Supplier Code of Conduct

Introduction

Gini and its products were born from a desire to make people’s lives easier, less complicated, and
happier. In line with this vision, we believe that our success is built on a foundation of strong ethical principles, sustainable practices in all aspects of our business, and long-term collaborations with our suppliers.

Our Commitment

We are committed to promoting sustainable practices throughout our supply chain by working closely with our partners and suppliers. To achieve this, we ensure that all products and services meet our high social, environmental, and ethical standards, contributing to a responsible and future-oriented business approach. In this spirit, we strive to foster collaboration based on integrity, fairness, and transparency.

Purpose and Scope of Application

This Code of Conduct sets out the expectations and requirements that we hold ourselves up to and place on all our business partners, including suppliers, service providers and subcontractors. It reflects our core values and aligns with international standards, laws, and regulations to promote transparency, respect for human rights, and sustainable development. We expect our partners to share these principles and to cascade on these values within their own business activities and supply chains and improve the sector within their sphere of influence.

We ask all our business partners to read this Code carefully and to commit to upholding the standards set out in it. Together, we can achieve a positive and sustainable impact and strengthen the trust of our customers and society.

Thank you for your commitment to partnering with Gini on this shared mission.

Legal Compliance and Relevant Norms and Standards

All business partners of Gini GmbH are expected to comply with applicable local, national and international laws and regulations, supporting to maintain a trusting and sustainable business relationship. Besides regulations, we invite our suppliers to comply with relevant international norms and standards that frame sustainability practices for businesses.

Legal Requirements

Business partners must ensure that they comply with all relevant legal requirements in their business activities. This includes, but is not limited to:

• Employment law: compliance with laws promoting fair labor practices, including adherence to working hours, minimum wages and labor contracts.
• Health and safety regulations: implementation of appropriate measures to ensure the safety and well-being of all employees.
• Environmental regulations: Compliance with laws and regulations that ensure the protection of the environment and the sustainable use of resources.
• Tax regulations: Compliance with all tax obligations through complete and accurate reporting.

Relevant International Norms and Standards

Our initiative is anchored in the frame of the following international standards, with which Gini and its business partners are to comply:

• OECD Guidelines for Multinational Enterprises: These guidelines provide a comprehensive framework for responsible, corporate behavior and cover areas such as human rights, the environment, taxation and fair competitive practices.
• UN Global Compact – The 10 Principles: The principles of the UN Global Compact provide a basis for corporate action in the areas of human rights, labor standards, environmental protection and anti-corruption.
• ILO Convention: Compliance with the fundamental labor standards of the International Labor Organization (ILO) is crucial for fair and safe working conditions.

Labor Practices and Human Rights

As part of the business Gini expects its business partners to create working conditions based on respect, dignity, and freedom from harassment or abuse. Business partners will seek to respect and actively promote human rights principles, which include, but are not limited to:

• Respecting the right to life, security, and liberty
• Protecting freedom of thought, conscience, and religion
• Prohibiting torture and inhumane treatment
• Ensuring fair remuneration, including the prohibition of withheld wages and the assurance of an adequate standard of living
• Guaranteeing safe and fair working conditions, including compliance with working hours, appropriate wages, and legally required social benefits
• Protecting children’s rights and prohibiting child labor
• Preventing forced labor, modern slavery, and human trafficking
• Ensuring freedom of association, assembly, organization, and collective bargaining
• Protecting privacy and family life from arbitrary or unlawful interference
• Prohibiting discrimination and unequal treatment in employment
• Recognizing the right of populations to access and benefit from their country’s natural resources for their livelihood

By upholding these standards, Gini and its partners contribute to fair, ethical, and socially responsible business practices.

Gini is committed to promoting ethical and sustainable sourcing practices and expects the same from its business partners. Suppliers must ensure that all materials and components provided to Gini are sourced responsibly and not obtained from conflict-affected or high-risk areas in a manner that finances or supports armed groups or human rights abuses.

Health and Safety

At Gini, protecting the health and safety of all employees, business partners, and stakeholders is a top priority. We are committed to fostering a culture of safety and well-being across our organization and expect the same from our suppliers, especially those in manufacturing and production industries.

We require our business partners to provide and continuously improve safe and healthy working conditions in line with all applicable laws and regulations on occupational safety. Potential risks must be regularly assessed, and effective preventive measures implemented to minimize the likelihood of accidents and injuries.

Suppliers must also ensure their employees receive appropriate training in health and safety practices to promote a high level of awareness and competence and to avoid incidences. Together, we aim to create a secure and supportive environment that prioritizes the well-being of everyone involved in our value chain.

Environmental Standards

We expect our suppliers, particularly those in manufacturing and production industries, to adopt practices that minimize their environmental impact.

This includes the efficient use of resources, the reduction of waste, and the prevention of pollution throughout their operations. Suppliers are encouraged to continuously improve their environmental performance by implementing innovative and sustainable solutions, reducing greenhouse gas emissions, and responsibly managing energy, water, and raw materials. These expectations are relevant for data centers and electronic suppliers.

Business Ethics

Our business partners are committed to upholding the highest standards of ethical business conduct throughout their operations. Ethical business conduct is critical to building and maintaining trust and integrity in our business relationships. It is our expectation that all business partners respect these values and implement them in their business processes.

To maintain trust and fairness, both parties should avoid situations where personal, financial, or other interests could create a conflict with our business relationship. If such situations arise, they should be disclosed promptly so that they can be addressed transparently and appropriately.
Neither our company nor our business partners should engage in or tolerate bribery, corruption, or any form of unethical advantage. We encourage our partners to implement effective measures to prevent such practices and to provide appropriate training to their employees to ensure compliance with anti-corruption regulations.

Additionally, fair competition is essential to a healthy business environment. We and our business partners commit to complying with all applicable competition and anti-trust laws. Practices such as price fixing, market allocation, or other anti-competitive behaviour should be avoided to ensure fair and respectful interactions with customers, suppliers, competitors, and employees.

Data Protection and Information Security

At Gini, the protection of data and the security of information are of utmost importance. We require our suppliers to strictly adhere to all applicable data protection laws and regulations, including but not limited to the General Data Protection Regulation (GDPR).

Suppliers must implement robust technical and organizational measures to safeguard data from unauthorized access, misuse, or breaches. This includes ensuring the confidentiality, integrity, authenticity and availability of data processed or handled on behalf of Gini or its customers.

Furthermore, suppliers must maintain strong cybersecurity practices, such as regular vulnerability assessments, secure system configurations, and the use of encryption technologies where necessary. Any actual or suspected data breaches must be reported to Gini without delay, along with details of the measures taken to mitigate the impact.

Suppliers are expected to ensure that employees handling sensitive information are adequately trained and aware of the importance of maintaining strict confidentiality and data security standards.

Monitoring and Compliance & Consequences of Non-Compliance

Gini reserves the right to request further documentation to monitor compliance with this Code of Conduct. We expect active cooperation and openness from our business partners to ensure transparent and effective monitoring.
In the event of an identified violation, the business partner agrees to actively and fully cooperate to develop and implement a corrective action plan to remedy the violation as soon as possible. If the Business Partner fails to cooperate in good faith or fails to take reasonable steps to remedy a violation, Gini reserves the right to terminate current business relationships and contracts without penalty.