Nakisa Supplier Code of Conduct

Our Code of Conduct is more than just a policy—it defines what we believe in, our culture and who we are. At Nakisa, we care deeply about doing the right thing. We share a commitment to operating with the highest ethical standards and making a positive difference in everything we do. We expect our Suppliers to respect and adhere to the same moral and ethical values in the management of their companies and the provision of their services.

In the present Code of Conduct, the term “Suppliers” shall mean any natural person or legal entity providing services or supplying other goods to Nakisa, including, without limitation, any supply chain partners, consultants, resellers, contractors, subcontractors and other professional service providers. Our Suppliers shall make every effort to ensure that the principles set forth in this Code of Conduct are followed and immediately inform us if they are notified by a regulatory authority or any other external party of an audit, investigation, lawsuit, or other inquiry regarding Nakisa, if not legally prohibited from doing so.

1. CULTURE AND VALUE STATEMENTS

1.1 Culture:

Unity in diversity is the best way to describe our culture.

Our learning and our experience at Nakisa are enriched by having Suppliers and partners who come from different backgrounds, ethnicities, religions, nationalities, cultures, genders and sexual orientations. The resulting diversity of ideas, understandings and experiences broadens our perception and wisdom as one company. Our cultural strength is derived from taking advantage of all the benefits our diversity provides, while working towards a cohesive purpose.

1.2 Values:

  1. Fairness: Suppliers are expected to adhere to the principles of fairness in their business practices, ensuring integrity, openness, and equitable treatment of all individuals and entities involved, including customers, employees, and partners.
  2. Integrity: Suppliers are expected to uphold the highest standards of integrity, conducting their business with honesty, transparency, and ethical behavior.
  3. Accountability: Suppliers are required to demonstrate accountability by taking full responsibility for their actions and decisions. They are expected to proactively address any issues or concerns that may arise and actively work towards resolving them in a timely and satisfactory manner. Suppliers should be open to feedback, learning from their experiences and continuously striving to improve their performance and meet their commitments.

2. HARASSMENT

2.1 Nakisa is committed to providing a safe and inclusive working environment for all individuals involved in its supply chain, including its Suppliers, subcontractors, and their employees. We recognize that harassment in any form undermines this commitment and is detrimental to the well-being and productivity of those We therefore expect Suppliers to abide by the following anti-harassment policy:

  1. Prohibition of Harassment: Nakisa has a policy of zero tolerance for any form of harassment, including but not limited to sexual harassment, verbal abuse, discrimination, bullying, and any behavior that creates an intimidating, hostile, or offensive work environment. This policy applies to all interactions within the scope of our supplier relationship, whether on-site, online, or at any other business-related location.
  2. Scope and Applicability: This policy applies to all individuals involved in the Supplier’s workforce, including employees, contractors, temporary workers, and volunteers. Suppliers are responsible for ensuring that their employees are aware of and adhere to this policy.
  3. Reporting Mechanism: We encourage Suppliers to establish a clear and confidential reporting mechanism for incidents of harassment. This may include designated contacts within the supplier organization, a helpline, or an online reporting system. Suppliers should promptly investigate any reports of harassment and take appropriate actions to address the situation in a timely and fair manner.
  4. Non-Retaliation: We have zero tolerance for retaliation against any individual who reports an incident of harassment or participates in an Suppliers must ensure that employees who make a complaint or cooperate in an investigation are protected from any form of retaliation, and appropriate measures should be taken to address and prevent retaliation.
  5. Training and Awareness: We expect Suppliers to provide regular training and awareness programs to their employees to prevent harassment, promote respect, and foster a culture of inclusivity. These training sessions should educate employees on what constitutes harassment, how to recognize it, and the procedures for reporting incidents.
  6. Compliance and Consequences: Suppliers are expected to comply fully with this anti-harassment policy. Failure to do so may result in corrective actions, including but not limited to warnings, termination of the Supplier contract, or other appropriate remedies. We reserve the right to take action based on the severity and frequency of the incidents, as well as the Supplier’s responsiveness and commitment to addressing the issue.

