Supplier Code of Conduct

Bamboozle Web Services Inc. (including its subsidiaries, the "Company") is committed to conducting business in a legal, ethical, transparent, and professional manner. The Company expects the highest ethical conduct from its employees and partners. Accordingly, we expect that our Suppliers will share and embrace the letter, values, and spirit of our business practices, including those set forth in this Supplier Code of Conduct.

Purpose and Introduction

It is essential that employees of the Company always conduct themselves with integrity, and in full compliance with the laws and regulations that govern the Company's global business. To that end, the Company has established and adheres to a Code of Business Conduct and Ethics, which contains general guidelines applicable to all the Company's directors, officers, employees, contractors, vendors, and agents for conducting business consistent with the highest ethical standards.

It is the Company's expectation that its Suppliers will share this commitment to integrity. The Company understands that its Suppliers are independent entities, but the business practices and actions of a Supplier may reflect upon the Company's reputation and brand. As a result, it is the expectation of the Company that its Suppliers and their suppliers, employees, agents, and subcontractors adhere to this Supplier Code of Conduct and all referenced declarations, principles, and conventions while conducting business with and on behalf of the Company.

All Suppliers should educate their directors, officers, employees, contractors, agents, and representatives to ensure they understand and comply with this Supplier Code of Conduct. This Supplier Code of Conduct supersedes and replaces any previous versions.

Core Company Principles

The Company expects the highest standards of behavior from its employees and those with whom it does business. By becoming a Supplier of the Company, you are stating that you share the Company's core principles.

We believe in transparency, fairness, and accountability in all our business dealings. Upholding respect for human rights, promoting diversity and inclusion, and fostering a safe and healthy working environment are not just initiatives, but integral components of how we operate. Our company is dedicated to innovation, sustainability, and continuous improvement, aiming to leave a positive impact on society and the environment.

Legal Compliance

The Company requires all Suppliers and their representatives to conduct business activities in full compliance with all applicable laws and regulations. This includes compliance with local, national, and international laws, trade regulations, environmental regulations, labor laws, and data protection laws. Suppliers are expected to stay informed about any changes in laws or regulations that may affect their operations and promptly adapt their practices to remain compliant.

All Suppliers shall, without limitation:

• Anti-Corruption: Comply with all applicable anti-bribery and anti-corruption laws, including the U.S. Foreign Corrupt Practices Act and the U.K. Bribery Act, refraining from making or receiving any illegal payments or promises of payments to obtain or retain business advantage.
• Antitrust and Fair Competition: Conduct business in full compliance with all applicable antitrust and fair competition laws, refraining from price-fixing, market allocation, or any other anti-competitive conduct.
• Data and Record Retention: Create, retain, and dispose of business records in full compliance with all applicable legal and regulatory requirements.
• Employment Practices: Conduct employment practices in compliance with all applicable laws, including respecting the rights of employees to associate freely, join labor unions, seek representation, and engage in collective bargaining.
• Environmental Regulations: Comply with all applicable environmental laws and regulations regarding hazardous materials, air emissions, waste, and wastewater discharges.
• Health and Safety: Comply with all applicable health and safety laws and regulations, providing a safe working environment for employees.
• Insider Trading: Not engage in or support insider trading by buying or selling securities while in possession of material nonpublic information.
• International Trade and Sanctions: Comply with all applicable international trade and sanctions laws, including trade embargoes, export controls, and sanctions imposed by relevant international bodies.
• Permits and Licenses: Obtain and maintain all necessary permits and licenses required to conduct their activities for the Company.
• Privacy and Data Protection: Comply with all laws and regulations regarding the privacy of information and data protection, handling confidential data responsibly and ensuring its protection from unauthorized access, disclosure, or misuse.
• Transparent Communications: Be transparent and honest in discussions with regulatory agency representatives, auditors, and government officials.

Labor and Human Rights

The Company is committed to developing an organizational culture with policies that support internationally recognized human rights and seeks to avoid complicity in human rights abuses. We support the principles contained within the United Nations Guiding Principles on Business and Human Rights, the Universal Declaration of Human Rights, the Global Network Initiative Principles, and the International Labour Organization's Declaration on Fundamental Principles and Rights at Work.

• Equal Treatment and Dignity: All individuals must be treated equitably, with respect and without discrimination. The Company prohibits the use of forced labor in any form. No person below the age of 15, or below the mandatory education completion age, is to be employed.
• Protection from Discrimination and Harassment: All employees, agents, and representatives are to be treated with respect and dignity, free from unlawful harassment or discrimination of any kind.
• Voluntary Employment: Employment must be voluntary, with zero tolerance for any forced labor, servitude, slavery, or human trafficking.
• Fair Compensation and Reasonable Working Hours: Suppliers shall ensure that their representatives receive fair compensation that complies with legal standards or industry norms. Working hours may not exceed the maximum limits established by applicable law.

Health and Safety

In addition to complying with applicable legal and regulatory requirements, the Company requires Suppliers to ensure a safe work environment and minimize hazards through effective design, engineering and administrative controls, preventative maintenance, and safe work procedures. Suppliers are also expected to provide continuous safety training, conduct audits, and take corrective actions as applicable to the services or products they provide.

Sustainability and Environmental Impact

The Company is committed to preventing adverse environmental impact and harm to the communities where it operates. Suppliers must comply with all applicable laws, regulations, and Company standards concerning sustainability and environmental norms. The Company encourages its Suppliers to consider and implement processes designed to mitigate their environmental impact, including measures to reduce energy consumption, air pollution, water use, biodiversity impacts, and waste generation.

Suppliers are requested to quantify the carbon footprint of their products and services provided to the Company and to make that data available upon request.

Management and Oversight

Audits and Supplier Operating Effectiveness

The Company expects its Suppliers to make available, upon request, a copy of any audit that has been performed on the controls and operating effectiveness of the Supplier. The Company additionally reserves the right to conduct audits to assess Supplier compliance with this Supplier Code of Conduct.

Training and Compliance

Suppliers must provide comprehensive training to their employees on the principles and requirements outlined in this Code of Conduct. Regular training sessions should be conducted to ensure ongoing compliance. It is the responsibility of the Supplier to ensure its employees and representatives understand and comply with this Supplier Code of Conduct.

Reporting and Investigations

The Company will address any reports in compliance with applicable laws and, when appropriate, shall conduct thorough investigations regarding reported conduct. Suppliers are expected to fully cooperate in these investigations and provide access to any information reasonably requested by the Company. Where remediation is required, the Supplier will be expected to implement a corrective action plan and timeline to resolve the failure effectively and promptly.

No Third-Party Rights

This Supplier Code of Conduct does not confer, nor shall it be deemed to confer, any rights on the part of third parties, including any third-party beneficiary rights. No employees of any Supplier shall have any rights against the Company by virtue of this Supplier Code of Conduct.

Contact Us

For questions about this Supplier Code of Conduct, please contact us at [email protected].