Windcave Code of Conduct for Suppliers



1. Introduction

1.1. Windcave is committed to conducting business ethically, responsibly and in compliance with applicable laws and international standards.

1.2. This Supplier Code of Conduct ("Code") sets out the minimum standards that suppliers must meet when doing business with Windcave. Suppliers are responsible for ensuring compliance with this Code throughout their supply chain.


2. Compliance with laws and regulations

2.1. Suppliers must comply with all applicable laws, regulations and regulatory requirements in the countries in which they operate and maintain appropriate policies, procedures and controls to ensure ongoing compliance.

2.2. Where local laws and this Code address the same subject, the higher standard shall apply.


3. Human rights, labour standards and modern slavery

3.1. Suppliers must respect internationally recognised human rights, including the principles set out in the UN Guiding Principles on Business and Human Rights and the International Labour Organization (ILO) core conventions.

3.2. Without limiting the generality of clause 3.1, suppliers must:

3.2.1. take reasonable steps to identify, prevent and mitigate modern slavery risks in their operations and supply chains;

3.2.2. maintain policies and procedures addressing modern slavery risks; and

3.2.3. cooperate with Windcave in connection with any modern slavery reporting obligations under relevant laws.

3.3. Suppliers must provide its staff wages, benefits and working hours in accordance with applicable law and provide a safe and healthy workplace.


4. Ethical business conduct

4.1. Windcave adheres to ethical standards and behaviour throughout the organisation by complying with our internal policies. Suppliers are also expected to conduct business with integrity and must not engage in bribery, corruption, fraud, money laundering or sanctions breaches, or anti competitive behaviour or collusion.

4.2. Suppliers must promptly disclose any actual or potential conflicts of interest relating to their relationship with Windcave.


5. Data security

5.1. Windcave is committed to data security. We use a variety of technologies and adhere to a broad range of security standards to protect sensitive information from unauthorised access, use or disclosure.

5.2. We expect our Suppliers to have adequate data privacy and security protection to protect against any unauthorised access, use and disclosure of personal information.


6. Environmental responsibility

6.1. Windcave aims to minimise the environmental impacts of our operations. Suppliers are also expected to minimise environmental impacts where reasonably practicable and support responsible resource use, waste reduction and emissions management.


7. Audit and remediation

7.1. Windcave reserves the right to request Suppliers to provide reasonable information or certifications to verify compliance with this Code.

7.2. If a Supplier fails to comply with this Code, Windcave may suspend engagement while issues are remediated or terminate the relationship for material or repeated non compliance.