minimum age for employment in the country, whichever is greatest. Supplier may provide legitimate workplace apprenticeship programs for educational benefit that are consistent with Article 6 of ILO Minimum Age Convention No. 138 or light work consistent with Article 7 of ILO Minimum Age Convention No. 138.

Environment, Health and Safety

The Company is firmly committed to a policy enabling all work activities to be carried out safely, and with all possible measures taken to remove (or at least reduce) risks to the health, safety and welfare of workers, contractors, authorized visitors, and anyone else who may be affected by our operations.

• Drugs, Alcohol, Smoking and Weapons Abuse

Accion maintains an abuse free workplace. To meet our responsibilities to employees, customers and other stakeholders, the Company must maintain a healthy and productive work environment. Substance abuse, or selling, manufacturing, distributing, possessing, using or being under the influence of illegal drugs and alcohol while at work is absolutely prohibited. The possession and/or use of weapons/firearms or ammunition on Company premises or while conducting the business of the Company is strictly prohibited. Possession of a weapon can be authorized only for security personnel when this possession is determined necessary to secure the safety and security of Company’s staff and employees.

• Environment and Community

Supplier shall develop, implement, and maintain environmentally responsible business practices to the best of their ability. We urge our Suppliers to adhere to global standards on environmental protection and work towards the following objectives while transparently reporting on their efforts:

• Energy and Emissions: monitor energy consumption, move to renewable sources of energy and reduce GHG emissions

• Water: reduce the consumption of freshwater, reuse and recycle wastewater
• Waste: segregate waste at source and adopt scientific practices in waste disposal and eliminate single use plastic from their operations. Monitor pollution of air, land, water (and noise pollution) and make necessary efforts to eliminate pollution
  
  

Supplier shall ensure its operations are in harmony with community stakeholders and shall not infringe upon land, forest and water rights of the community.

Raising Concerns and Complaints

The The Company believes that its Stakeholders should conduct their affairs in a fair and transparent manner by adopting the highest standards of professionalism, integrity, honesty and ethics. The company has a clearly articulated Whistleblower policy encouraging all parties to report either orally or in writing allegations of known or suspected improper activities. The Company also safeguards and protects employees from any reprisal or victimization for whistleblowing in good faith.

The Company will investigate all reported instances of questionable or unethical behavior. In everywhere improper behavior is found to have occurred, the company will take appropriate action. We will not tolerate retaliation against those who raise genuine ethical concerns in good faith.

Alerting Accion to potential issues will assist in promoting a compliant corporate environment and will protect Accion’s reputation. All stakeholders have an obligation to raise such concerns to whistleblower@accionlabs.com as soon as possible.

Media Inquiries

The Company is a well-known company in our community, and from time to time, employees may be approached by reporters and other members of the media. In order to ensure that we speak with one voice and provide accurate information about the company, we should direct all media inquiries to marketing@accionlabs.com.