RWS Moravia Supplier Code of Conduct

Moravia IT s.r.o., Moravia IT, LLC, and their affiliates (collectively, “RWS Moravia”) are committed to ensuring that their supply chains are safe and that their business is conducted in an ethical and responsible manner. The RWS Moravia Supplier Code of Conduct (the “Code”) sets forth the requirements and standards RWS Moravia holds for each of its suppliers, vendors, contractors, consultants, and all third-parties who do business with RWS Moravia (each, a “Supplier”). 

Each of our Suppliers must fully comply with this Code, and in all of its activities must follow the laws, rules and regulations of the countries in which it operates. In addition, each Supplier will require compliance with these requirements in their agreements with their personnel, suppliers, service providers, contractors and subcontractors (collectively, their “Supply Chain”). 

A. Labor 

A Supplier’s labor practices relating to all of its employees, independent contractors, and personnel must comply with all applicable laws, as well as the requirements and principles of this Code. Suppliers must engage workers whose age is the greater of: (i) 15, (ii) the age of completion of compulsory education, or (iii) the minimum age to work in the country where work is performed. 

Our Suppliers must not use forced labor – slave, prison, indentured, bonded, or otherwise. Our Suppliers must not traffic workers or in any other way exploit workers by means of threat, force, coercion, abduction, or fraud. Working must be voluntary, and workers must be free to leave work and terminate their employment or other work status with reasonable notice. Workers must be given clear, understandable contracts regarding the terms and conditions of their engagement in a language understood by the worker. 

Our Suppliers must provide workers with a safe and healthy work environment, and suppliers must, at a minimum, comply with applicable laws regarding working conditions and with the standards below. 

Our Suppliers must pay their workers in a timely manner and provide compensation (including overtime pay and benefits) that, at a minimum, satisfy applicable laws. Working hours for Supplier’s personnel must not exceed the maximum amount permitted by law. 

Conditions of working must be based on an individual’s ability to do the job, not on personal characteristics or beliefs. Our Suppliers must not discriminate on the basis of race, color, national origin, gender, religion, disability, age, pregnancy, marital or family status, or similar factors in hiring and working practices such as job applications, promotions, job assignments, training, wages, benefits, and termination. Suppliers must not subject workers or applicants to medical tests that could be used in a discriminatory manner. 

Our Suppliers may only engage workers who have a legal right to work. If Suppliers engage foreign or migrant workers, such workers must be engaged in full compliance with the immigration and labor laws of the host country. 

B. Ethical conduct 

Our Suppliers must not offer nor accept bribes or other means of obtaining undue or improper advantages to anyone for any reason, whether in dealings with governments or the private sector. Our Suppliers must not attempt to induce RWS Moravia to violate our Personnel Code of Conduct. Supplier will have a zero tolerance policy for offering and accepting any and all forms of bribery, corruption, extortion and embezzlement (covering promising, offering, giving or accepting any bribes). Supplier will perform all business dealings transparently and these dealings will be accurately reflected on Supplier’s business books and records. Supplier will not make illegal payments themselves or through a third party (or agent). Supplier will implement monitoring and enforcement procedures to ensure compliance with anti-corruption laws. Suppliers must comply with applicable anti-corruption laws, including the United States Foreign Corrupt Practices Act and the United Kingdom Bribery Act, and not offer anything of value, either directly or indirectly, to government officials in order to obtain or retain business. Suppliers must not make illegal payments to government officials themselves or through a third party. 

Suppliers must protect worker whistleblower confidentiality and prohibit retaliation against workers who report workplace grievances. A whistleblower is any person who makes a disclosure about improper conduct by an employee or officer of a company, or by a public official or official body. 

Supplier will disclose information regarding business activities, structure, financial situation and performance in accordance with applicable regulations and prevailing industry practices. Falsification of records or misrepresentation of conditions or practices in the Supply Chain is unacceptable and not permitted. 

Supplier will respect intellectual property rights and will conduct the transfer of technology and know-how in a manner that protects intellectual property rights. 

Supplier will comply with all applicable fair business, advertising and competition laws, including fair trading and antitrust laws. 

Supplier will commit to protecting the reasonable privacy expectations of personal information of everyone they do business with, including suppliers, customers, consumers and employees. Supplier will comply with privacy and information security laws and regulatory requirements when personal information is collected, stored, processed, transmitted and shared. 

C. Environmental 

Our Suppliers must comply with applicable environmental laws. RWS Moravia encourages our suppliers to implement systems that are designed to minimize the impact on the environment by their Supply Chain. 

Suppliers must obtain and keep current all required environmental permits, approvals, and registrations and follow applicable operational and reporting requirements. Suppliers will identify and manage chemicals and other materials posing a hazard to human health, human safety or the environment to ensure their safe handling, movement, storage, use, recycling or reuse and disposal. Suppliers will monitor and treat as required prior to discharge or disposal all wastewater and solid waste generated from operations, industrial processes and sanitation facilities. Suppliers will adhere to all applicable laws, regulations and customer requirements regarding prohibition or restriction of specific substances, including labeling for recycling and disposal. 

D. Ongoing assessments and continued improvement 

Suppliers’ compliance with this Code is subject to review by RWS Moravia, including third-party auditing of work facilities. Suppliers must provide prompt access to their facilities and workers during any audit. 

We require suppliers to promptly provide a detailed remediation plan and take corrective actions for deviations from this Code upon request by RWS Moravia.