1. Introduction

Meca-Trade is committed to being a responsible corporate citizen and a trustworthy partner. We believe that sustainable and ethical practices create long-term value for both Meca-Trade and its stakeholders. We uphold the highest standards of integrity under all circumstances and expect the same commitment from our suppliers. Our suppliers must comply with this Supplier Code of Conduct and ensure that their own suppliers adhere to the same standards. Suppliers must also comply with all applicable laws and regulatory requirements, including those related to sanctions, anti-corruption, human rights, and environmental regulations.

Meca-Trade Supplier Code of Conduct is based on the UN Global Compact initiative, UN Universal Declaration of Human Rights and International Labour Organization’s (ILO) Fundamental Principles and Rights at Work. As a part of supplier selection process, Meca-Trade conducts due diligence to identify and manage potential risks.

2. Human Rights

2.1 Health and Safety

Suppliers must provide a safe and healthy working environment that minimizes work-related injuries and implements all feasible measures to prevent such incidents.

Suppliers are required to fully comply with applicable national health and safety laws and regulations.

All employees must receive appropriate health and safety training and be provided with the necessary protective equipment to perform their tasks safely.

2.2 Labor Rights

Suppliers shall ensure that all work is voluntary and free from any form of coercion, forced labor, bonded labor, or human trafficking. Suppliers shall not withhold wages, identity documents, or any other important personal documents.

Suppliers shall not employ child labor in their operations or supply chain. They must adhere to the higher of either local legal age requirements or the International Labor Organization’s minimum age of 15 years.

Suppliers shall pay fair and reasonable wages and benefits in accordance with relevant legal standards.

Suppliers shall always treat all employees equally and with respect.

Suppliers shall prohibit all forms of harassment, including physical, sexual, or verbal abuse.

Suppliers shall foster equal opportunities and diversity, ensuring that employees receive equal pay for work of equal value.

Suppliers shall not tolerate discrimination based on racial or ethnic background, age, gender, disabilities, sexual orientation, religious beliefs, family status, social origins, political opinions, union membership, or other such characteristics.

Suppliers shall ensure working hours, vacation times, wages, and other working conditions comply with local laws and international standards.

Suppliers shall ensure freedom of association, allowing employees to organize, join associations, and bargain collectively.

2.3 Conflict Minerals

Suppliers shall not source minerals or metals, such as tin, tantalum, tungsten, or gold, from regions where such materials contribute to conflicts.

If a Supplier causes or contributes to human rights violations of any kind, they are expected to cease such violations immediately and offer remedies to affected individuals. If necessary, the Supplier must develop and implement a corrective action plan.

3. Working with Integrity

3.1 Anti-Corruption Obligation

Offering, promising, authorizing, giving, or accepting, directly or indirectly, any payments or anything of value to improperly influence a business decision or to secure special treatment is strictly prohibited. Facilitation payments are prohibited.

3.2 Gifts and Hospitality

Any gifts or hospitality offered must be given in a legitimate business context and be reasonable, proportionate, and modest in economic value.

Suppliers shall never offer gifts of cash or cash equivalents (such as gift cards) or gifts that intend to make the recipient feel that the giver expects something in return to Meca-Trade.

3.3 Conflicts of Interest

Suppliers must act in an open and transparent manner and avoid and mitigate situations which create or have the appearance of a conflict of interest.

Suppliers must notify Meca-Trade of any actual or potential conflict of interest as soon as they identify them.

Once a potential or actual conflict of interest is identified, the Supplier should work with their main Meca-Trade contact to determine the best way to manage it.

4. Environmental Responsibility

Suppliers shall operate in an environmentally responsible and sustainable manner. At a minimum, suppliers must comply with all applicable environmental laws, regulations, and standards in the countries in which they operate. In addition, suppliers are expected to:

Conserve natural resources, including water, energy, and raw materials, through efficient use, reuse, and recycling, and to promote a circular economy across the product or service lifecycle.

Reduce pollution and emissions, including greenhouse gases, hazardous substances, and other pollutants to air, water, and soil, while striving for climate neutrality by setting measurable targets.

Protect and preserve biodiversity and natural ecosystems, avoiding deforestation, habitat destruction, and other activities that harm wildlife.

Obtain and maintain all required environmental permits and approvals and adhere to their operational and reporting requirements.

Identify, manage, and reduce the use of hazardous substances in production and operations, with the goal of replacing them with safer alternatives when feasible.

Monitor environmental impacts and continuously seek ways to improve environmental performance, including implementing environmental management systems or certifications (e.g., ISO 14001).

5. Fair Business Practices

5.1 Competition Law

Suppliers must strictly adhere to all applicable competition laws.

Suppliers shall take all necessary actions and training measures to ensure sufficient knowledge about, and strict adherence to, competition law compliance, including the rules regarding information exchange.

5.2 Anti-Money Laundering

Suppliers shall comply with anti-money laundering obligations and ensure that they do not put into circulation any funds or other assets that originate directly or indirectly from criminal offenses, such as fraud, tax evasion, human trafficking, or bribery.

5.3 Terrorist Financing and Conflict Contribution

Suppliers shall not conduct business with entities that have connections with terrorist organizations or organized crime.

Suppliers shall avoid contributing to conflict through their sourcing practices.

5.4 Trade Sanctions

Suppliers shall not buy from or supply products or materials to any countries, territories, individuals, or entities in breach of any applicable sanctions, export restrictions, and other similar restrictive measures, including but not limited to those issued by the United Nations, European Union, United States, and United Kingdom.

Suppliers shall have a risk-based due diligence approach, which considers and verifies the basic facts of business partners, including company type, business nature, domicile, and country of origin of purchases.

5.5 Accuracy of Information and Data Protection

Suppliers shall issue accurate and transparent financial and other information about their business operations.

Suppliers shall protect entrusted confidential and sensitive information with due care and ensure cybersecurity in their operations by understanding risks and implementing sufficient controls.

Suppliers shall commit to the principles of good data protection and comply with applicable data protection laws and regulations.

Suppliers shall respect the privacy of personal data of employees and all other stakeholders and ensure that personal data is collected and processed only to the extent necessary for predetermined and legitimate purposes.

6. Compliance

By adhering to this Supplier Code of Conduct, suppliers contribute to a fair, ethical, and sustainable business environment that benefits all stakeholders. Meca-Trade reserves the right to conduct audits and assessments to ensure compliance with this Code and all applicable laws, including those related to sanctions, anti-corruption, human rights, and environmental regulations.

Suppliers who are not in compliance with this Supplier Code of Conduct must promptly implement any necessary corrective actions, or they may be terminated from consideration of future business with Meca-Trade.