Compliance with Laws and Ethical Standards

❖    Suppliers must comply with all applicable local, national, and international laws and regulations in all jurisdictions where they operate.

❖    Suppliers shall prohibit all forms of extortion, embezzlement, bribery, and improper advantage-seeking behaviors.

❖    Gifts, hospitality, or entertainment intended to influence a business decision must not be offered or accepted.

❖    Suppliers must implement robust policies to comply with anti-bribery, anti-corruption (e.g., FCPA, UK Bribery Act), anti-money laundering, and competition laws and ensure that all their dealings are fair, ethical, free of corrupt practices and in full compliance of laws

❖    Suppliers must at all times refrain from soliciting, accepting, or agreeing to accept any bribe, gift, or inducement that could be perceived as influencing their judgment or actions in favor of a third party.

❖    Suppliers must refrain from any “facilitation payments” or “grease payments,” which are small payments or gifts made to secure or speed up routine government actions.

❖    Suppliers shall ensure that ensure that all financial transactions are accurately and transparently recorded in their books and records, reflecting the true nature of the transaction.

❖    Suppliers shall ensure that all charitable donations and sponsorships must be legitimate, properly documented, and not used as a disguise for bribery.

❖    Suppliers shall respect internationally recognized human rights as outlined in the Universal Declaration of Human Rights and ILO standards.

❖    Employment shall be freely chosen. Forced, bonded, or indentured labor or involuntary prison labor is strictly prohibited.

❖    Child labor should not be used under any circumstances. Suppliers must verify age and ensure workers meet the minimum legal working age.

❖    Suppliers must treat all workers with dignity and respect, providing a workplace free of harassment, abuse, or coercion.

❖    Wages must meet or exceed legal requirements and paid on time. Overtime must be voluntary and compensated.

❖    Suppliers must support freedom of association and the right to collective bargaining as permitted by local law.

❖    Suppliers must provide a safe and healthy workplace environment in accordance with applicable safety laws and regulations.

❖    Risk assessments should be conducted regularly and appropriate controls implemented to prevent injury, illness, and unsafe exposure.

❖    Emergency response procedures, fire exits, sanitation, ventilation, and access to potable water must be ensured.

❖    Suppliers should have health and wellbeing programs in place, including awareness campaigns, ergonomics, and stress management.

❖    Suppliers must promote a diverse and inclusive work environment, ensuring equal opportunity in recruitment, compensation, promotion, and training.

❖    Discrimination on the basis of race, caste, religion, gender identity, disability, age, sexual orientation, marital status, or political affiliation is prohibited.

❖    Suppliers are encouraged to establish internal Diversity, Equity and Inclusion (DEI) policies and promote digital accessibility and inclusive language in all materials

❖    Suppliers shall actively work to reduce their environmental footprint and implement sustainable business practices.

❖    They must comply with all applicable environmental laws and aim to minimize waste, energy use, emissions, and resource consumption.

❖    Suppliers should track and report their environmental performance, particularly on greenhouse gas emissions, water usage, and biodiversity impacts.

❖    They are encouraged to adopt climate resilience strategies and align with global frameworks.

❖    Suppliers must protect the confidentiality, integrity, and availability of Capillary Technologies’ and its customers’ information.

❖    They must comply with data protection laws (e.g., GDPR, CCPA) and ensure secure collection, processing, transfer, and storage of personal data.

❖    Any breach involving Capillary Technologies data must be reported within 24 hours, with appropriate forensic investigation and mitigation.

❖    Implement appropriate technical and organizational security measures to prevent unauthorized access, loss, or misuse of information

❖    Suppliers should evaluate their platforms against accessibility checklists and conduct periodic accessibility audits

❖    Intellectual property rights of Capillary Technologies must be respected; no unauthorized use, copying, or distribution is permitted.

❖    Suppliers must conduct due diligence to identify and mitigate risks of modern slavery, child labor, conflict minerals, and unsafe labor practices in their supply chains.

❖    Suppliers must ensure their own vendors and subcontractors comply with equivalent ethical, legal, and sustainability standards.

❖    Supply chain transparency should be documented, and Suppliers should take remedial actions if unethical practices are found.

❖    Suppliers must maintain accurate records demonstrating compliance with this Code and provide them with them upon request.

❖    Capillary Technologies reserves the right to audit, inspect, or assess suppliers’ facilities, practices, and policies, with reasonable notice, or request information, participate in surveys, questionnaires at the cost of the Supplier to show compliance with this Code.

❖    Suppliers must cooperate fully with any investigation or assessment and implement corrective actions as needed.

❖     The Processor is required to promptly return all personal data to Capillary Technologies and delete any existing copies within 30 days following the cessation of any services involving the processing of Consumer Personal Data.

❖    The Processor must provide written certification and evidence confirming the deletion of such data within 30 business days of the cessation date.