Partner Code of Conduct

Partner Code of Conduct is a set of guidelines that outlines the ethical and legal standards that Akciju sabiedriba “ELKO Grupa” and its subsidiaries (hereinafter also referred to as “ELKO Group”, or “ELKO” expect from their business partners. The code is designed to promote honest and ethical conduct, ensure compliance with all applicable laws, rules and regulations, in areas of labor practices, human rights, environmental protection, data privacy and product compliance and anti-corruption measures.

In accordance with this Partner Code of conduct, everyone associated with ELKO Group must comply with the standards set out in this code.

Partner Code of Conduct addresses a wide range of topics, however, it is not exhaustive. Where the Partner Code of Conduct sets higher or stricter standards than those required by applicable laws or regulations, the provisions of the Partner Code of Conduct shall prevail.

General Conditions

Partner Code of Conduct applies to all ELKO Group suppliers, distributors, wholesalers, resellers, sales agents and other business partners.

By signing this document, you confirm that you, as a cooperation partner of ELKO Group concern:

• will work in accordance with the requirements set out in the Partner Code of Conduct;
• agree to inform your employees, agents, representatives, subcontractors or other involved third parties of the aforementioned standards of the Partner Code of Conduct and to do your best to ensure that said persons and parties observe and comply with these standards;
• allow ELKO Group or an independent auditor, in accordance with the agreement between ELKO Group and you as a cooperation partner, if there is reason to believe that the Partner Code of Conduct has been violated, to check compliance with the Partner Code of Conduct by implementing appropriate measures, such as audit, assessment, inspection, investigation and/or review measures. ELKO Group will provide prior written notice of the application of such measures unless there is an immediate threat and will implement such measures in a manner that will not affect your normal course of business. Both ELKO Group and you, as a cooperation partner, will pay your expenses related to such events.

As a partner, you acknowledge that adherence to the Partner Code of Conduct is critical to ELKO Group. Failure to comply with them will be considered a serious violation, as a result of which ELKO Group may review your suitability as a cooperation partner at the level of the entire ELKO Group concern.

ELKO Group itself is and expects its cooperation partners to be committed to responsible business and adhere to a number of international declarations, European Union regulations and directives, conventions and guidelines on human rights, labor rights and conditions, environmental responsibility and anti-corruption. These include, but are not limited:

• The United Nations’ Universal Declaration of Human Rights;
• The Core Conventions of the International Labor Organization;
• The OECD Guidelines for Multinational Enterprises;
• The UN Guiding Principles on Business and Human Rights;
• The United Nations Global Compact Principles;
• Children’s Rights and Business Principles;
• European Union regulation relating to product compliance and sustainability.

Labor

Upholding human rights to all employees.

Aligned with the UN Guiding Principles on Business and Human Rights, Partner commits to respect human rights within its business operations. All employees shall be treated with respect and dignity and are entitled to fundamental human rights. In relation therewith, subject to applicable national laws and regulations which may require higher standards than those set forth below (in which case such standard shall apply):

FREE LABOR

Forced, bonded (including debt bondage) or indentured labor, involuntary or exploitative prison labor, slavery or trafficking of persons is not permitted.

CHILD LABOR

Our internal policies and workplace practices are fully compliant with national and international labor laws that strictly prohibit child and forced labor.

BASIC CONDITIONS

Working hours

Working hours are not to exceed the maximum set by local law. All overtime must be voluntary.

Wages and Benefits

According to law (minimum wages, overtime, benefits requested by law). Outsourced labor in accordance to law.
Each employee receives fair and equitable remuneration that corresponds to the work performed, individual performance, qualifications, and the situation in the labor market. Remuneration is determined based on the value of the position (including the level of responsibility, required skills and competencies, and other objective factors), and any form of direct or indirect discrimination in the determination of remuneration is strictly prohibited.
The principle of equal pay is applied regardless of gender, age, nationality, or other personal circumstances.
Remuneration is paid on a regular basis in accordance with a clearly defined schedule, and transparent rules for the calculation of remuneration are ensured. Remuneration is reviewed and evaluated on an annual basis.
Employees are guaranteed remuneration that is not less than the statutory minimum wage established in the respective country. Provide all employees, a living wage, sufficient to meet the basic needs of employees and to provide some discretionary income and when applicable, salary shall be based on criteria set by collective bargaining agreements.

Non-Discrimination

To have a strict nondiscrimination policy established within the hiring process as well as everyday work situations. Everyone should be treated equally regardless of race, sex, gender identification, sexual orientation, national origin, native language, religion, age, disability, marital status, citizenship, genetic information, pregnancy, or any other characteristic protected by law.

