SUPPLIER CODE OF CONDUCT

AKESA SUPPLIER CODE OF CONDUCT 

About this Code 

Akesa Group (‘Akesa’) is committed to conducting business ethically, with integrity, and in compliance with applicable laws. Our suppliers are an extension of our business, and the way they operate reflects on Akesa, our customers, and the patients who ultimately rely on the goods and services we deliver. 

This Code sets out Akesa’s expectations of our suppliers. It applies to any third party that provides goods or services to Akesa or acts on Akesa’s behalf, including consultants, vendors, agents, distributors, logistics providers, and their subcontractors. We expect our suppliers to apply the same standards in their own supply chains. 

We recognise that not every part of this Code will be directly relevant to every supplier. We ask suppliers to apply each section as it relates to the services they provide.  

Specific operational, regulatory, and contractual requirements applicable to a supplier engagement are set out in the relevant agreement, technical agreement, and onboarding documentation. 

Ethical conduct 

Anti-bribery and corruption 

Akesa has zero tolerance for bribery and corruption. We expect our suppliers to: 

• act with integrity in all dealings related to Akesa; 

• never offer, give, accept, or solicit anything of value to obtain an improper business advantage; 

• avoid facilitation payments and similar improper payments in any form; 

• maintain reasonable internal procedures to prevent corruption, and keep accurate business records; and 

• comply with anti-bribery and corruption laws relevant to their operations. 

Conflicts of interest 

We expect our suppliers to act in Akesa’s interests when working on Akesa’s behalf. This means: 

• avoiding situations where personal, financial, or other interests could conflict with duties to Akesa; 

• disclosing any actual or potential conflict of interest as soon as it becomes apparent, including engagements with Akesa competitors, personal relationships with Akesa personnel, and financial interests in related parties; and 

• not using information obtained through an Akesa engagement for personal benefit or for the benefit of any third party. 

Fair competition and trade compliance 

Akesa competes fairly and expects suppliers to do the same. Suppliers should not participate in price-fixing, bid-rigging, or market allocation, and should comply with applicable trade controls, export restrictions, and sanctions. 

Gifts and hospitality 

Suppliers should not offer gifts or hospitality to Akesa personnel that could improperly influence business decisions. Modest, customary business hospitality is acceptable where it is transparent and proportionate.  

People 

Human and labour rights 

Akesa respects human rights and expects suppliers to do the same. We align our expectations with the International Labour Organization (ILO) Core Conventions and the UN Guiding Principles on Business and Human Rights. We expect suppliers to: 

• ensure all employment is voluntary, and that workers are free to leave with reasonable notice and without penalty; 

• prohibit forced, bonded, trafficked, or prison labour in their operations and supply chains; 

• not employ workers below the legal minimum age, and not assign hazardous work to workers under 18; 

• provide a workplace free from discrimination, harassment, abuse, and retaliation, with employment decisions based on merit; 

• pay at least the legal minimum wage and comply with laws on working hours, rest, and overtime; 

• respect workers’ rights to associate, organise, and raise concerns through lawful means; and 

• identify and mitigate modern slavery and human trafficking risks in their operations and supply chains. 

Health, safety, and wellbeing 

We expect suppliers to provide a safe and healthy working environment, including: 

• compliance with applicable work health and safety laws; 

• identification, assessment, and mitigation of occupational risks; 

• appropriate training, protective equipment, and emergency procedures before workers perform hazardous tasks; 

• respect for workers’ right to refuse unsafe work without retaliation; and 

• recording and investigation of incidents, with corrective action where needed. 

Worker grievance mechanism 

We expect suppliers to provide their workers with an accessible way to raise concerns about workplace conditions, conduct, or ethical matters, and to protect workers from retaliation when they do so in good faith. 

Product integrity 

For suppliers handling therapeutic goods or performing regulated activities on Akesa’s behalf, product integrity is fundamental. We expect these suppliers to: 

• comply with applicable Good Distribution Practice (GDP), Good Wholesaling Practice (GWP), and equivalent standards in their jurisdictions; 

• maintain product authenticity, traceability, and integrity throughout their custody of the goods; 

• prevent counterfeit, falsified, diverted, or tampered goods from entering Akesa’s supply chain; 

• maintain validated temperature control and cold chain integrity where required; 

• keep auditable records that support regulator inspection; 

• notify Akesa promptly of any suspected counterfeit, falsified product, product complaint, or quality issue; and 

• cooperate with regulatory authorities and with Akesa during inspections, investigations, and audits. 

Information and data 

Suppliers that handle Akesa’s confidential or proprietary information, intellectual property, or personal data are expected to: 

• apply reasonable technical and organisational safeguards proportionate to the sensitivity of the information; 

• comply with applicable privacy and data protection laws in their operating jurisdictions; 

• use Akesa information only for the purposes agreed with Akesa; 

• notify Akesa without undue delay of any suspected or actual data breach affecting Akesa information; and 

• return or securely delete Akesa information at the end of the engagement or on Akesa’s request. 

Environment 

Akesa expects suppliers to operate responsibly with respect to the environment. This means: 

• complying with applicable environmental laws, permits, and regulations; 

• managing waste, emissions, and hazardous materials safely; and 

• taking reasonable steps to reduce energy, water, and resource use. 

Raising concerns with Akesa 

We encourage suppliers, their workers, and their subcontractors to report suspected breaches of this Code, unethical conduct, or any concern about Akesa or its supply chain. Reports may be made to: 

Chief Operating Officer 

Email: [email protected] 

Akesa will treat all reports confidentially to the extent permitted by law. We do not tolerate retaliation against any person who raises a concern in good faith.