Supplier Code of Conduct

1. Purpose & Applicability

This Supplier Code of Conduct ("Code") defines the minimum standards Zentish Exim Pvt Ltd ("Company") expects from all suppliers, vendors, contractors, subcontractors, agents, and their personnel ("Suppliers") in connection with the supply of goods and services to the Company and its affiliates. By accepting purchase orders or engaging with the Company, Suppliers acknowledge and agree to comply with this Code.

Suppliers are responsible for ensuring compliance throughout their own supply chains, including subcontractors and sub-suppliers.

2. Legal Compliance

• Comply with all applicable laws, regulations, and regulations in all jurisdictions of operation.
• Maintain all required licenses, permits, and certifications for operations and products.
• Comply with export controls, sanctions, customs, and trade regulations in all jurisdictions.
• Maintain accurate books and records in accordance with applicable accounting standards.

2. Business Ethics & Integrity

• Zero tolerance for corruption, bribery, kickbacks, or facilitation payments.
• No offering or accepting improper payments, gifts, or hospitality to influence business decisions.
• Accurate and transparent business records; no falsification or off-book accounts.
• Fair competition; no price-fixing, bid-rigging, market allocation, or collusion.
• Protect confidential information and intellectual property of the Company and its customers.

3. Human Rights & Labor Practices

• No Forced Labor:Zero tolerance for forced, bonded, indentured, or prison labor. No human trafficking.
• No Child Labor:No employment of persons under the applicable minimum legal working age.
• Freedom of Association:Respect workers' rights to associate freely and bargain collectively.
• Non-Discrimination:Equal opportunity; no discrimination based on race, gender, religion, age, disability, sexual orientation, or other protected characteristics.
• Fair Wages & Benefits:Comply with minimum wage, overtime, and benefit laws; timely payment.
• Working Hours:Comply with legal limits on working hours, overtime, and rest periods.
• Safe & Healthy Workplace:Provide safe, hygienic working conditions; comply with all HSE regulations.

4. Environmental Responsibility

• Comply with all applicable environmental laws, regulations, and permits.
• Minimize waste, emissions, and resource consumption; promote circular economy principles.
• Proper handling, storage, and disposal of hazardous materials and waste.
• Prevent pollution; implement spill prevention and emergency response plans.
• Manage chemicals responsibly per REACH, GHS, and local chemical regulations.
• Monitor and reduce greenhouse gas emissions, energy, and water consumption.

4. Product Quality & Safety

• Products/services must meet all agreed specifications, quality standards, and regulatory requirements.
• Implement robust quality management systems (ISO 9001 or equivalent).
• Provide accurate product documentation (COA, SDS, TDS, specifications) with each shipment.
• Notify the Company immediately of any quality deviations, recalls, or safety concerns.
• Traceability systems for raw materials and finished products.

5. Supply Chain Transparency & Traceability

• Maintain traceability of raw materials to source (mine, farm, plantation, etc.).
• Disclose country of origin for all materials and components.
• No conflict minerals (3TG: tin, tantalum, tungsten, gold) from conflict-affected areas without responsible sourcing.
• Map and disclose sub-suppliers upon request; support supply chain mapping initiatives.

6. Chemical Regulatory Compliance

• Comply with REACH (EU), TSCA (US), and equivalent regulations globally.
• Provide SDS compliant with GHS/CLP for all chemical products.
• Register substances as required; notify SVHC (Substances of Very High Concern) presence >0.1%.
• Comply with biocides, pesticides, and specific chemical regulations as applicable.

7. Anti-Corruption & Anti-Bribery

• Zero tolerance for bribery, kickbacks, or corrupt practices in any form.
• No improper payments to government officials or private parties.
• Accurate books and records; no off-book accounts or falsified documentation.
• Implement adequate procedures to prevent corruption (per UK Bribery Act, US FCPA, India PCA).

8. Data Protection & Information Security

• Protect Company confidential information, trade secrets, and personal data.
• Comply with GDPR, India DPDP Act, and applicable data protection laws.
• Implement appropriate technical and organizational security measures.
• Report data breaches affecting Company data within 24 hours.

9. Monitoring, Audit & Remediation

• Self-assessment questionnaires and documentation requests as requested.
• On-site audits by Company or third-party auditors with reasonable notice.
• Corrective action plans for non-conformities with defined timelines.
• Failure to remediate material breaches may result in contract termination.
• Company reserves the right to terminate for material or persistent non-compliance.

10. Reporting Concerns

Suppliers and their personnel are encouraged to report concerns about violations of this Code, Company policies, or applicable laws through the Company's whistleblower channel:

• Email:compliances@zentish.com
• Web Form:Anonymous Web Form

Good-faith reports are protected from retaliation. Confidentiality maintained to the extent permitted by law.