Supplier Code of Conduct

I. Introduction

RED GLOBAL (“We” or “RED”) is a permanent recruitment and staffing company that operates in multiple regions in the world.

We aim for high ethical and social standards and expect all our suppliers to do so equally and operate in an ethical, legally compliant and professional manner.

As such we have devised a Code of Conduct which reflects these core principles and sets out the minimum standards that must be met by any Suppliers to our business.

When working for RED we expect our suppliers to adhere to the following principals:

II. Legal compliance

In addition to complying with the standards set out in this Code, when carrying out an agreement with RED, the Supplier shall comply with all applicable laws and regulations of the country where RED is based (and if applicable, the laws and regulations of any other jurisdiction where the Supplier operates), including the laws and regulations relating to issues addressed in this Code. This Code applies to activities in the locations where Suppliers’ services are performed.

III. Data Protection and Privacy

1. Compliance with Data Protection Laws:

Suppliers must comply with all applicable data protection laws and regulations, including but not limited to the General Data Protection Regulation (GDPR) in the European Union and any other relevant national or international laws.

2. Data Processing Purpose:

Suppliers shall only process personal data obtained from or on our behalf for the specified purposes outlined in our agreement or contract. Any additional processing must be agreed upon in writing and compliant with applicable laws.

3. Confidentiality and Security:

Suppliers must ensure the confidentiality, integrity, and security of all personal data processed on behalf of our organisation. This includes implementing appropriate technical and organisational measures to protect against unauthorised access, disclosure, alteration, or destruction of personal data.

4. Data Minimisation:

Suppliers shall only collect, process, and retain personal data that is necessary for the fulfilment of their obligations under the agreement or contract. They must not collect excessive or irrelevant personal data.

5. Data Subject Rights:

Suppliers must assist our organisation in fulfilling data subjects' rights requests, including but not limited to access, rectification, erasure, and data portability, as required by applicable data protection laws.

6. Subprocessing:

Suppliers shall not subcontract or engage sub-processors for the processing of personal data without our prior written authorisation. If subcontracting is permitted, suppliers must ensure that sub-processors comply with the same data protection obligations as outlined in this Code of Conduct.

7. Data Transfers:

Suppliers Shall not transfer personal data outside of the European Economic Area (EEA) or other jurisdictions with similar data protection standards without our explicit consent and ensuring adequate safeguards are in place, such as Standard Contractual Clauses or Binding Corporate Rules.

8. Data Breach Notification:

Suppliers must promptly notify our organisation of any personal data breach affecting the personal data processed on our behalf. The notification should include all relevant details of the breach, its impact, and any remedial actions taken or proposed.

9. Data Protection Impact Assessments (DPIAs):

Suppliers shall conduct DPIAs where required by law or as requested by us to assess the impact of data processing activities on data subjects' privacy rights and to implement appropriate measures to mitigate risks.

10. Training and Awareness:

Suppliers must ensure that their employees involved in the processing of personal data receive adequate training on data protection laws, regulations, and best practices. They should also promote a culture of data protection awareness within their organisation.

11. Audits and Compliance Monitoring:

Suppliers must allow us or our Client (if applicable) to audit their data processing activities, facilities, and documentation to ensure compliance with this Code of Conduct and applicable data protection laws. Suppliers shall cooperate fully with such audits and provide necessary assistance and information.

12. Non-Compliance and Remedies:

Failure to comply with this Code of Conduct or data protection laws may result in termination of the agreement or contract, legal action, or other remedies available under applicable law.

IV. Ethical conduct (integrity, honesty, no conflict of interest)

1. Ethical Conduct:

All business activities are to be conducted with integrity, honesty, and transparency and avoid engaging in any conduct that is unlawful, unethical, or contrary to RED’s values.

2. Conflicts of Interest:

Any conflicts of interest are to be disclosed and managed appropriately and situations where personal interests may conflict with the interests of RED, our clients, or stakeholders are to be avoided.

3. Anti-Bribery and Corruption:

Bribery, corruption, and improper payments in all business dealings are prohibited and not tolerated. This includes any actions that offer, solicit, or accept bribes or kickbacks, whether directly or indirectly, to or from any individual or organisation.

4. Fair Competition:

We promote fair and open competition in the marketplace and do not engage in anticompetitive practices such as price-fixing, bid-rigging, market allocation, or other forms of collusion.

5. Trade Sanctions:

Suppliers shall comply with all applicable laws and regulations relating to trade sanctions. They must not purchase goods or services from, or otherwise engage in trade with, any individuals, entities, organisations, or countries that are covered by applicable trade sanctions.

6. Tax

Suppliers shall meet their tax obligations, shall not participate in or facilitate unlawful tax evasion or fraud and shall not become involved in any arrangements that might result in their workers not being taxed appropriately.

V. Anti-slavery and human trafficking

Any forms of slavery and/or human trafficking are prohibited, and we will not tolerate any involvement in or support of such practices within our operations or supply chains. We expect all our (potential) Suppliers to commit to this, too.

