ECOM AGROINDUSTRIAL CORP.

LIMITED
ECOM Agroindustrial Corp. Limited and its group companies (together, “ECOM”) is committed to conducting its business in an ethical, legal,
environmentally and socially responsible manner. ECOM continuously works to improve the sustainability of its operations. While our policies
ensure that we comply with applicable laws, our actions demonstrate our commitment to invest in protecting the environment, enhancing
traceability and expanding the development of sustainable production programmes. We expect our suppliers to share our commitment to
doing business in a responsible, sustainable and ethical manner and set out below our Supplier Code of Conduct (the “Code”) to which we
expect our Suppliers to act in accordance.
LEGAL & ETHICAL COMPLIANCE ECOM reserves the right to ask for a full supply chain map in order to
ECOM conducts its business in compliance with all applicable laws, facilitate risk assessments and gauge legal, ethical and environmental
rules and regulations including antitrust laws, applicable sanction compliance in the upstream supply chain. Our suppliers will be
regimes and is not engaged in bribery, corruption, money laundering transparent about all known farms/coops/buying stations used to
or other fraudulent practices. We expect the same from our Suppliers source goods for us and provide such information upon request.
and a Supplier must have in place policies and procedures to ensure Sustainability: We are committed to improving the quality of our
such compliance. farmers’ yields, quality of product and, in turn, their income. Every
HUMAN RIGHTS & LABOUR local market is different, but where possible this will include:
(i) engaging with farmers directly and through farmer organisations;
Child labour and modern slavery: We are committed to acting
(ii) training to improve agricultural practices, resulting in better farm
ethically and with integrity in all our business relationships and to
management, yields and quality; (iii) certification to enable trade in
implementing and enforcing effective systems and controls to ensure
higher value markets; (iv) access to better inputs and credit; and
slavery and human trafficking are not taking place anywhere in our
(v) access to better genetics and technologies. We expect our
supply chains or in any part of our business. We adhere to local laws
Suppliers to engage in and be supportive of such sustainability
regarding minimum employment age and do not employ children
practices. Continuous improvement: We recognise that achieving
who are under the local minimum school leaving age. We expect the
the requirements of this Code is a dynamic process and we encourage
same approach from our Suppliers and that a Supplier complies with
continuous improvement within a supplier’s operations. In cases
the (i) United Nations Universal Declaration of Human Rights, (ii) the
where improvement is required, we will support our supplier to
International Labour Organisation core labour standards, convention
establish clear milestones and processes to support their
182 (worst forms of child labour) and 138 (minimum age), (iii)
achievement. Grievance reporting: We encourage and expect our
conventions and (iv) applicable laws governing child labour, slavery,
suppliers to encourage and provide means for their employees to
forced or compulsory labour and human trafficking. Abuse: Under no
report concerns, complaints, or potentially unlawful activities in the
circumstance do we permit the use of violence, harassment or abuse
workplace, with the option to do so anonymously, without threat of
in any of our operations. Our Suppliers should also operate in this
reprisal, intimidation, or harassment. Any report must be treated in
way. Discrimination: It is our policy that no job applicant or employee
confidence. Suppliers must investigate such reports and take
receives less favourable treatment on the grounds of sexual
corrective action if needed and notify ECOM of legal actions,
orientation, age, race, colour, nationality, ethnic origin, religion,
administrative investigations, or prosecutions that may affect their
belief, disability or marital status or is disadvantaged by conditions
performance of any contractual obligations to ECOM, or where such
which cannot be shown to be justifiable. In addition, we are
legal actions could adversely affect a supplier’s or ECOM’s reputation.
committed to granting all workers Freedom of Association so that any
employee who is associated with any collective bargaining or trade ENVIRONMENT
union does not receive less favourable treatment. Our Suppliers We are committed to improving the environments in which we
should also operate in such a non-discriminatory way. Diversity and operate; as a minimum, we expect our Suppliers to comply with
inclusion. Our suppliers are expected to value the dignity of each environmental laws, hold required permits, to strive to improve
employee as a unique person with individual skills and perspectives. environmental practices and minimise the environmental impact of
Suppliers are expected to categorically reject individuals and their operations. Greenhouse gas emissions: Our suppliers will take
ideologies that seek to sow hate, discord, and division based upon an appropriate steps to minimize greenhouse gas (GHG) emissions and
individual’s personal characteristics. Reasonable compensation: We its impact on climate change and air quality. Suppliers should collect
pay and we expect our suppliers to pay reasonable compensation and GHG data, assess and reduce their emissions. Suppliers will provide
benefits that, at a minimum, comply with all applicable laws and documentary evidence of their carbon footprint and their efforts to
regulations. reduce it, if requested. Energy efficiency: Our suppliers will take
HEALTH AND SAFETY appropriate steps to minimize the consumption of energy as well as
put in place energy saving strategies (i.e., use of renewable sources
Our policy is to comply with applicable laws by taking all reasonably
and fuels, fuel-efficient logistics operations). Water management &
practical steps to safeguard the health and safety at work of all our
conservation: Our suppliers will take appropriate steps to minimize
people, and the safety of our customers, suppliers and all others who
their impact on water by: (i) reducing their water consumption; (ii)
are affected by our activities. Our Suppliers should also adhere to
ensuring groundwater quality is maintained; (iii) ensuring discharged
local health and safety laws and work towards safeguarding the
wastewater qualities comply with local regulations and are (where
health and safety of their employees.
possible) improved; and (iv) by supporting water conservation. No
SUPPLY CHAIN RESPONSIBILITY deforestation: Our suppliers will take appropriate steps to ensure
Traceability: By investing in supply chain intelligence, we are their operations do not contribute to deforestation and biodiversity
continuing our on-going commitment to our customers to provide loss. When establishing new operations or expanding existing ones,
fully traceable and sustainable commodities. We expect our Suppliers our suppliers shall obtain all legal approvals and permissions. We also
to have enhanced levels of control and transparency to assist us in expect our suppliers to keep documentary evidence of land use
our commitment to provide traceability throughout the supply chain. history and provide it if requested.

Through supplying ECOM, you confirm that you comply with the above principles. This Supplier Code goes beyond compliance with the law
and aims to advance social and environmental responsibility. We may assess your compliance with this Code at any time we have a business
relationship with you, and any violations of this Code may lead to termination of our business relationship. ECOM will review this Code on a
regular basis and will introduce revisions where necessary or appropriate. Suppliers will always find the most up to date version of the Code
on the ECOM website at http://www.ecomtrading.com.