3. DISCRIMINATION AND DIVERSITY

3.1 Nakisa is committed to upholding principles of equality, fairness, and non-discrimination throughout its supply Discrimination based on factors such as race, color, religion, gender, sexual orientation, gender identity, national origin, age, disability, or any other protected characteristic undermines these principles and is contrary to Nakisa’s values. We therefore expect Suppliers to abide by the following anti-discrimination policy:

  1. Equal Opportunities: We expect our Suppliers to provide equal opportunities to all individuals, regardless of their background or characteristics, in all aspects of employment, including but not limited to recruitment, hiring, training, promotion, compensation, benefits, and termination. Discrimination or bias in any form is strictly prohibited.
  2. Non-Discrimination: Suppliers must not engage in any form of direct or indirect discrimination, including discriminatory practices, policies, or behaviors that disadvantage or marginalize individuals based on protected characteristics. This includes but is not limited to discriminatory actions related to hiring, assignments, working conditions, or any other employment-related decisions.
  3. Harassment and Hostile Environment: Suppliers must ensure that their employees are not subjected to harassment, or a hostile work environment based on protected characteristics. This includes verbal, physical, or visual conduct that creates an intimidating, offensive, or hostile Suppliers should establish mechanisms to prevent, address, and promptly resolve any incidents of harassment or hostile environment.
  4. Reasonable Accommodation: Suppliers should provide reasonable accommodation, where required by applicable laws or regulations, to individuals with disabilities or other protected characteristics to ensure equal access to employment opportunities, unless it would impose an undue hardship on the Supplier’s Reasonable accommodation may include modifications to policies, practices, or physical facilities to enable equal participation.
  5. Supplier Diversity and Inclusion: We encourage our Suppliers to embrace diversity and inclusion within their own organizations and supply chains. Suppliers should strive to create a diverse workforce and actively engage in initiatives that promote the inclusion of underrepresented groups.
  6. Compliance and Consequences: Suppliers are expected to comply fully with this anti-discrimination Any violation of this policy may result in corrective actions, including but not limited to warnings, termination of the Supplier contract, or other appropriate remedies. We reserve the right to take action based on the severity and frequency of the discrimination incidents, as well as the Supplier’s responsiveness and commitment to addressing the issue.

4. CONFLICTS OF INTEREST

4.1 Nakisa acknowledges the significance of making impartial decisions at work and is committed to avoiding any circumstances that could potentially generate a conflict of interest for the company. We expect the same commitments from our Supplier must avoid any actions that generate conflicts of interest or give the impression of conflicts of interest.

4.2 What is a Conflict of Interest (“Conflict”)?

The following activities illustrate different types of potential or actual Conflict that should be avoided and/or disclosed to Nakisa, as applicable. The list is not exhaustive and is merely intended to provide guidance:

  1. Self-benefiting: Using your position or relationship within Nakisa to promote your own interests, including using confidential or privileged information gained in the course of involvement with Nakisa for personal benefit or gain or receipt of benefits or favors, or gifts or entertainment that may influence the performance of your duties with Nakisa;
  2. Influence peddling: Soliciting benefits for yourself from outside organizations, companies, entities or individuals in exchange for using your influence to advance the interests of those organizations, companies, entities or individuals with Nakisa;
  3. Other business relationships and dealings: Approving contracts, transactions or arrangements with organizations, companies, entities or individuals in which you have a direct or indirect interest, whether financial or not, which could adversely affect the performance and execution of your duties. This includes transactions involving persons or entities of which the Supplier is a director, trustee, officer, member or key employee or has a financial interest through ownership or control or otherwise in any legal entity, corporation, general partnership, limited partnership, limited liability company or other type of business entity, whether for profit or not, the Supplier may have indirect control or influence; and
  4. Property transactions: Directly or indirectly leasing, renting, trading, or selling movable or immovable property to or from Nakisa.