VI. Fair treatment of employees

Suppliers are to provide our employees the best working environment possible and therefore commit to the principals below.

1. Health and Safety:

Provide a safe and healthy work environment for all employees, contractors, and visitors. Comply with applicable health and safety laws and regulations and implement measures to prevent accidents, injuries, and occupational hazards.

2. Work Hours and Rest Breaks:

Ensure that work hours are reasonable and in compliance with applicable labour laws and regulations. Provide adequate rest breaks and time off to promote employee well-being and prevent burnout.

3. Fair Wages and Benefits:

Pay employees fair wages and benefits that meet or exceed legal requirements and industry standards. Ensure that compensation is provided in a timely and transparent manner, and that deductions are lawful and clearly communicated.

4. Non-Discrimination:

Prohibit discrimination and harassment in the workplace on the basis of race, colour, gender, sexual orientation, gender identity, religion, national origin, disability, age, or any other protected characteristic. Treat all employees with dignity and respect.

5. Equal Opportunities:

Provide equal opportunities for employment and advancement based on merit, skills, and qualifications. Avoid favouritism, nepotism, or any form of unfair treatment in hiring, promotion, or other employment decisions.

6. Workplace Diversity and Inclusion:

Promote a diverse and inclusive workplace where employees of all backgrounds feel welcome, valued, and empowered to contribute. Embrace diversity as a strength and actively promote inclusion through policies and initiatives.

7. Ethical Conduct:

Encourage ethical conduct and integrity in all aspects of work. Prohibit dishonesty, fraud, theft, or any other unethical behaviour that undermines trust and integrity in the workplace.

8. Rights to work

Where legal requirements require employees to obtain a right to work before commencing employment, it is to be warranted that these legal requirements will be adhered to.

9. Written contract for Employees and Workers

Suppliers must provide all their employees and workers with written contracts in a language they understand. These contracts must clearly state the terms of employment, including job description, salary, working hours, and other working conditions. This is to ensure that all workers are fully informed of their rights and obligations from the outset of their employment.

10. Freedom of association and collective bargaining

Suppliers recognise and respect the right of their employees to freely join or refrain from joining workers organisations, including trade unions, and entering into collective bargaining as permitted by law.

VII. Environmental responsibility

Suppliers shall ensure compliance with applicable local and national environmental laws and regulations across all operational countries and jurisdictions and shall manage business operations according to industry best practices and with a focus on responsibility and sustainability.

In all cases Suppliers should be able to demonstrate environmental policies and management systems sufficient to ensure continuous improvement in environmental performance.

The potential environmental impacts of daily business decision-making processes should be considered along with opportunities for conservation of natural resources, source reduction, material recycling, and pollution control to ensure cleaner air and water and reduction of landfill wastes. RED encourages its suppliers to identify, set targets and implement action plans for reducing environmental impacts in the areas of water, wastewater, energy, greenhouse gas emissions, waste and packaging.

VIII. Reporting / Whistleblowing

Suppliers are to commit to adhere to the following principals in regard to reporting or whistleblowing:

1. Confidential Reporting:

Concerns, misconduct, or violations of laws, regulations, or company policies through are to be reported via confidential channels.

2. Protection from Retaliation:

Retaliation or adverse actions against individuals who report concerns or participate in whistleblowing activities in good faith are to be prohibited.

3. Investigation and Response:

Reports of concerns or misconduct are to be promptly and thoroughly investigated by the Supplier. Appropriate action is to be taken to address substantiated issues and prevent recurrence.

4. Fair Treatment:

Whistleblowers are to be treated fairly and impartially throughout the investigation process. They are to be kept informed of the progress and outcome of the investigation to the extent possible without compromising confidentiality or legal considerations.

5. Documentation and Recordkeeping:

All reports of concerns or misconduct, as well as investigation outcomes and actions taken, are to be documented and retained in accordance with applicable laws and regulations.

IX. Compliance with this Code of Conduct

Suppliers are to review and accept this code of conduct prior to providing services for

RED or RED’s Clients. In the even the Supplier cannot comply with the above-mentioned stipulations the Supplier is to inform RED accordingly and stating the reasons for not complying.

RED reserves the right to conduct audits on the Suppliers compliance with the Code of Conduct. The Supplier agrees to assist RED in the aforementioned audits.

In the event the Supplier fails to comply with the principals as set forth in this Code of Conduct, RED reserves to terminate any and all contractual relationships with the Supplier with immediate effect. RED additionally reserves the right to take legal action where appropriate.

X. Acknowledgement

The Supplier warrants that they will adhere to the principals set forth in this Code of Conduct. Furthermore, the Supplier will ensure that any Employees, subcontractors, or other agents of the Supplier will adhere to these principals.

This Code of Conduct is to be treated as a living document that can be iteratively improved over time where RED sees the necessity to do so.

XI. Queries

Any questions or queries in relation to this code of conduct are to be raised with

RED’s Legal and Compliance Team, which can be contacted via the following e- mail address: redlegal@redglobal.com