Supplier Code of Conduct

Oben requires its suppliers to adhere to defined integrity and social responsibility standards. The Oben Supplier Code of Conduct ("S-Code") specifies these requirements. Suppliers are expected to comply with the S-Code, follow applicable laws and regulations, and ensure their suppliers, subcontractors, and agents also meet comparable standards.

Overview

The S-Code reflects Oben’s values and sets forth what is required and expected of its Suppliers with respect to the following topics:

  1. Ethics and integrity
  2. Data privacy and security
  3. Inclusion and diversity
  4. Employment, working conditions, and human rights
  5. Wellbeing, health, and safety
  6. Environmental sustainability

S-Code - Oben Supplier Code of Conduct

Ethics and Integrity

Oben follows all applicable laws and regulations. Suppliers must do the same and meet these key requirements:

Anti-bribery and Anti-corruption

Suppliers must adhere to all relevant anti-bribery and anti-corruption legislation.

Gifts and Entertainment

Suppliers must not offer or accept gifts, payments, or inducements to improperly influence Oben, its employees, families, associates, or third parties.

Non-Retaliation

Oben requires Suppliers to provide a transparent process for reporting workplace concerns, ensuring protection from retaliation for all involved.

Trade and sanctions

Suppliers are expected to adhere to relevant trade and sanctions laws and regulations.

Data Privacy and Security

Oben requires Suppliers to protect individual privacy and secure confidential information for employees, customers, and business partners.

Confidential Assets and Information

Suppliers must protect Oben’s and its clients’ confidential assets and information by maintaining strong security processes.

Personal Information and Privacy

Suppliers are required to handle personal information in compliance with applicable laws and regulations. Access, use, or disclosure of any personal information provided by or on behalf of Oben is permitted only as specified in the Supplier agreement and according to relevant legal requirements.

Inclusion and Diversity

Oben values diversity and fosters inclusion. Discrimination is not accepted in any form.

Non-Discrimination and Workplace Diversity

Suppliers must comply with all laws regarding non-discrimination in hiring, employment, harassment, and retaliation. Their workplaces should be free from discrimination, harassment, victimisation, or abuse based on factors such as age, disability, origin, gender, race, sexual orientation, marital or parental status, pregnancy, political beliefs, religion, union membership, or veteran status. Unequal treatment includes paying different wages for work of equal value.

Supplier Diversity

Oben is committed to diversity and inclusion by partnering with diverse and underrepresented businesses in its sourcing and procurement. Suppliers are expected to: 1. use unbiased and transparent evaluation processes, 2. ensure fair access for diverse suppliers, and 3. actively seek and involve diverse suppliers where feasible.

Employment, working conditions, and human rights

Oben is a participant in the United Nations Global Compact and cites the Ten Principles regarding human rights, labor, environment, and anti-corruption; the Universal Declaration of Human Rights; the International Labour Organization’s (ILO) Declaration on Fundamental Principles and Rights at Work; and the UN Guiding Principles on Business and Human Rights. Oben states its intention to follow these frameworks and expects Suppliers to operate in accordance with them.

Modern slavery / human trafficking

Oben and its suppliers must prohibit slavery, forced labor, child labor, and human trafficking in their supply chains. Suppliers are required to comply with laws and must implement measures to ensure legal compliance.

Child labor

Oben does not permit child labor at any stage of its supply chain. For these purposes, “child” means anyone employed below the age of 18 or below the legally defined minimum working age, unless otherwise specified by applicable law.

Human rights

Oben requires all operations and Suppliers to respect human rights. Suppliers must ensure a safe, respectful workplace free from violence, threats, punishment, coercion, abuse, disrespect or harassment.

Freedom of association

Suppliers must allow workers to freely form or join unions and workers’ councils, as permitted by local laws, without fear of retaliation, harassment, or intimidation. Employment laws Suppliers are expected to follow applicable wage and labor laws and regulations. Employees are to receive pay statements in a timely manner that provide sufficient information to verify compensation accuracy. Temporary, dispatch, and outsourced labor must comply with all relevant legal standards.

Use of security forces

Suppliers that employ or use security forces are required to provide appropriate training and instructions to prevent mistreatment, harm to individuals, or limitations on workers’ freedom of association.

Wellbeing, health, and safety

Oben expects Suppliers to maintain strong health and safety standards in all operations.

Health and safety

Suppliers must follow all health and safety laws. Oben requires suppliers to reduce risks, prevent accidents, and maintain a safe workplace for everyone, including employees, contractors, and third parties.

Environment Sustainability

Oben aims to reduce its environmental impact and requires Suppliers to do likewise.

Promote Environmental responsibility

Suppliers must follow environmental laws and regulations. When required, they should manage environmental risks, energy use, and emissions, and, where relevant, monitor and reduce water, resource usage, and waste.

Environmentally friendly technologies

Suppliers and their supply chains should promote, encourage development and defusal of eco-friendly technologies.

Compliance with the S-Code

Reporting Violations

Suppliers are required to report any legal or S-Code violations, as well as breaches of Oben policies, to Oben. When permitted by law, they are also expected to forward subpoenas, regulatory requests, media inquiries, or other third-party communications related to Oben. Use our whistleblower confidential channel for reporting suspected misconduct or legal, policy, or ethical violations. Details about this process are available on our webpage.

Oben’s Rights

Oben maintains the following rights to ensure and enforce Supplier compliance with this S-Code.

Supplier Selection

Oben will review Suppliers’ compliance with the S-Code during selection, onboarding, and throughout the partnership.

Supplier Assessment

Suppliers may be required to confirm and periodically reconfirm compliance with the S-Code and provide relevant written policies upon request. Oben may require Suppliers to complete third-party assessments or on-site audits to ensure compliance with the S-Code. Suppliers should work proactively with Oben to address performance issues and implement corrective actions as needed.

Non-Compliance, Violations, and Termination

Suppliers must ensure that their suppliers, subcontractors, and agents comply with this S-Code or equivalent standards. Any violations, including those by these parties, must be reported and addressed by Suppliers. If non-compliance or breaches occur, Oben may allow time for corrective action unless the violation is severe, irreparable, or illegal. Oben can suspend or end its relationship with the Supplier and report any legal violations to authorities.

Order of Precedence; Changes to the S-Code

If this S-Code conflicts with the law, Suppliers must follow the law. Where this S-Code requires more than the law, Suppliers should meet those requirements as long as they are permitted by law. Oben reserves the right to modify or update the S-Code at its discretion. Date of initial adoption: 20th November, 2024