Freedom of association

Recognize employees’ right to form freely and to join, or not to join, trade unions or similar employee representative organizations and to collective bargaining.

Not penalize, persecute, discriminate or harass employees when they join a trade union or act as employee representatives.

Maintain an effective and confidential grievance mechanism that facilitates open communication between management and workers, addresses concerns early, openly, and on an informed basis, and encourages employees to use grievance mechanisms without fear of punishment or retribution.

Health and Safety

Aligned with international Occupational Health and Safety standards, Partner commits to provide and maintain a safe and healthy workplace for its employees, visitors, contractors and any subcontractors working on its behalf. In relation therewith, subject to applicable national laws and regulations which may require higher standards than those set forth below (in which case such standard shall apply).

OCCUPATIONAL SAFETY

Health and safety hazards

Address workplace hazards and risks through sufficient and relevant control measures such as appropriate personal protective equipment, as well as prevention and protection devices.

Ensure that employees, visitors, contractors and any subcontractors working on Partner’s behalf have access without any charge to these safety measures and that they are sufficiently trained in how to use them.

Emergency training and awareness

Be able to identify and respond to potential emergency situations by having in place adequate and appropriate measures.

Regularly train employees on emergency planning responsiveness.

Workplace conditions

Aligned with international Occupational Health and Safety standards, Partner commits to provide and maintain a safe and healthy workplace for its employees, visitors, contractors and any subcontractors working on its behalf.

Environment

PERMITS AND REPORTING

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.

HAZARDOUS SUBSTANCES

Chemicals, waste, and other materials posing a hazard to humans or the environment are to be identified, labeled and managed to ensure their safe handling, movement, storage, use, recycling or reuse, and disposal.

WASTE MANAGEMENT

Participants shall implement a systematic approach to identify, manage, reduce, and responsibly dispose of or recycle solid waste (non-hazardous).

RESPONSIBLE SOURCING OF MINERALS

Partners shall adopt a policy and exercise due diligence on the source and chain of custody of the tantalum, tin, tungsten, and gold in the products they manufacture to reasonably assure that they are sourced in a way consistent with the Organization for Economic Co-operation and Development (OECD) Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas or an equivalent and recognized due diligence framework.

Ethics

IP

Intellectual property rights are to be respected, transfer of technology and know-how is to be done in a manner that protects intellectual property rights, and customer and supplier information is to be safeguarded.

PRIVACY

Participants are to commit to protecting the reasonable privacy expectations of personal information of everyone they do business with, including suppliers, customers, consumers, and employees. Participants are to comply with privacy and information security laws and regulatory requirements when personal information is collected, stored, processed, transmitted, and shared.

FAIR PRACTICES

Determination towards fair operating practices includes but is not solely limited to upholding fair business, advertising and competition standards. Participants adhere to a zero-tolerance policy toward any form of bribery, corruption, extortion, or misappropriation.

ANTI-BRIBERY AND CORRUPTION

No form of extortion and bribery, including improper offers for payments to or from individuals performing work for ELKO Group, shall be tolerated. ELKO Group expects Partners to adhere to the highest standard of moral and ethical conduct, to respect local laws and not engage in any form of corrupt practices, including extortion, fraud, or bribery, at a minimum.

DATA PRIVACY

Participants ensure compliance with applicable personal data protection and information security laws and regulatory requirements when collecting, storing, processing, transferring, and sharing personal data.

PRODUCT COMPLIANCE

As a distributor, ELKO represents a key link between suppliers and manufacturers, as well as downstream companies and participants in the supply chain. ELKO places particular importance on the observance of human rights, ethical standards, and environmental considerations throughout the entire supply chain.

ELKO’s primary objective is to ensure fulfillment of our business partners’ requirements by providing the best possible service and outstanding quality, while always assuming full legal responsibility. We rely on trustworthy, long-term, and cooperative partnerships with our customers, suppliers, and service providers.

We ensure that all products distributed by ELKO comply with applicable European Union regulations, directives, and other binding legal requirements, including those related to product safety, labeling, environmental protection, and market surveillance. We actively monitor regulatory developments and implement the necessary measures to guarantee product compliance and availability both within and outside the European Union market.

COMMITMENT TO COMPLY WITH THE PARTNER CODE OF CONDUCT

We hereby confirm that we have received, read, and understood the contents of the ELKO Partner Code of Conduct. We undertake responsibility for ensuring compliance with its provisions and for informing relevant employees about the content of this document.

The Partner Code of Conduct is published on ELKO’s official websites at https://www.elko.lv/ and https://www.elkogroup.com/. We are obliged to monitor updates and amendments to this document and to comply with the latest version.