Environmental, Social and Governance (ESG) Code of Conduct for a Supplier

1. Introduction

Happytel Retail Group Pty Ltd (the “Company”) has adopted this ESG Code of Conduct (Code) in relation to its Suppliers. In this Code, a “Supplier” is any business or other entity that agrees to or does supply any goods or services to the Company.

By adopting this Code, the Company demonstrates its commitment to, and compliance with, its ESG Strategy.

The Company may periodically review and update this ESG Policy as it deems necessary.

 

2. Suppliers’ Commitment

This Code sets out the minimum standards that must be met by the Company’s Suppliers. Each Supplier is required (as far as is reasonably practicable commensurate with its size) to:

1. (a) comply with this Code;
2. (b) adopt and implement policies, standards and processes consistent with the Company’s ESG Policy (as set out under sections 4, 5 and 6); and
3. (c) have systems in place to ensure compliance and to demonstrate that it is compliant.
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3. Environmental principles

Each Supplier will (and as far as is reasonably practicable encourage its supply chain to):

1. (a) operate management procedures to include environmental factors;
2. (b) ensure that the goods it manufactures and the components that it incorporates into its goods comply with all applicable environmental protection laws and regulations;
3. (c) continuously improve environmental performance and integrate recognized environmental best practice into business operations;
4. (d) have in place a suitable environmental management system for identifying and managing environmental risks and hazards;
5. (e) act to reduce the carbon footprint of its business activities;
6. (f) where possible, reduce consumption of resources and improve efficiency of those resources;
7. (g) promote a culture of environmental awareness amongst all employees;
8. (h) provide training for all employees as appropriate to enable them to carry out their job functions in a manner that shows care for the environment;
9. (i) promote the re-use and recycling of materials and minimize waste;
10. (j) manage and dispose of all waste in a responsible manner in ways that show concern for the environment; and
11. (k) use packaging materials that comply with all applicable environmental laws and regulations.
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4. Social principles

Each Supplier will (and as far as is reasonably practicable encourage its supply chain to):

1. (a) comply with all applicable anti-slavery and human trafficking laws and regulations;
2. (b) not infringe any internationally recognized human rights;
3. (c) provide and maintain a working environment free from all forms of discrimination, harassment and bullying;
4. (d) promote diversity and inclusion amongst its workforce;
5. (e) provide fair remuneration and ensure that as a minimum remuneration is sufficient to cover basic living requirements and that working hours do not exceed the maximum permitted by applicable laws and industry standards; and
6. (f) comply with workplace health and safety laws, and take steps to eliminate workplace hazards and work-related accidents and injuries;
7. (g) support local community by employing local people where appropriate and reasonable to do so; and
8. (h) permit employees’ freedom of association, union membership and collective bargaining in accordance with applicable laws, to protect or represent their interests.
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5. Governance principles

Each Supplier will (and as far as is reasonably practicable encourage its supply chain to):

1. (a) ensure that it complies with all applicable local, state and federal laws and regulations, relevant standards and codes of practice (including standards of safety and quality for products and services);
2. (b) ensure that it has clear and effective governance for ESG;
3. (c) promote strong oversight and transparency at all levels of its organization;
4. (d) establish and maintain high standards of business ethics;
5. (e) comply with all applicable data protection laws and maintain appropriate privacy and data security measures to protect the integrity and confidentiality of information held on its systems (including information supplied by the Company); and
6. (f) maintain and implement policies covering, and comply with all applicable laws relating to, conflicts of interest, anti-bribery and corruption.