SUPPLIER CODE OF CONDUCT

Introduction

At Oxylabs (coretech lt, UAB), we are committed to environmental, social, and governance (ESG) practices. We conduct our business ethically and expect our suppliers to do the same. The purpose of this Code of Conduct is to set forth our expectations for all suppliers associated with Oxylabs and its affiliates. This includes vendors, service providers, consultants, partners, and any other entities involved in business with Oxylabs ("the Suppliers” or “the Supplier").

Oxylabs believes in a proactive approach to ethical conduct. Thus, we encourage all our Suppliers to not only comply with applicable laws, good business practices, and this Code of Conduct but also strive to exceed these standards whenever possible.

1. Labor conditions and human rights

At Oxylabs, we are committed to creating and sustaining an environment that respects and actively upholds human rights and labor ethics. This commitment is deeply embedded in our core values and operational principles, aligning with international standards such as the United Nations Guiding Principles on Business and Human Rights, the United Nations Global Compact, and the Universal Declaration of Human Rights.

We require all Suppliers to respect human rights by avoiding and remedying any harm to human rights. This includes a commitment to non-discrimination in hiring and employment practices, ensuring that no discrimination occurs based on nationality, gender, age, religion, or any other status. 

The Supplier may not engage in or permit any employment practices that involve forced labor, debt bondage, or any form of involuntary labor. All work should be conducted on a voluntary basis, and employees must have the autonomy to terminate their employment at any point, according to their own discretion.

The Supplier shall follow all applicable laws and regulations regarding child labor. The Supplier is strictly prohibited from the use of child labor in both their direct operations and their extended activities and is actively committed to the complete elimination of child labor practices.

The Supplier shall compensate its employees with wages that are fair and in line with prevailing market standards, adhering to national laws and practices. Supplier also upholds the freedom of association and the effective recognition of the right to collective bargaining. This includes providing channels for individuals to communicate openly with management without fear of retaliation, intimidation, or harassment.

2. Diversity, Equity, and Inclusivity​​ 

Oxylabs values the integration of diverse perspectives into our operations, which we believe is crucial for our success. The Supplier is expected to incorporate diversity into their supply chain management and recruitment practices, ensuring fair and equitable treatment in the Supplier selection process.

Furthermore, a cooperative work environment is fundamental, demanding that all employees are treated with dignity and respect. The Supplier must strictly prohibit any form of harassment or bullying. Specifically, any conduct that includes offensive gestures, language, or physical contact of a sexual, coercive, threatening, abusive, or exploitative nature must not be tolerated.

3. Health and Safety

The Supplier shall ensure a safe and healthy workplace in line with all relevant laws and regulations. The Supplier must effectively manage risks, providing detailed safety instructions tailored to its specific operations and ensuring employee compliance. Emergency preparedness plans, comprehensive training on emergency procedures, and suitable safety and sanitary facilities are essential. The Supplier is also required to establish protocols for accident prevention and management, fostering an environment where employees can report incidents without hesitation and receive necessary medical care and support for their return to work. These comprehensive health and safety standards reflect Oxylab's commitment to ensuring the welfare of all individuals within its supply chain.

4. Anti-corruption, anti-competitive behavior, and conflicts of interest

Oxylabs is dedicated to maintaining the highest standards of integrity and ethics in all our business dealings. This commitment extends to our Suppliers, who are crucial partners in our mission. Our Supplier must rigorously avoid any form of corruption and bribery. This includes the prohibition of offering, giving, authorizing, or accepting bribes, gifts, loans, or any other advantages that could influence decision-making or gain improper advantage. Any form of representative gift or entertainment offered to Oxylabs employees must not exceed EUR 100 in value.

The Supplier must refrain from engaging in anti-competitive behavior with the purpose of limiting the effects of market competition.

Transparency is key. Supplier is expected to disclose any potential conflicts of interest immediately, including personal relationships with Oxylabs employees. Moreover, any suspicion of corrupt practices within the supply chain should be reported to Oxylabs without delay.

