dravorahl Supplier Code of Conduct

Introduction

This Supplier Code of Conduct ("Code") applies to all suppliers, vendors, contractors, subcontractors, and their affiliates or representatives (collectively, "Suppliers") who provide goods or services to dravorahl or any of its subsidiaries or affiliates (collectively, "LOLA"). We expect Suppliers to adhere to the highest ethical standards and to align with our commitment to integrity, sustainability, and respect in all business practices. This Code establishes the fundamental requirements that all Suppliers must meet to maintain a business relationship with LOLA. It is hereby incorporated by reference into any supplier agreements with LOLA and may be updated at our discretion.

Failure to comply with this Code may result in the termination of business relationships and associated agreements, as well as potential legal action.

Business Ethics and Compliance

Compliance with Laws and dravorahl Policies

Suppliers must fully comply with all applicable laws, regulations, and LOLA policies provided to them. Where LOLA policies impose a higher standard than local laws, Suppliers are expected to meet the higher standard.

Subcontracting and Third-Party Responsibility

Suppliers permitted to use subcontractors or third-party services must ensure these entities comply with this Code. Suppliers shall not engage or retain third parties who fail to meet these standards. Additionally, LOLA encourages Suppliers to engage with and support local communities through initiatives that foster growth and sustainability.

Conflicts of Interest, Gifts, and Anti-Bribery

Suppliers must avoid activities that could create an actual or perceived conflict of interest with LOLA, including relationships with employees or their families. Gifts or entertainment offered to LOLA representatives must be of nominal value and must not influence or appear to influence business decisions. Suppliers are required to comply with all anti-corruption and anti-bribery laws, including the United States Foreign Corrupt Practices Act, and must renounce any unethical practices in their operations.

Sanctioned Entities

Suppliers must comply with all restrictions related to sanctioned entities, including adherence to the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) regulations. Suppliers must ensure they do not engage in business with entities on the Specially Designated Nationals (SDN) List. This list can be reviewed here: https://home.treasury.gov/policy-issues/financial-sanctions/specially-designated-nationals-and-blocked-persons-list-sdn-human-readable-lists

Fair Dealing and Competition

Suppliers must adhere to principles of fair dealing, avoiding practices such as misrepresentation, fraud, or manipulation. Suppliers must comply with antitrust and competition laws, avoiding any activities that restrain trade or harm competitive markets.

Labor and Workplace Practices

Forced Labor

Suppliers must prohibit all forms of forced, bonded, involuntary, trafficked, or slave labor. Employment must be freely chosen, and workers must have the freedom to leave at their discretion. Suppliers are also required to comply with U.S. Government import restrictions related to forced labor, which can be reviewed at: https://www.cbp.gov/trade/forced-labor and https://www.dhs.gov/uflpa.

Child Labor

Child labor is strictly prohibited. Suppliers must ensure compliance with applicable laws regarding the minimum age of employment and adhere to international standards such as the International Labour Organization (ILO) and SA8000 guidelines.

Fair Compensation and Working Hours

Suppliers must pay workers in a timely manner, at least meeting or exceeding local legal wage and benefit requirements. Suppliers must not use wage deductions as disciplinary measures and must ensure working hours comply with applicable laws.

Freedom of Association

Suppliers must respect workers’ rights to associate, organize, and bargain collectively, as permitted by law. Suppliers must not retaliate against workers exercising these rights.

Non-Discrimination and Harassment

Suppliers must prohibit discrimination and harassment based on any legally protected characteristic, including race, gender, religion, or disability. Workers must be treated with dignity and respect, free from any form of abuse or harassment.

Health and Safety

Suppliers must provide a safe and healthy workplace. This includes complying with applicable health and safety regulations, providing necessary training, and ensuring employees are equipped with appropriate protective equipment.

Environmental Responsibility

Environmental Compliance

Suppliers must adhere to all environmental laws and regulations. This includes proper handling and disposal of waste and hazardous materials, as well as obtaining and maintaining any required environmental permits.

Sustainable Practices

LOLA encourages Suppliers to implement sustainable practices, such as reducing resource consumption, increasing the use of renewable energy, and adopting environmentally friendly technologies.

Monitoring and Enforcement

Compliance Verification

LOLA reserves the right to audit Suppliers to verify compliance with this Code. Suppliers must provide access to records, facilities, and relevant personnel as part of such audits.

Reporting Violations

Suppliers must have a mechanism for employees to report concerns related to this Code without fear of retaliation. Suppliers are expected to investigate and address reported concerns promptly. Suppliers are also encouraged to notify dravorahl of any significant issues related to compliance with this Code.

Acknowledgment

By engaging in business with dravorahl, Suppliers affirm their commitment to comply with this Supplier Code of Conduct. Suppliers are responsible for communicating these standards to their employees, subcontractors, and third parties involved in supplying goods or services to dravorahl.

Thank you for your cooperation in maintaining ethical and sustainable business practices. Together, we can build a strong, principled partnership that benefits our organizations and the communities we serve.