1. Relationship With Applicable Laws
In addition to complying with the provisions of this Business Partner Code of Conduct of Rokko Holdings Ltd and its related subsidiary company (hereinafter “ROKKO”, “the Company”), the Business Partners shall comply with all local laws and regulations applicable to the Business Partners and its operations.

This ROKKO Business Partner Code of Conduct corresponds to the principles of the Code of Conduct (Version 8.0) of the Responsible Business Alliance (RBA).
Where the requirements of such applicable local laws, regulations, and this document differ or are in conflict, the Business Partners shall comply with the highest standard consistent with applicable local laws and regulations.

2. Fundamental labour Principles and Human Rights
Business Partners shall respect labour principles and human rights as set out in the International Labour Organization’s Core Conventions and Declaration on Fundamental Principles and Rights at Work. This applies to all workers, including direct employees, temporary, migrant, internship, contract, and any other type of workers. Business Partners takes specific steps to make workers aware of their rights and responsibilities

3. Forced Labor
Business Partners shall not employ or use any form of forced, bonded, or compulsory labour, and shall strictly prohibit any form of slavery or human trafficking. Business Partners shall always have written policy in relation to such matters and shall ensure the policy’s effective implementation within its organization. In particular, Business Partners shall establish and implement appropriate systems to ensure that no form of forced, bonded, or compulsory labour, slavery or human trafficking is employed or used within the Business Partners’ operations and its supply chain.

All work must be voluntary, and workers shall be free to leave their employment upon giving reasonable notice. Workers shall not be required to lodge deposits, identity papers, passports, or work permits as a condition of employment.

4. Freedom of Association and the Right to Collective Bargaining
Business Partners shall recognise and respect the right to freedom of association and the right to collective bargaining of its employees and/or workers consistent with local laws and regulations.

Business Partners shall inform workers that they are free to join or not to join a worker’s organisation e.g. trade union of their choice. Their doing so will not result in any negative consequences to them, or retaliation, from Business Partners. Business Partners shall not interfere with the establishment, operation of such workers’ association, and workers’ rights to freely elect their representatives.

5. Child Labour
A child means any person under 15 years of age. The Business Partners shall not employ or use child labour in their business operations.

6. Young Workers
When young workers (age between 15-18) are employed, Business Partners shall ensure they do not work at night and that they are protected against working conditions that are harmful to their health, safety, morals, and development. Business Partners ensures that young workers’ working hours do not affect their attendance at school or any other training or instruction programmes.Prior to actual working, Business Partners seeks to ensure that young workers are properly trained on occupational health and safety.

7. Employment Conditions
Business Partners shall at a minimum comply with local laws and regulations. Workers shall be provided with a written employment contract, voluntarily signed by them, before performing any work at the Business Partner’s facilities that defines the terms and conditions of employment in a language understandable to the workers.

Business Partners shall pay a fair and reasonable wage which shall, at minimum, comply with applicable legal and industry standards. Business Partners shall not use deductions from wages as a disciplinary measure. Business Partners shall ensure that working hours do not exceed the maximum set by local laws and regulations. Further, a work week shall not be more than 60 hours per week, including overtime, except in emergency or unusual situations. All overtime shall be voluntary. Workers shall be given at least one day off every seven days (do no work more than six consecutive days).

8. Non-Discrimination
Business Partners shall promote equality of opportunity and diversity in the workplace, not engage in or support any form of discrimination, including based on race, colour, age, sex, sexual orientation, pregnancy, language, disability, religion, trade union membership, political or other opinions, or social origin.

9. Health And Safety
Business Partners shall provide and maintain a safe and healthy working environment in accordance with applicable local laws, regulations, and internationally recognised standards.

Hazards shall be identified, risk assessed, mitigated, and monitored and the necessary precautionary measures taken to prevent occupational incidents, diseases, and foreseeable emergencies.

Potential emergency situations and events shall be identified and assessed, and their impact minimized by implementing emergency plans and response procedures. Worker exposure to chemical, biological, and physical agents shall be identified, evaluated, and controlled according to the Hierarchy of Controls. Physically demanding tasks of workers shall be identified, evaluated and controlled. Where appropriate, physical guards, interlocks, and barriers shall be provided and properly maintained if machinery presents an injury hazard to workers.

Workers’ right to remove themselves from imminent danger without seeking permission is respected by Business Partners. Appropriate systems are put in place for recording, investigating, report, and implementing learning points from occupational injuries and illnesses. Business Partners shall develop and implement training programme designed to ensure that workers are adequately educated on health and safety issues.

Workers shall be provided with clean toilet facilities, potable water, and sanitary food preparation, storage, and eating facilities in the workplaces. Worker accommodation provided by Business Partners shall meet the basic amenities specified by the relevant authorities.

10. Environment
Business Partners shall take responsibilities towards prevention of environmental pollutions, and climate change, ensure that responsible practices for managing environmental impacts are in place, and encourage the development and adoption of environmentally friendly technologies.

All required environmental permits such as discharge monitoring, approvals and registrations shall be obtained, maintained and kept up-to-date and their operational and reporting requirements are to be followed. Emissions, discharges of pollutants and generation of waste shall be minimized or eliminated at the source. Chemicals, waste, and other materials posing a hazard to humans, or the environment, shall be identified, labelled, and managed to ensure their safe handling, movement, storage, use, recycling or reuse, and disposal. Systematic approach to identify, manage, reduce, and dispose of or recycle solid waste shall be implemented. Air emissions of volatile organic chemicals, aerosols, corrosives, particulates, ozone depleting substances, and combustion by products generated from operations shall be routinely monitored, controlled, and treated as required prior to discharge.

