Supplier Code

IMAGINEASIUM SUPPLIER CODE

Last updated: November 20, 2023

ImagineAsium Supplier Code of Conduct and Ethics

At ImagineAsium and its affiliated companies, we recognize that we must conduct business in an ethical manner, respect internationally recognized human rights, and never tolerate or be complicit in any human rights abuses. We expect all our vendors and contractors who provide any goods, services, products, materials or other elements to or for ImagineAsium (“Suppliers”) to adhere to this standard as well and we rely upon our Suppliers to never participate in and to work to eradicate the use of unethical labor practices in their supply chains. While we recognize that our Suppliers may establish standards on an individual basis, we choose to do business with Suppliers who adhere to the basic principles and ideals outlined in this Supplier Code of Conduct (the “Code”).

This Code outlines the minimum standards for ImagineAsium Suppliers. As ImagineAsium’s corporate responsibility and supply chain management evolves, we anticipate further engagement with our Suppliers so that we can expand our commitment to ethical business practices working together. Suppliers are expected to have appropriate management systems in place and take necessary steps to comply with this Code, including transparency concerning policies and practices and related employee education. As part of this Code, we encourage our Suppliers to similarly hold their suppliers accountable to these standards.

COMPLIANCE

Suppliers must follow all relevant international and local laws, regulations and conventions, including those related to labor, health and safety, and the protection of the environment. Suppliers are expected to inform ImagineAsium should there be any significant breaches, allegations of non-compliance or investigation into noncompliance by authorities related to any goods or services that such Supplier provides to ImagineAsium that may affect a Supplier’s ability to provide goods or services to ImagineAsium in a manner consistent with this Code.

HUMAN RIGHTS AND LABOR

ImagineAsium supports and respects fundamental human rights. Suppliers should recognize and be committed to upholding the human rights of workers, and to treat them with fairness, dignity and respect. This includes the following minimum standards:

Forced, bonded or indentured labor, prison labor or modern slavery is not to be used in any of its forms. All work will be voluntary, and workers should be free to leave the office, without retaliation, at the end of their workday or when they have reasonable justifications, and to terminate their employment upon reasonable notice. Workers should not be required to relinquish control of government-issued identification, passports or work permits, nor deposit a bond, as a condition of employment.

Child labor is not to be used in any stage of the work performed for ImagineAsium or in relation with ImagineAsium products or services. If the minimum employment age in a country is not defined, the term “child” shall refer to any person under the age of 15 or under the age for completing compulsory education in that country, whichever is higher. Suppliers should not employ any person under the age of 18 for hazardous labor likely to harm their health or safety.

Suppliers shall ensure equality of opportunity and fair treatment of their workers and protect them against all sorts of discriminatory actions. Suppliers may be subject to additional national and local labor and fair employment laws and accompanying regulations. To assure full compliance with these laws and regulations, all personnel actions, including recruiting, hiring, assignment and promotion, as well as decisions affecting compensation, benefits, transfers, and training, must be made without regard to creed, race, origin, color, age, gender, sexual orientation, ethnicity, mental or physical disability, religion, political affiliation, health condition, pregnancy, union membership, marital status, or any other status protected by law.

Suppliers should maintain a safe and inclusive environment where employees are treated with dignity and respect. There is to be no actual or threatened harsh or inhumane treatment, including any sexual harassment, sexual abuse, corporal punishment, violence, mental or physical abuse or coercion of workers. Suppliers may never take or tolerate any actions which contribute toward human exploitation, including human trafficking and sexual exploitation of children.

Compensation paid to workers must comply with all applicable local wage laws and collective agreements, including those relating to minimum wages, overtime hours, rest breaks and legally mandated benefits. If there is no minimum wage in a country, Suppliers should ensure that their workers receive a compensation at least equivalent to industry standards and sufficient to cover their basic living requirements. Working hours and work weeks are not to exceed the maximum set by local law, collective agreements and industry standards. Deductions from wages as retaliatory or disciplinary measures cannot be accepted.

Open communication and direct engagement between workers and management are the most effective ways to resolve workplace and compensation issues. Suppliers will respect the rights of workers to associate freely, including the right to join a labor union or similar organization, and to bargain collectively and communicate openly with management regarding working conditions, without fear of reprisal, intimidation or harassment.

HEALTH AND SAFETY

Suppliers are responsible for upholding a safe and healthy work environment. Suppliers must comply with all laws, regulations and rules governing employee occupational health and safety in the jurisdiction where they operate. Suppliers must have procedures and systems in place to prevent, manage, track and report occupational injury and illness, including provisions to: i) encourage employee reporting; ii) classify and record injury and illness cases; iii) provide necessary medical treatment; iv) investigate cases and implement corrective actions to eliminate their causes; and v) facilitate the return of employees to work. Employees should receive training on safety, including, where appropriate, proper use of equipment, chemicals, and use of personal protective equipment.