5. Anti-money Laundering. Economic Sanctions

Our Code of Conduct mandates that no Supplier should provide services or engage in arrangements that could directly or indirectly contribute to money laundering or support illicit activities such as terrorism, tax evasion, or fraud. Furthermore, the Supplier is required to comply with all relevant economic sanctions and export control laws and regulations. Any actions that could potentially lead to violations of these laws by either the Supplier or Oxylabs are strictly prohibited. 

6. Information Security, Data Protection and Intellectual Property Rights

The Supplier must protect personal data and confidential information against unauthorized use, disclosure, or loss, complying with applicable laws. They should implement administrative, physical, and technical safeguards in line with industry standards and ensure that personal data or confidential information is not used beyond the scope of the services provided.

The Supplier is required to respect intellectual property rights, ensure the lawful transfer of technology and know-how, and prevent the use of unlicensed copyrighted materials.

7. ESG Responsibility

Oxylabs encourages its Suppliers to actively engage in ESG practices. This involves regularly assessing and minimizing the negative ESG impacts of their activities. Supplier is expected to establish and pursue continuous improvement in its ESG performance, aligning with Oxylabs's commitment to sustainability.

The Supplier should have an effective environmental management system in place, including goals to reduce environmental impact, measures, controls, audits, reporting mechanisms, and employee training programs. This system should encompass chemical and waste management, recycling, wastewater treatment, air emissions control, and other relevant environmental aspects.

The Supplier is encouraged to contribute to the circular economy goals. This includes responsible development, production, supply of goods, and provision of services, emphasizing recycling and efficient use of resources. The Supplier should strive for energy efficiency, including the use of renewable energy sources in its operations, and aim to reduce the use of hazardous chemicals.

Procedures must be implemented to reduce or eradicate the emission of greenhouse gas, as well as to prevent contamination and waste during production and transportation processes. Environmental concerns at local, regional, and global levels should be duly considered and addressed.

The Supplier is expected to work towards reducing or eliminating waste in all forms. This includes managing and controlling waste streams in compliance with laws and regulations and in an environmentally sound manner. Efforts should be made to prevent pollution and manage wastewater, solid waste, and stormwater in a way that minimizes environmental impact.

Oxylabs expects its Supplier to commit to responsible sourcing of materials, particularly those likely to originate from high-risk areas for human rights violations or environmental degradation. The Supplier must exercise due diligence in its sourcing practices.

Our commitment to sustainability is paramount. Our Supplier is expected to engage collaboratively and with transparency on sustainability initiatives. This includes the obligation to disclose climate-related or other ESG data when requested, ensuring that our shared goals for a sustainable future are pursued with openness and accountability.

8. Trust, Cooperation, and Compliance

Oxylabs acknowledges that rectifying certain non-compliance issues can be complex and time-consuming, often due to contributing factors from the wider community. Oxylabs is committed to a collaborative approach and is ready to work alongside Suppliers, regulatory bodies, labor unions, and industry groups to develop tailored solutions for each specific scenario. 

We encourage any Supplier experiencing difficulties in complying with the Code of Conduct to communicate proactively through our designated communication channel, “Speak Up,” on the oxylabs.io website or directly with the direct contact person at Oxylabs. Openness and honesty are essential in upholding the integrity of our operations and relationships. Our collective endeavor is to foster a business environment that embodies our fundamental values and contributes to our shared aspiration for excellence.

Oxylabs asserts its right to confirm Suppliers' compliance through discussions, both internal and external evaluations, and thorough due diligence. Supplier is required to furnish information that is complete, accurate, and provided within a timely manner upon request. Should non-compliance be identified, a remediation plan may be necessitated.

Any Supplier found in violation of the Code of Conduct that, upon reasonable notice, fails to take corrective action, Oxylabs reserves the right to either suspend or terminate our relationship with any Supplier immediately, based on the severity and frequency of the violations.