Supplier Code of Conduct

Omio's Supplier Code of Conduct

Version 1 | Date: 01.02.2024

Omio strives to achieve high ethical standards in its own business and in its cooperation with its business partners. We want to operate throughout the world in an ethical, legally-compliant and professional manner. This Code of Conduct is applicable to Omio Corp. and all companies affiliated with it (“Omio”).

This Code of Conduct states the general principles which shall be complied with by all Omio suppliers and partners (“Suppliers”) so that we ensure that we all work to the same standards.

Business standards

The Supplier must comply with all applicable laws, rules and regulations and its business should be carried out in an ethical, transparent, responsible and respectful manner and in compliance with the highest standards of ethical conduct. The Supplier, including all its officers, directors and employees, should adhere to industry best practice standards for conducting business and operate under a formal or informal code of business standards or a similar policy.

The Supplier must not make any false representations or provide false information or data to Omio or in connection with any transaction or work involving Omio, and shall adhere to the fair competition rules.

Human rights, slavery and human trafficking

The Supplier should adhere to recognising, respecting and protecting the human rights of its employees, those of its own suppliers and business partners and the communities affected by its business. The Supplier must comply with all applicable anti-slavery and human trafficking laws. The Supplier must take steps to ensure that its business operations are free from slavery and human trafficking practices, both internally and within its supply chains and other external business relationships.

Employees

Working hours for the Supplier’s employees should not be excessive and must comply with relevant national laws. Wages and benefits should meet or exceed minimum national standards.

The Supplier must seek to eliminate discrimination in access to employment, training and working conditions, on grounds of race, colour, sex, age, religion, political opinion, national extraction, sexual orientation, disability or social origin and to promote equality of opportunity and treatment.

Suppliers must ensure that they do not make use of or profit from any type of child or forced labour. All national legislation and international agreements that specify a minimum age for employees must be complied with.

Preventing conflicts of interest

The Supplier should act with integrity and transparency regarding its business. Any direct or indirect close relationship between the Supplier and Omio’s employees, officers and stockholders or any other relation having an impact on the business collaboration must be disclosed to Omio. The conflict of interest shall be disclosed before the start of negotiations or as soon as the conflict becomes known.

Anti-bribery and corruption

The Supplier must comply with all applicable anti-bribery and anti-corruption laws. The Supplier must establish and maintain procedures to prevent:

  • any offer, promise, gift or solicitation of an advantage as an inducement or reward to a person for the improper performance of that person’s position or as an attempt to influence a person in that person’s capacity as a public official; and
  • participation in any other form of corrupt practice (such as theft, fraud, blackmail, participation in a criminal organisation and money laundering) under any circumstances.

Health and safety

The Supplier must comply with applicable local and national laws and regulations relating to health and safety in all its countries of operation.

A healthy and safe working environment should be provided by the Supplier for all employees and office visitors in accordance with applicable international standards and national laws. Necessary precautions should be taken to prevent accidents and injury to health arising out of, associated with, or occurring in the course of the Supplier’s business activities.

Adequate policies and procedures relating to health and safety should be in place, which are either provided to, or accessible by, employees. The Supplier should ensure that appropriate training on health and safety is provided to its employees.

Sanctions compliance

The Supplier shall comply with all the sanctions laws and regulations applicable to its business.

The Supplier shall not enter into contracts with entities or individuals included from time to time in the lists of sanctions published by the European Union, the United Kingdom and the United States of America.

For the purpose of this clause ‘sanctions’ shall refer to all economic, trade and financial sanctions laws, regulations, embargoes or restrictive measures of any of the countries mentioned above.

The Supplier shall keep Omio informed at all times of all relevant information on: (i) any changes in circumstances relevant to compliance with sanctions; (ii) actual or potential breaches of Supplier’s obligations in relation to sanctions.

Security and personal information

The Supplier must implement and maintain security safeguards, including administrative, physical and technical safeguards designed to protect its information systems from unauthorised access, and shall promptly inform Omio if it believes its systems have been compromised in a manner that could result in any damage to Omio.

The Supplier must commit to protecting the personal information of its clients, suppliers and employees. The Supplier must comply with all applicable privacy and information security laws and regulatory requirements when personal information is collected, stored, processed, transmitted or shared.

In the event of a data breach on the side of the Supplier, including events of destruction, loss, change or unauthorised disclosure of personal data, which affect Omio, the Supplier shall inform Omio immediately upon becoming aware of the data breach and comply with the actions which it is required to take under the applicable data protection legislation.

Confidentiality

The Supplier must ensure that confidential information and trade secrets obtained by it in the course of its business activities with Omio are treated in strict confidentiality.

The confidential information should only be disclosed to the Supplier’s employees on a need-to-know basis. The confidential information may only be disclosed to third parties, to the extent that this is expressly provided in a confidentiality agreement entered into between Omio and the Supplier. Any of the Supplier’s employees or third parties receiving confidential information from the Supplier should be party to confidentiality agreements or be otherwise bound by confidentiality obligations substantially similar those between the Supplier and Omio.

Intellectual Property

The Supplier is obliged to protect Omio’s intellectual property rights and not to use them for any purposes other than as authorised by Omio under its contracts with the Supplier.

Environmental

The Supplier shall comply with all applicable local and national laws and regulations relating to the protection of the environment. Any negative impact on the environment caused by the Supplier’s business activities should be continuously reduced, including aiming to reduce the consumption of water, energy (gas, electricity and solid fuels) and other manufacturing and/or office materials and, where possible, encouraging recycling and the use of recycled materials.

Compliance

Omio reserves the right to request information and documents to check the Supplier’s compliance with the Code of Conduct. If Omio reasonably believes that the Supplier does not comply in full with this Code of Conduct, it shall work with the Supplier to agree on a corrective action plan with a reasonable timeline that will enable the Supplier to achieve full compliance. If the Supplier has given incorrect information or cannot implement the required improvements, we reserve the right to terminate our business relationship under the terms of the contract between the parties.

Should the Supplier, its officers, directors or employees be in breach of the laws, rules or regulation where such breach can influence Omio’s brand or reputation, or can entail additional legal obligations for Omio, the Supplier shall promptly notify Omio of such breach, and the parties will work together on a mutually acceptable course of action. In such cases Omio also reserves the right to terminate our business relationship under the terms of the contract between the parties.

The Supplier is solely responsible for any expenses incurred for complying with this Code of Conduct.

This Code of Conduct is published on Omio website and applies to the Suppliers dealing with Omio.

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