4.3 Disclosure of a Conflict of Interest

Suppliers have a duty to make a timely and full disclosure of any suspected or actual violations of this Conflict of Interest Policy. Reports of suspected violations shall be addressed to Nakisa’s Legal Department in a strictly confidential manner, by email at contracts@nakisa.com.

If Nakisa has reasonable grounds to believe that the Supplier has failed to disclose an actual or possible Conflict, it shall afford such Supplier an opportunity to explain the alleged failure to disclose. If, after hearing the response and making such further investigation as may be warranted by the circumstances, Nakisa determines that such Supplier has in fact failed to disclose an actual or possible Conflict, it shall take appropriate action, up to and including termination of any agreement currently in place with the Supplier.

5. ANTI-BRIBERY AND CORRUPTION

Nakisa is committed to conducting business with the highest standards of integrity, transparency, and compliance. We have zero tolerance for corruption, bribery, or any form of unethical behavior. This policy applies to all of Nakisa’s Suppliers and their representatives who engage in business with Nakisa. By implementing and enforcing this policy, Nakisa seeks to maintain a culture of integrity, fairness, and ethical business conduct throughout its supply chain.

5.1 Gifting

  1. 5.1.1 Nakisa employees do not give or accept any gift or favor that could compromise or raise doubts about the neutrality of their decisions. We therefore expect the same commitment from our Suppliers. Suppliers must ensure that payments, gifts, or other commitments to customers, government officials, subcontractors, or other parties transacting on their behalf are in compliance with all foreign corruption and applicable anti-bribery Cash or cash equivalents are strictly prohibited.
  1. 5.1.2 Because gifts and entertainment may be used to disguise bribery and corruption, we require that you only offer or accept gifts or entertainment that are reasonable, directly related to a proper business purpose, and in accordance with local laws governing such activity. Any offer of a gift or entertainment to one of our employees during an open bidding process in which you are involved is strictly prohibited.

5.2 Bribery: Suppliers and their representatives must not directly or indirectly make, offer, promise, give, solicit, or accept any payment or anything of value, any form of bribe, kickback, facilitation payment, or improper advantage to/from any employee, agent, or representative, or any other person with a position of trust within an organization or a government/public office.

5.3 Money laundering: Suppliers must not engage in money laundering activities or any illegal financial transactions.

5.4 Political Contributions: Suppliers should refrain from making political contributions, either monetary or in- kind, on behalf of Nakisa, unless explicitly permitted by applicable laws and regulations.

5.5 Supplier Screening and Training: Suppliers will conduct due diligence to assess the integrity and reputation of any third-party suppliers before engaging in business This may include reviewing references, conducting background checks, and assessing compliance with anti-corruption laws. Nakisa’s Suppliers will provide training and awareness programs to their own suppliers and their representatives regarding anti-corruption and anti-bribery policies, laws, and best practices.

5.6 Reporting: Suppliers are encouraged to report any suspected violations of this policy promptly and confidentially to Nakisa’s Legal Department (contracts@nakisa.com). Nakisa will protect whistleblowers from any retaliation.

5.7 Compliance Monitoring: Nakisa may periodically audit and monitor its Suppliers’ compliance with this policy.

5.8 Consequences of Non-Compliance: Violations of this policy may lead to various consequences, including but not limited to:

  1. Termination of the Supplier’s relationship with Nakisa; and
  2. Legal action, which may include reporting the violation to relevant authorities.

6. EQUAL EMPLOYMENT OPPORTUNITIES

Nakisa follows both Canadian federal and provincial regulations where employment equality is concerned.

As an organization regulated by the Canadian federal government, we follow the rules set out by the Employment Equity Act. The Employment Equity Act. is a federal law that requires the provision of equal employment opportunities within your organization to four designated groups: women; Aboriginal peoples; persons with disabilities; and members of visible minorities (http://lois-laws.justice.gc.ca/eng/acts/e-5.401/index.html).

