Supplier Code of Conduct

1Scope & Purpose

This Supplier Code of Conduct ("Code") defines the minimum standards and requirements that suppliers, manufacturers and business partners ("Supplier") must comply with when producing goods or providing services for TBK Projects.

The Code applies to all production sites, facilities and subcontractors involved in TBK Projects' supply chain and forms an integral part of the contractual relationship.

2Legal Compliance & International Standards

The Supplier shall comply with all applicable local, national and international laws and regulations. In addition, the Supplier commits to respecting internationally recognised standards, including but not limited to:

• The United Nations Global Compact principles;
• The International Labour Organization (ILO) Core Conventions;
• The OECD Guidelines for Multinational Enterprises.

Where local laws and international standards differ, the higher standard shall apply.

3Human Rights & Labour Standards

The Supplier shall respect and protect fundamental human rights and ensure fair and lawful working conditions. This includes, but is not limited to:

3.1 Prohibition of Forced and Child Labour

• No forced, bonded or involuntary labour;
• No child labour in violation of applicable laws or ILO standards;
• Workers shall not be required to surrender identity documents or deposits.

3.2 Non-Discrimination & Equal Treatment

• No discrimination based on gender, age, ethnicity, nationality, religion, disability, sexual orientation or political opinion;
• Equal opportunities in employment and occupation.

3.3 Freedom of Association

• Respect for the right to freedom of association and collective bargaining, where legally permitted.

3.4 Working Hours & Wages

• Compliance with applicable laws regarding working hours and rest periods;
• Payment of wages at least in accordance with legal minimum wages and benefits;
• Overtime shall be voluntary and compensated in accordance with the law.

4Health & Safety

The Supplier shall provide a safe and healthy working environment. Minimum requirements include:

• Compliance with occupational health and safety laws;
• Implementation of fire safety and emergency procedures;
• Clear marking and accessibility of emergency exits;
• Regular health and safety training for employees;
• Recording and investigation of work-related accidents.

5Environmental Responsibility

The Supplier shall comply with all applicable environmental laws and regulations and strive to minimise its environmental impact. This includes:

• Responsible management of emissions, wastewater and waste;
• Safe handling, storage and disposal of hazardous substances;
• Efficient use of resources such as energy, water and materials;
• Implementation of environmentally responsible production practices where possible.

Any environmental incidents or significant non-compliance must be reported to TBK Projects without undue delay.

6Product Safety, Chemical Compliance & Materials

The Supplier shall ensure that all products supplied to TBK Projects comply with applicable product safety and chemical regulations in the destination markets, particularly within the European Union. This includes, but is not limited to:

• Compliance with the EU General Product Safety Regulation (GPSR) and applicable national laws;
• Compliance with REACH Regulation (EC) No 1907/2006 and the POP Regulation (EU) 2019/1021;
• Compliance with any Restricted Substances List (RSL) issued by TBK Projects;
• No intentional use of prohibited or restricted substances.

The Supplier shall maintain Safety Data Sheets (SDS), test reports and declarations of conformity and provide them upon request.

7Traceability & Documentation

The Supplier shall maintain appropriate systems to ensure traceability of:

• Production sites;
• Materials and components;
• Production batches and processes.

Relevant documentation must be retained and made available to TBK Projects or appointed third parties upon request.

8Subcontracting & Supply Chain Transparency

The Supplier shall not subcontract any part of the production or processing of goods for TBK Projects without prior written approval. Where subcontracting is approved:

• Full transparency regarding subcontractors and production locations is required;
• The Supplier remains fully responsible for compliance by subcontractors with this Code;
• Undisclosed subcontracting may constitute a material breach of contract.

9Business Ethics, Anti-Corruption & Integrity

The Supplier shall comply with all applicable anti-corruption and anti-bribery laws, including but not limited to the UK Bribery Act 2010 and the U.S. Foreign Corrupt Practices Act (FCPA).

The Supplier shall:

• Not offer, promise, give or accept bribes or improper advantages;
• Maintain accurate and transparent business records;
• Implement internal controls to prevent corruption and fraud.

Any breach of this section may result in immediate termination of the business relationship.

10Complaints Mechanism & Non-Retaliation

The Supplier shall establish or participate in an effective complaints or grievance mechanism allowing workers and stakeholders to raise concerns related to human rights, labour conditions, health & safety or environmental impacts.

The Supplier commits to:

• Handling complaints confidentially and fairly;
• Prohibiting retaliation against whistleblowers or complainants acting in good faith;
• Cooperating with TBK Projects in investigations and remediation.

Serious incidents or risks must be reported to TBK Projects without undue delay.

11Audits, Monitoring & Corrective Actions

TBK Projects reserves the right to:

• Request documentation or self-assessments;
• Conduct or commission audits, announced or risk-based;
• Require corrective and preventive action plans (CAPA).

The Supplier shall cooperate fully and remedy identified non-compliances within agreed timelines.

12Breach & Termination

Failure to comply with this Code may constitute a material breach of contract and may result in:

• Suspension of orders;
• Termination of the business relationship;
• Further legal action where applicable.

13Acknowledgement

Suppliers formally acknowledge and sign this Code as part of the TBK Projects supplier onboarding process. The signed version forms an integral part of the contractual relationship.