Supplier Code of Conduct

NNG is a global automotive software supplier on a mission to create the next generation of smart, secure, connected mobility solutions from the cockpit to the cloud. Our vision is to be the trusted industry partner for delivering the future of connected mobility.

While pursuing our mission and vision, sustainability, responsibility, integrity, and respect are our values and we are committed to ensure that the standards reflecting these values are adopted at a minimum by our next tier suppliers and subcontractors, but we strongly encourage implementation at all levels of our supply chain.

This Supplier Code of Conduct (“Code”) highlights standards involving labor relations, health, safety, environment, and ethical conduct that are consistent with the values of NNG and our suppliers are expected to observe and adhere to these standards. All entities supplying goods or services to NNG and thereby becoming an NNG supplier shall be obliged to accept this Code. In case any of the agreed contractual requirements are more detailed or rigorous than those contained in this Code, then the supplier should meet those contractual requirements.

In all its activities, Supplier must operate in full compliance with the laws, rules, and regulations of the countries in which it operates (“applicable law”). The Code also encourages Supplier to go beyond legal compliance, drawing upon internationally recognized standards, to advance social and environmental responsibility and business ethics. In no case can complying with the Code violate applicable laws. If, however, there are differing standards between the Code and applicable law, compliance to the Code is defined as meeting the stricter requirement.

Supplier will support NNG’s implementation of legally required and other due diligence processes by actively participating in related initiatives, including instruments such as self-assessment questionnaires. NNG reserves the right to audit Supplier’s compliance with this Code in an appropriate manner. Any audit will be scheduled at business hours mutually agreed with the Supplier and will be prepared by the Supplier providing documentation substantiating the adherence to this Code.

Supplier’s adherence to this Code, which NNG may amend from time to time, is regarded by NNG as essential for doing business with Suppler. Significant violation of this Code may result in the suspension or termination of the Supplier contract or the business relationship in NNG’s sole discretion.

Supplier and its respective employees as well as stakeholders in general are encouraged to report violations of this Code at compliance@nng.com. Supplier shall support any investigations into alleged violations. Additionally, in line with their own due diligence efforts, Suppliers should provide grievance / complaints mechanisms or support respective sector or country specific non-judicial mechanisms.

A. Labor

Supplier shall ensure that human resources are managed in accordance with internationally recognized principles of corporate responsibility, including the respect of internationally recognized human rights as set forth in the Universal Declaration of Human Rights by the United Nations and standards published by the International Labour Organization (ILO). Supplier shall acknowledge the rights of its employees and treat them with dignity and respect.

Supplier shall be committed to:

· not using nor tolerating the use of all forms of modern slavery (including child-, forced-, obliged-, or undeclared labor and any labor connected to human trafficking);

· not implementing nor tolerating any form of discrimination based on nationality, gender, racial and ethnical origins, religious beliefs, political opinions, age, sexuality, disability or health in recruitment;

· not using nor tolerating any form of discrimination in remuneration policies, access to training, career development, dismissal or staff retirement;

· granting the staff the right to set up and join trade union organisations of their own choice and to hold collective negotiations with the company in line with the rules, practices and cultu­res of the various countries;

· ensuring a safe and healthy working environment and adopting suitable measures to prevent any accident or damage to workers’ health;

· complying with the laws and standards applicable in the relevant business sector on working hours and public holidays;

· the provision of fair remuneration and benefits, at least equivalent to the applicable legal minimum wage;

· providing suitable staff training.

Supplier shall create an environment where employees are comfortable raising concerns, including adequate “whistle-blower” or reporting channels available and feedback processes in place designed to ensure confidentiality and protection for employees and suppliers.

B. Health and Safety

In order to minimize the incidence of work-related injury and illness, as well as enhancing quality, consistency, worker retention and morale, Supplier shall provide its employees with a safe and healthy working environment in compliance with all applicable laws and regulations as well as Part IV of the Occupational Safety and Health Convention of 1981 by the ILO.

Supplier is expected to have effective safety programs covering human safety, emergency preparedness, chemical, physical, and biological agent exposure, ergonomics, which includes incident reporting and investigation.

C. Environment

Suppliers shall minimize the negative impacts their business operations have on the community, environment, and natural resources throughout their supply chain. In particular:

· all required environmental permits (e.g. discharge monitoring), approvals, and registrations are to be obtained, maintained, and kept current and their operational and reporting requirements are to be followed;

· emissions and discharges of pollutants and generation of waste are to be minimized or eliminated;

· the use of natural resources, including water, fossil fuels, minerals, and virgin forest products, is to be conserved by practices such as modifying production, maintenance and facility processes, materials substitution, re-use, conservation, recycling, or other means;

· hazardous substances (chemicals, waste and other materials posing a hazard to humans or the environment) shall be controlled by identifying, labeling and management to ensure safe handling;

· identify, manage, reduce, and responsibly dispose of or recycle solid waste (non-hazardous);

· seek opportunities to conserve water, reduce air pollution;

· look form methods to improve energy efficiency to minimize energy consumption and greenhouse gas emissions.

D. Ethics

Supplier shall conduct business considering the following basic ethical standards throughout its supply chain. Supplier shall

· comply with all applicable laws, rules and regulations in the countries in which it operates and will maintain suitable measures to ensure compliance with such laws, rules and legal regulations;

· comply with all applicable antitrust laws, and any other competition laws, rules and regulations dealing for example with unfair competition and restraints of trade, and relationships with competitors and customers;

· apply a zero-tolerance policy prohibiting all forms of corruption and bribery. Supplier will ensure not to offer, give, receive, or solicit any bribes or other means to obtain any improper benefit or advantage. Do not allow others to make improper payments for your benefit;

· comply with all applicable laws governing the prevention of money laundering and not to participate in any money laundering activity;

· perform all business dealings transparently performed and accurately reflected within its organization. Supplier will choose its business partners carefully and only after conducting a thorough background check;

· respect intellectual property rights at all times. Any transfer of technology and know-how to- and from Supplier should be carried out in a manner that protects intellectual property rights.

· avoid conflicts between itself and NNG by disclosing any personal or outside business arrangements between Supplier company, employees, management, or owners, and NNG, its employees, management, or owners. Under no circumstances shall the personal relations or interests of employees influence the conclusion of a contract, and that no employee can directly or indirectly draw any personal benefit from a contract.

· keep sensitive business information and trade secrets confidential and refrain from looking for confidential data, unless it is explicitly authorized to do so in compliance with the regulations in force. Supplier may not use confidential information for any purpose which is not related to the performance of your duties.

· commit to protecting the reasonable privacy expectations of personal information of everyone you do business with. This includes its suppliers, customers, consumers, and employees. Supplier shall comply with privacy and information security laws and regulatory requirements when personal information is collected, stored, processed, transmitted, or shared.

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