Mitratech Supplier Code of Conduct

INTRODUCTION

At Mitratech we believe that sustainable success is built upon a foundation of shared values, ethical conduct, and mutual respect. We are deeply committed to operating our business with the highest standards of integrity, fostering respect for human rights, and advocating environmental care across all our global operations.

Our core values of co-innovation, ownership, agility, creativity, putting people first, confidence, honesty, and transparency are not just aspirations; they are the guiding principles that define our internal culture and extend to every partnership we forge. We are dedicated to delivering exceptional value to our customers, and this commitment is intrinsically linked to the integrity and responsibility demonstrated by our entire supply chain.

Therefore, we expect our suppliers, vendors, contractors, resellers, and their respective employees, agents, and subcontractors (collectively, “Suppliers”) to fully embrace and uphold these fundamental principles. This Supplier Code of Conduct (“Code”) is more than a set of rules; it is a clear articulation of the minimum standards of conduct required for doing business with Mitratech, reflecting our shared responsibility to conduct business ethically and sustainably. Compliance with this Code, in addition to all applicable local, national, and international laws and regulations, is an integral and mandatory part of our agreements with you.

Compliance with Laws and Regulations

Suppliers must comply with all applicable local, national, and international laws, regulations, and industry standards in all jurisdictions where they operate. This includes, but is not limited to, laws related to:

• Labor and employment
• Health and safety
• Environmental protection
• Data privacy and security
• Anti-corruption and anti-bribery
• Import/export controls and trade sanctions
• Competition (antitrust)
• Product safety and quality
• Intellectual Property protection (e.g., copyright, patent, trade secret laws relevant to software)
• Anti-slavery (Mitratech’s anti-slavery policy is available at: https://mitratech.com/mitratech-modern-slavery-statement/)

Confidentiality and Data Security

Suppliers must protect the confidentiality of all proprietary and sensitive information shared by Mitratech. Such information must not be disclosed to any third party without prior written consent from Mitratech.

In addition to the foregoing, Suppliers must also:

• Comply with all confidentiality provisions in their agreements with Mitratech.
• Implement appropriate technical, physical, and administrative safeguards to protect data from unauthorized access, use, disclosure, modification, or destruction.
• Comply with all applicable data privacy and protection laws (e.g., GDPR, CCPA, local data protection laws).
• Protect intellectual property rights, including patents, copyrights, trademarks, and trade secrets related to software.

Ethical Business practices, Bribery, and Corruption

Suppliers must conduct their business with the highest standards of integrity and transparency. This includes, but is not limited to, the following:

• Anti-Bribery and Anti-Corruption: Suppliers shall not engage in, or tolerate, any form of bribery, corruption, extortion, or embezzlement. This includes complying with all applicable anti-corruption laws, such as the U.S. Foreign Corrupt Practices Act (FCPA) and relevant local anti-corruption laws. Offering, giving, receiving, or soliciting any form of bribe or kickback is strictly prohibited. Suppliers must ensure that all business dealings are transparent and accurately recorded.
• Fair Pricing: Suppliers must engage in fair pricing practices and avoid price gouging, especially during times of increased demand or limited supply. Suppliers are expected to provide products and services at prices that reflect fair market value.
• Fair Competition: Suppliers shall conduct business in accordance with applicable antitrust and competition laws.
• Conflicts of Interest: Suppliers must avoid actual or apparent conflicts of interest. Furthermore, Suppliers must avoid any conflicts of interest that may compromise their ability to act in the best interests of Mitratech. Any potential conflicts of interest must be disclosed to Mitratech immediately.
• Accurate Records: Suppliers must maintain accurate books and records that honestly and accurately reflect all transactions.
• Responsible Sourcing: Suppliers should identify and mitigate risks of unethical practices in their own supply chains, such as those related to conflict minerals or forced labor.