As a Quebec based company, Nakisa also complies with the rules set forth by La commission des normes du travail (http://www.cnt.gouv.qc.ca/en/) which promotes fair and balanced labour relations between employers and employees in compliance with the Act respecting labour standards. We expect all our Suppliers to comply with applicable labor laws in the course of their relationship with Nakisa.

7. HUMAN RIGHTS

All people are entitled to human rights. Nakisa believes that all of its employees and Suppliers deserve a fair and ethical workplace and must be treated with dignity and respect. This means that you must treat all employees, contractors, and subcontractors fairly, with dignity, respect, and integrity. You shall not discriminate, harass, intimidate, threaten, humiliate, or abuse employees or contractors generally and specifically as follows:

  1. Nakisa and Suppliers shall not discriminate against any staff member based on race, color, religion, gender, age, national or social origin, sexual orientation, gender identity, marital status, disability, political affiliation, or union membership, in hiring and other employment practices like salary, promotions, rewards, access to training, employment termination, and retirement, and to be equally committed to providing equal opportunities and treatment to all employees.
  2. Nakisa and Suppliers shall provide a workplace free of harassment, corporal punishment, coercion, and abuse. Any threats or other forms of intimidation must be Suppliers shall ensure that all work is conducted willingly, with employees engaged voluntarily and without any form of undue influence or force. Employment contracts shall be easily understood by employees, and they should be free to terminate their employment upon reasonable notice. They shall not traffic persons or use any form of forced, bonded, slave, or prison labor. Employees should not surrender any personal identification documents as a condition of employment.
  3. Nakisa and Suppliers shall not engage in or support any form of forced labor, including involuntary or coerced labor, debt bondage, human trafficking, or any work performed under the threat of punishment, restriction of movement, or other forms of physical, psychological, or sexual abuse.
  4. Nakisa and Suppliers shall employ only members of staff who are at least the applicable minimum legal age for the work to be For persons under the age of 18, Nakisa and Suppliers shall identify presence, monitor health, working conditions, hours of work, and shall not employ for hazardous work or in a manner that is economically exploitative, interferes with education, or is harmful to health, physical, mental, spiritual, moral, or social development. Suppliers shall follow all applicable laws, regulations and/or collective agreements with respect to working conditions, hours, days of rest, wages, and salaries.
  5. Nakisa and Suppliers shall freely allow employees to associate with others and organizations of their choice and seek representation to bargain collectively.
  6. Nakisa and Suppliers shall allow employees to express their concerns about working conditions or potentially unlawful practices without threats of reprisal or harassment.
  7. Nakisa and Suppliers must always provide a healthy and safe working environment to all employees and As a minimum, this includes safe drinking water, adequate lighting, temperature, ventilation, and sanitation. All facilities and housing conditions, if provided, must be constructed and maintained in accordance with the standards set by applicable laws and regulations.

8. GREEN POLICY

Nakisa is committed to leading our industry and our organization by minimizing the impact of its activities on the environment. Nakisa seeks to work with Suppliers who strive to use resources, material and energy as efficiently and responsibly as possible. At a minimum, Suppliers are required to operate in compliance with relevant environmental laws of the countries in which they operate.

The key points of Nakisa’s strategy to minimize its impact on the environment are as follows:

  1. Lowering the heat to a comfortable level.
  2. Recommending that Suppliers, employees and contractors working on Nakisa’s premises drink tap water, not bottled water, provided tap water is safe for consumption.
  3. Reducing printing as much as possible and striving to attain a paperless organization.
  4. Reducing electricity consumption by turning off the lights in the rooms when not in use.
  5. Reducing electricity consumption by turning off or putting in sleep mode all company computers and laptops when not in use.
  6. Unplugging appliances when they are not in use.
  7. Actively promoting recycling.
  8. Meeting or exceeding all the environmental legislation that applies to Nakisa.

9. ACKNOWLEDGEMENT

By doing business with Nakisa, you are deemed to have read, understood and agreed to abide by this Code of Conduct. Failure to adhere to these standards or failure to correct violations may result in corrective actions by Nakisa, including but not limited to warnings, termination of the Supplier contract, or other appropriate remedies.

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