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Ethics Purchasing Policy

Carbon Revolution Operations Pty Ltd
Business Ethics & Purchasing Policy

Carbon Revolution’s objective is to conduct business in an innovative, fair, ethical and sustainable way, which includes purchasing goods and services from suppliers and ensuring parties forming part of the supply chain strive to uphold and deliver excellence in their performance.

People and the environment are our most important resources and for this reason we set out our minimum expectations towards business ethics, working conditions, human rights, and environmental leadership; for our suppliers as well as their subcontractors and suppliers. We expect that suppliers will uphold these standards and cascade them down their supply chain.

These guidelines are based on fundamental principles of social and environmental responsibility that are compliant with local law and consistent with international expectations. Carbon Revolution employees and suppliers must comply with the following policy requirements.

  1. Product & Plant Integrity
    Suppliers are required to operate under an appropriate Quality Assurance / Control System which ensures that goods or services supplied meet with Carbon Revolution’s requirements and any applicable laws, standards, codes or regulations.

    Suppliers are expected to minimize the risk of introducing counterfeit and/or diverted parts into deliverable products and must not source minerals from countries or regions impacted by conflict (Conflict Minerals). Conflict Minerals include columbite-tantalite (coltan) (i.e. tantalum), cassiterite (i.e. tin), gold, wolframite (i.e. tungsten) or their derivatives.
  2. Bribery, Corruption & Money Laundering
    Suppliers must comply with all applicable laws, regulations, codes and sanctions relating to anti- bribery, anti-corruption and anti-money laundering, in the countries where it and its affiliates operate.

    Suppliers and Carbon Revolution employees shall not offer, give or agree to give or receive any form of inducement (gift, financial or other advantage) to influence decisions or outcomes relating to the purchase goods or services.
  3. Privacy
    Suppliers are expected to put in place appropriate measures to respect Carbon Revolution’s privacy, to protect personal data against loss and unauthorized/unauthorised access or use, and to comply with relevant privacy and information security laws and regulations.
  4. Fair Working Conditions
    Suppliers to Carbon Revolution must comply with the applicable employment laws relating to employment conditions, fairness, anti-discrimination, ethical recruiting, freedom of association and the prohibition of child labour as defined in ILO Convention No. 138 and those requirements set out below:
    • Child Labour - ensure that child labour is not tolerated in any form. The age of employment for young workers must meet or exceed, legal regulations and local labour laws.
    • Human Rights and Working Conditions - respect the human rights of workers, and treat all people with dignity as recognized by the international community.
    • Modern Slavery - prohibit any forms of modern slavery including any forms of forced or compulsory labour and human trafficking.
    • Wages and Benefits - provide compensation and benefits that comply with applicable local laws, including those relating to minimum wages, overtime compensation, and legally mandated benefits.
    • Working Hours - comply with local laws regarding working hours, including overtime.
    • Freedom of Association - allow workers to communicate openly with management regarding working conditions and management practices without fear of reprisal, intimidation or harassment. Companies should respect employee rights to associate freely, to join or not join labour unions, bargain collectively, seek representation, and join workers’ councils in accordance with local laws.
    • Health & Safety - provide workers a safe and healthy working environment that meets or exceeds applicable local laws and industry standards for safety and occupational health.
    • Harassment - provide a work place free of harassment against workers in any form.
    • Non-Discrimination - not tolerate any form of discrimination in respect of employment and occupation and should provide equal employment opportunities regardless of worker or applicant characteristics such as race, colour, age, gender, sexual orientation, gender identity, ethnicity or national origin, disability, pregnancy, religion, political affiliation, union association, covered veteran status, genetic information or marital status.
  5. Financial Responsibility
    All business dealings are expected to be transparently performed and accurately reflected on the supplier’s financial reports and filings. Suppliers are expected to disclose financial and non- financial information in accordance with laws and regulations applicable to their country.
  6. Fair Competition/Anti-Trust
    Suppliers are expected to operate honestly and ethically, uphold standards of fair business and:
    • conduct business in a manner that avoids any appearance of impropriety; and
    • comply with all laws relating to anti-trust and anti-competitive business practices.
  7. Intellectual Property
    Suppliers are expected to respect Carbon Revolution’s intellectual property rights and use commercially reasonable practices to protect the transfer of confidential technology and know-how.
  8. Export Controls and Economic Sanctions
    Suppliers are expected to comply with applicable restrictions on the export or re-export of goods, software, services and technology, as well as with applicable restrictions on trade involving certain countries, regions, companies or entities and individuals.
  9. Environment
    Suppliers are expected to support a proactive approach to environmental responsibility by protecting the environment, conserving natural resources and reducing the environmental footprint of their production, products and services throughout their life-cycle. A comprehensive approach includes but is not limited to:
    • Energy Consumption & Greenhouse Gas Emissions - implementing a comprehensive energy reduction strategy and management program while increasing use of renewable energy.
    • Water Quality & Consumption - effectively reduce, reuse, and recycle water with responsible treatment of wastewater discharges to protect the environment and improve overall water quality.
    • Air Quality - routinely monitor, appropriately control, minimize/minimise, and to the extent possible, eliminate emissions contributing to local air pollution.
    • Natural Resources Management and Waste Reduction - encourage and support the use of sustainable, renewable natural resources while reducing waste and increasing reuse and recycling.
    • Responsible Chemical Management - identify, minimize or eliminate the use of restricted substances in manufacturing processes and finished products to ensure regulatory compliance. Suppliers should also be aware of any use of reportable substances in processes and finished products, and actively investigate suitable substitutes.
  10. Whistleblower Protection of Identity
    Suppliers are expected to establish processes that allow concerns to be raised anonymously with confidentiality and without retaliation.
  11. Reporting & Compliance
    Suppliers are expected to notify Carbon Revolution of any beaches or suspected breaches as soon as possible. Any such notifications will be treated as strictly confidential. Carbon Revolution reserves the right to require that suppliers demonstrate compliance with this policy and to audit suppliers to verify compliance with this policy.

 

Jake Dingle
CEO
Carbon Revolutions Operations Pty Ltd

 

Copyright 2020. Carbon Revolution. All rights reserved. Carbon Revolution Ltd. is a company registered in Australia - ACN 128 274 653.