Code of Conduct

+ CONDUCT

Code of Conduct Policy

Ulundi, LLC and each of its affiliates and subsidiaries (“Ulundi”) are firmly committed to conducting business with the highest integrity and in compliance with all applicable laws. Ulundi expects that all partners, vendors, suppliers, sub-suppliers, contractors, consultants, and each of their respective employees and any other third parties involved with the execution of Ulundi work (“Partners”) will, at a minimum, comply with the standards of business conduct consistent with those in this Code of Conduct (“Code”).

This Code of Conduct Policy is not a modification of any partner agreement. It is subject to updating and modification at Ulundi's sole discretion.

+ Ethics

Business Integrity - Partners will uphold the highest standards of ethics to promote honesty and integrity in business operations. Partners are expected to prohibit all forms of bribery, corruption, extortion, and embezzlement. Partners shall not engage in any activity to obtain an unfair or improper advantage. Partners shall abide by all applicable anti-corruption laws and regulations of the countries in which they operate (for example, the United States Foreign Corrupt Practices Act (FCPA) and applicable international anti-corruption laws.

Gifts and Entertainment - Gifts should be infrequent and not substantial in value. Gifts to Ulundi employees who violate Ulundi policies will be returned to Partners or handled in a manner that complies with our internal policies.

Anti-Corruption and Bribery - Partners shall not offer or accept bribes. Partners are responsible for overseeing the conduct of their subcontractors and ensuring that applicable laws are not violated.

Payment to Government Officials, State-Owned Entities, or Candidates for Political Office - In dealing with government employees and officials, Partners should not give or offer, either directly or indirectly, any gratuity, gift, favor, entertainment, loan, or anything of monetary value.

Antitrust - Partners are expected to conduct their business in line with fair competition and in accordance with all applicable anti-trust laws.

Reporting and Disclosure of Information - Partners shall accurately record information regarding their business activities, labor, health and safety, and environmental practices, and shall disclose such information without falsification or misrepresentation to all appropriate parties.

Logistics and Trade Compliance - Partners shall comply with sanctions-related requirements as governed by applicable laws and regulations.

Counterfeit, Fraudulent, and Suspect Items - Partners shall maintain processes and standards that are designed to assure the integrity of each shipment to Ulundi from its origin through to its destination and all points in between, including taking measures to ensure the corresponding know-how does not end up in the hands of counterfeiters or third parties.

Confidentiality - Partners may not use, disclose, or retain confidential or proprietary information about Ulundi or third parties (including Ulundi's clients or partners) obtained in the course of their business dealings with Ulundi except as allowed by contract provision.

Data Privacy and Information Security - Partners must follow all applicable data protection, privacy, and information security laws in the countries in which they operate and be committed to respecting and protecting the privacy of individuals (including, without limitation, Ulundi clients, Ulundi employees, or other Partners).

+ Safety

Working Environment - Partners shall provide a safe and healthy working environment to prevent accidents, illness, and injury to health from happening in the workplace. Partners shall minimize employee exposure to potential safety hazards.

+ Labor

Anti-Discrimination and Harassment - Ulundi is committed to offering equal employment opportunities, treating individuals fairly, and maintaining a work environment free of discrimination, harassment, and intimidation, and employees are expected to avoid conduct that could be interpreted as such. Ulundi expects its partners to have this same commitment and treat individuals without regard to their race, color, religion, sex, age, national origin, veteran status, physical or mental disability, marital status, ancestry, citizenship, pregnancy, sexual orientation, gender identity, genetic information, other protected activities, or any other characteristic protected by federal, state, or local laws (“protected characteristics”).

Ulundi is also dedicated to providing a work environment free from offensive conduct directed at any individual’s protected characteristics. Offensive conduct and/or harassment that affects tangible job benefits interferes unreasonably with an individual’s work performance, violates federal, state, or local laws, or creates an intimidating, hostile, or offensive working environment, which will not be tolerated. (Review our Zero Tolerance Policy)

Anti-Slavery, Human Trafficking, and Child Labor - Partners shall ensure that all work performed is voluntary. Partners shall not traffic persons or use any form of slave, forced, bonded, indentured, or prison labor. Involuntary labor includes the transportation, harboring, recruitment, transfer, receipt, or employment of persons by means of threat, force, coercion, abduction, fraud, or payments to any person having control over another person for exploitation. Partners shall ensure that the third-party recruitment agencies they use are compliant with the provisions of this Code and the law. Partners recruiting foreign contract workers either directly or through third-party agencies shall be responsible for the payment of all recruitment-related fees and expenses. Ulundi does not accept or approve the use of child labor.

Partners shall not make use of child labor and take the appropriate measures to ensure that no child labor occurs at their own place of operation or at their subcontractor’s place of operation. (Review our Modern Slavery Act Policy)

Partner Diversity, Equity, and Inclusion - We recognize that the markets in which we operate are multicultural and diverse. In turn, we must support diverse business enterprises within our communities. Expanding the diversity of suppliers in our supply chain is an important part of our procurement strategy. We understand the value of an inclusive supply chain that includes small and local enterprises and other diverse businesses reflective of the communities we serve. We look to our supply chain partners to implement similar strategies in their business.

+ Environmental

Environmental Permits - Partners shall obtain, keep current, and comply with all required environmental permits and regulations. Waste and recycling partners shall participate in the Ulundi Partner Review Program.

Sustainability - Partners shall minimize adverse effects on the community and environment to safeguard the health and safety of the public and shall be able to provide related information when requested. Partners will seek opportunities that promote the efficient use of resources and energy, as well as clean and low-energy solutions. The partner will practice responsible sourcing of the minerals tin, tantalum, tungsten, and gold (3TG). Because of this potential for association with conflict and human rights abuses, Ulundi strives to ensure that our supply chains are ethical and sustainable and that we are fulfilling our commitment to respect human rights through responsible sourcing practices.

+ Import & Export Control

Partners shall comply with the import and export, re-export, and sanctions laws, directives, and regulations of the United States of America, and of any other applicable jurisdiction or country (to the extent not in conflict with the laws of the United States of America). The partner shall not acquire any goods or services if any law, regulation, directive, or other government action of the United States or any other applicable country would prohibit such a transaction. This includes, but is not limited to, a prohibition on the supply of goods or services that originate in a country that is subject to a U.S. economic embargo, or that are supplied by a person that is a listed or blocked person or entity under any U.S., UN, EU, or other applicable embargo or sanctions program. Partners shall provide truthful and accurate information for reporting purposes when requested and obtain import and/or export licenses and/or consents where necessary. (View current US Trade Sanctions)