Last reviewed & updated: June 30, 2022

EXA Infrastructure Supplier Code of Conduct

1. Introduction

EXA Infrastructure operates a global business. This EXA Infrastructure Supplier Code of Conduct specifies requirements applicable to our suppliers and other third party conducting business with or on behalf of EXA Infrastructure in the areas of compliance with laws, human rights, safe working conditions, business integrity, environment and secure supply chains. 

2. Compliance with Laws

Suppliers must obey all international, country and local laws, rules, and regulations in the countries where they operate.

3. Non- Discrimination and Anti-Harassment 

Suppliers must not engage in any form of unlawful discrimination based upon sex, race, color, ethnicity, national origin, age, disability, religion, or any other basis protected by law. In addition, Suppliers must maintain a workplace environment free from unlawful harassment.

4. Health, Safety and Human Rights

Suppliers must provide a safe and health work environment.  Suppliers must also respect and support the protection of human rights.

5. Corporate Opportunities

Suppliers must undertake the following measures to maintain the security of our networks and the protection of our records, data and information:

• Screening of your personnel performing services for EXA Infrastructure to ascertain such person’s trustworthiness;
• Notifying EXA Infrastructure within 72 hours of discovering any breach or loss of EXA Infrastructure records, data, or information in your possession; and
• Providing certain identifying information to EXA Infrastructure, upon request, regarding any persons who may have access to our communications infrastructure or our data, records, or information.

The above measures are incorporated as mandatory requirements in our agreements with our commercial partners and third-party service providers.

6. Anti-Corruption, Anti-Bribery and Gifts

Suppliers must comply with all applicable anti-corruption and anti- bribery laws. Suppliers shall not offer or provide EXA Infrastructure employees gifts or kickbacks to obtain favorable treatment from EXA Infrastructure.

7. Sanctioned Countries and Trade Controls

Suppliers must comply with all applicable laws and regulations relating to sanctions and export and trade control laws. Supplier must not take any action which may cause EXA Infrastructure to breach sanctions and/or trade control laws.

8. Environment

Suppliers shall perform in an environmentally responsible manner and comply with applicable environment laws and regulations.

9. Reporting Illegal or Unethical Behavior

EXA Infrastructure maintains an Ethics and Compliance Helpline and website (“Helpline”) which are monitored by the EXA Infrastructure Human Resources department. Suppliers may anonymously report violations or suspected violations of this Code by contacting the Helpline at www.safecall.co.uk/report.

10. Enforcement

EXA Infrastructure takes compliance with this Code very seriously. EXA Infrastructure shall determine appropriate actions to be taken in the event of violations of this Code, including possible termination of the Supplier’s business relationship with EXA Infrastructure.