Business Partners shall implement a water management program that monitors water sources, use and discharge, seeks opportunities to conserve water, and prevent contamination to water sources. Energy consumption and all Scope 1, Scope 2 and significant categories of Scope 3 greenhouse gas emissions of Business Partners shall be tracked, documented, and publicly reported. Business Partners shall look for methods to improve energy efficiency and to minimize their energy consumption and greenhouse gas emissions.

11. Materials Restrictions
Business Partners shall adhere to all applicable local laws, regulations, and ROKKO’s requirements regarding the prohibition or restriction of specific substances in products and manufacturing.
Upon request, Business Partners of product-related materials and packaging must show compliance with the EU’s RoHS Directive 2011/65/EU (with amendment 2015/863/EU) for product materials, and Directive 94/62/EC for packaging materials.

12. Responsible Sourcing of Minerals
Business Partners shall adopt a policy and exercise due diligence on the source and chain of custody of tin, tungsten, tantalum, gold and cobalt (3TG+C) in the products they manufacture to reasonably assure that they are sourced in a way consistent with the “OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas”. Business Partners are expected to provide sourcing information of such minerals upon ROKKO’s request.

13. Prohibited Business Practices

· Bribery, Corruption and Fraud

Business Partners shall comply with applicable local laws and regulations concerning bribery, corruption and fraud. Business Partners shall not offer, give, ask for, accept or receive any form of bribe, facilitation payment, or undue or improper advantage, favour or incentive to/from any public official, ROKKO’s employee, or any other third party (either in private or public sector), whether directly or through an intermediary.

· Gifts and business courtesies

The Business Partners shall not, directly or indirectly, offer or give gifts to the company’s employees or representatives or anyone closely related with them. Cash or cash equivalents shall not be offered or given. Hospitality, such as social events, meals or entertainment may be offered if there is a legitimate business purpose involved, and the cost is kept within reasonable limits. Travel expenses for the individual representing ROKKO shall be paid by the Company. Hospitality, expenses, or gifts shall not be offered or given in situations of contract negotiation, bidding, or award. Business Partners shall not, directly, or indirectly, offer or give any gifts or hospitality to any third party, including public officials, to obtain or retain business or a business advantage for ROKKO.

· Anti-Competition

The Business Partners shall always meet competitors honestly and professionally. Business Partners shall not cause or be part of any breach of applicable competition laws and regulations, such as illegal cooperation on pricing and illegal market sharing.

14. Disclosure of Information
Information regarding Business Partners’ labour, health and safety, environmental practices, business activities, finance, and performance shall be accurately recorded and disclosed in accordance with applicable local regulations and prevailing industry practices. Falsification of records or misrepresentation of conditions or practices in the supply chain are unacceptable.

15. Intellectual Property
Intellectual property rights of customers and suppliers shall be respected. Transfer of technology and know-how is to be done in a secure manner that protects intellectual property rights.

16. Persona Data Protection
Business Partners shall commit to protecting the personal data of employee, customers, and suppliers using reasonable information security controls when personal information is collected, stored, processed, transmitted, and shared.

17. Whistleblowing
Business Partners, their employees, contractors, and public are encouraged to report any attempted, suspected, and actual breach of this Business Partner Code of Business Conduct to the following channels:

Email: whistleblow@rokko.net

Whistleblowing reporting could be made with reporter’s identification or anonymously. All reporting received will be treated in confidence and protected from retaliation or victimization.

18. Audit
Business Partners will maintain complete and accurate books and records in relation to the scope of work under contract. These will include corporate records, time sheets, work records, supply records, accounts, receipts, invoices, and other supporting documentation. Business Partners will retain these books and records for at least three (3) years following the period to which they relate.

During the term of this agreement, ROKKO may at any time appoint an auditor (who may be an employee of ROKKO or a third party) to conduct an audit of the books and records of the Business Partners relevant to scope of work under contract. Business Partners will, for the purposes of such audit, provide all reasonable assistance to ROKKO’s auditor.

19. Management Systems Standards
Business Partners shall adopt or establish management systems appropriate to the size, nature and context of their operations, including commitment to respect human rights, environment, due diligence process, and access to remedy for internal and external stakeholders resulted from non-compliance to this Business Partner Code of Conduct.

20. Sub-Business Partners
Business Partners shall incorporate the requirements of this ROKKO’s Business Partner Code of Conduct in any agreements where Business Partners enters into with their external providers (including its contractors, service providers and vendors) in the supply chain.

21. Non-Conformity and Corrective Actions
Business Partners shall take appropriate corrections on non-conformity identified by ROKKO, these shall include investigation of their root causes, determination of correction and corrective actions for the effectively close-out of non-conformity within agreed timeframe with ROKKO.

22. Termination
In the event of any breach by Business Partners of this Business Partner Code of Conduct, ROKKO shall request Business Partners to implement Non-Conformity And Corrective Actions process according to clause 21 of this document, failing which ROKKO shall have the right to terminate the agreement by giving reasonable notice to Business Partners.

Business partners will indemnify ROKKO for any liability or loss suffered by ROKKO due to their breach to this agreement.