Protection and Responsible Use of Mitratech’s Assets

Suppliers must protect Mitratech’s assets and use them responsibly. These assets must be used solely for legitimate business purposes as authorized by Mitratech and in the performance of services under the applicable Agreement. This includes both tangible assets and intangible assets (e.g., proprietary information, intellectual property, software, confidential data, and relationships with Mitratech’s value-chain partners). Misuse, unauthorized use, or damage of Mitratech’s assets is strictly prohibited.

Labor Practices and Human Rights

Mitratech is committed to upholding human rights. Suppliers must treat their employees with dignity and respect and adhere to the following labor practices:

• No Child Labor: Suppliers shall not employ individuals below the legal minimum age for employment in the country where the work is performed, or below the age for completing compulsory education, whichever is higher.
• No Forced Labor: Suppliers shall not use any form of forced, bonded, indentured, compulsory, or trafficked labor. Employees must not be required to surrender government-issued identification, passports, or work permits as a condition of employment.
• Wages and Benefits: Wages paid to employees shall comply with all applicable wage laws, including those relating to minimum wage overtime hours, and legally mandated benefits.
• Working Hours: Working hours shall not exceed the maximum limits set by applicable laws. Employees shall be granted rest days as required by law.
• Non-Discrimination: Suppliers shall not discriminate in hiring, employment practices, or any other terms and conditions of employment on the basis of race, color, religion, gender, sexual orientation, gender identity, national origin, age, disability, veteran status, or any other legally protected characteristic.
• Fair Treatment and Harassment: Suppliers shall treat all employees with respect and dignity. No employee shall be subjected to physical, sexual, psychological, or verbal harassment or abuse.
• Freedom of Association: Suppliers are expected to uphold and respect the rights of workers to freely associate, join unions, and engage in collective bargaining. Suppliers must ensure that their practices are in full compliance with all applicable labor laws and regulations. Any form of interference, intimidation, or retaliation against workers exercising these rights is strictly prohibited. Suppliers are encouraged to foster an environment where open communication and direct engagement between workers and management are supported and respected.

Health and Safety

Suppliers must provide a safe and healthy work environment for all employees to prevent accidents, injuries, and occupational diseases. This includes, but is not limited to:

• Providing appropriate personal protective equipment, if applicable to your industry.
• Implementing proper safety procedures and training.
• Maintaining clean and safe facilities, machinery, and equipment.
• Ensuring emergency preparedness and response procedures are in place.

Environmental Protection

Mitratech believes that protecting the environment is both the right thing to do and a sound business practice. We are committed to reducing our environmental impact and request that employees, clients, and suppliers do the same. We encourage and expect suppliers to adopt environmentally friendly practices, such as using virtual meeting solutions instead of traveling, opting for public transport when accessible, and conserving utilities.

As a company, we believe that through policy adherence and action, we can influence global issues and climate change. Mitratech strives to engage in business practices that reduce our carbon footprint.

Mitratech actively works to combat deforestation through, but not limited by, the methods below, and encourages suppliers to do the same:

• Minimizing the use of paper products, such as printing
• Automatically enrolling new employees in electronic agreement when permissible
• Utilizing e-signature software for internal and external business purposes when available
• Minimizing the usage of single-use dishware by providing reusable dishware in communal  kitchens
• Providing access to recycling, composting, and other sustainable waste options in office locations

Monitoring, Compliance, and Consequences

Mitratech reserves the right to monitor compliance with this Code, including through audits, assessments, and inspections. Suppliers must provide reasonable access during normal business hours, to information and personnel necessary to verify compliance. Suppliers are expected to cooperate fully with any such audits.

Failure to comply with this Code may result in immediate termination of the Supplier’s relationship and agreements with Mitratech, and may lead to other legal actions.

Reporting Non-Compliance

• Suppliers are encouraged to report any actual or suspected violations of this Code, applicable laws, or ethical concerns related to their engagement with Mitratech.
• Reports can be made to Mitratech via email to [email protected]
• Mitratech will treat all reports seriously and confidentially, and will not tolerate retaliation against any individual who makes a report in good faith.

Code Acknowledgement

By entering into or continuing a business relationship with Mitratech, Suppliers acknowledge and agree to comply with this Code.