ENVIRONMENT

ImagineAsium is committed to minimizing the impact of its operations, and those of its Suppliers, on the environment.

Suppliers must undertake ongoing efforts to improve in minimizing environmental impact of their operations, products, and services. Examples of considerations include reducing energy and water consumption, reducing greenhouse gas emissions, reducing waste and pollution, reducing impact on biodiversity and ecosystems, reducing environmental impact of products during various lifecycle stages as applicable and opting for environmentally friendly technologies.

Suppliers must obtain, maintain and keep current all required environmental permits and registrations and follow the operational and reporting requirements of such permits.

Suppliers are to adhere to applicable laws and regulations regarding prohibition or restriction of specific substances including labeling laws and regulations for recycling and disposal, including for chemicals and air emissions.

Waste of all types, including water, energy, raw materials, and processed materials, is to be reduced or eliminated at the source or by practices such as modifying production, maintenance and facility processes, materials substitution, conservation, recycling and re-using materials. Any wastewater or solid waste that is generated from Suppliers’ operations is to be characterized, monitored, controlled and treated as required prior to discharge or disposal according to applicable standards and codes.

ETHICS

ImagineAsium’s Employee Guide requires that ImagineAsium’s business be conducted with honesty and integrity, and in compliance with all applicable laws. As such, we expect ImagineAsium Suppliers and their agents to similarly maintain the highest standards of moral conduct, ethics and integrity in all business interactions.

Any and all forms of corruption, extortion, bribery, influence peddling, offering or accepting any kickbacks, embezzlement and money laundering are strictly prohibited and may result in immediate termination of the relationship with ImagineAsium and legal action.

Bribes, kickbacks, individual incentives or other means of obtaining undue or improper advantage may never be offered or accepted. Suppliers should observe local laws and custom with respect to gifts, and the value of such offers should never be considered material enough to influence business decisions or contravene applicable regulations.

Financial records shall be kept in accordance with all applicable accounting practices and comply with all relevant legal and regulatory requirements.

Suppliers are expected to comply with applicable laws relating to conflicts of interest and to disclose to ImagineAsium any situation that may appear as a conflict of interest, for instance where a ImagineAsium employee have an interest of any kind in the Supplier’s business or has economic or personal ties with the Supplier.

ImagineAsium is dedicated to the well-being of the communities in which we do business, as evidenced through charitable giving and various forms of community involvement. Suppliers are encouraged to engage with their communities to help foster social and economic development and sustainability.

Suppliers shall ensure that their workers can report concerns, unethical or unlawful practices, or any violations of this Code, without fear of retaliation or disciplinary action.

CONFIDENTIALITY, DATA PRIVACY AND CYBERSECURITY

Suppliers must implement processes to effectively safeguard all of ImagineAsium’s confidential, sensitive, and proprietary and customer information and intellectual property regarding its business activities, financial terms and conditions, performance, and/or any other information deemed confidential, and such information shall be disclosed only in accordance with the guidelines specified within any confidentiality provisions or nondisclosure agreement with ImagineAsium.

We expect Suppliers to respect the privacy of their workers, customers and business partners. Suppliers should commit to process personal data in compliance with the applicable laws and regulations and implement appropriate measures to ensure the integrity and security of their systems.

COMPETITION, TRADE AND CONSUMER PROTECTION

Suppliers should conduct their business in full compliance with competition and consumer laws. Suppliers should deal with business partners and customers in a fair manner and should ensure that they never engage in anticompetitive or unfair trading practices. Suppliers must commit to provide clear, transparent and accurate information to their customers and to refrain from making any misleading or otherwise unauthorized claims. We also require Suppliers to comply with all applicable laws and regulations relating to product safety, customs and import and export controls and to respect trade restrictions that may be imposed by national or international rules or conventions.

COMPLIANCE WITH THIS SUPPLIER CODE

Our relationship with our Suppliers is based on mutual trust and respect. Suppliers may also demonstrate their commitment to the principles outlined in this Code through compliance with their own code of conduct or company policies that embrace these standards.

Due to the importance of our Suppliers remaining in alignment with this Code, ImagineAsium may ask a Supplier to verify compliance with this Code by any of the following methods and to take corrective action if there is a reason for concern:

Self-Assessments: We may ask a Supplier to fill in a questionnaire on compliance with this Code.
Certifications/Statements: We may ask a Supplier for a certification or statement confirming compliance with this Code.
On-Site Audits: We or an authorized third party acting on our behalf may contact our Suppliers and ask for permission to verify compliance with this Code on site.

ImagineAsium reserves the right to amend or modify this Code at any time and to publish the updated version of this Code on its website.

Without limiting any other agreement ImagineAsium may have with its Suppliers, but notwithstanding anything to the contrary in those agreements, ImagineAsium may, in compliance with the applicable law, terminate its relationship with any Supplier found to be in material violation of this Code.

For further information or to report any violation of this Code, please contact ImagineAsium Legal at contact@ImagineAsium.com.