Supplier Policies
Supplier Policy
Supplier Policy
Last updated: May 2025
1. INTRODUCTION
1.1 Pepwave International Limited (the “Company”), together with its affiliates (collectively, the “Group”), is dedicated to creating lasting value for its shareholders. This dedication relies on the sustainable advancement of our businesses and the communities in which we operate.
1.2 This Policy is designed to ensure that our supply chain aligns with our commitment and describes the minimum standards that the Group expects of its suppliers (as defined below). We believe that by integrating Environmental, Social, and Governance (ESG) considerations into our supplier relationships, we can collectively drive positive change and contribute to a more sustainable and ethical global business environment.
1.3 Furthermore, we are dedicated to ensuring that our suppliers uphold these principles and play an active role in promoting sustainable practices and ethical conduct within their own operations. We expect that any suppliers we work with have a similar policy, and that their suppliers are also guided by similar principles or codes of conduct. Suppliers should be prepared to give us (and those authorised by us) all reasonable assistance required in order to verify compliance with this Policy.
1.4 This Policy is applicable to suppliers, contractors, and subcontractors (collectively, the “Suppliers”) of the Group, and covers the following areas:
- legal and regulatory compliance
- corporate governance and fair business practices
- supply chain management
- labour practices
- confidential information and data privacy
2. LEGAL AND REGULATORY COMPLIANCE
2.1 Compliance with Laws, Rules and Regulations. Suppliers must conduct their activities in full compliance with the laws, rules, and applicable regulations in the respective jurisdictions of their operations. Suppliers must also endeavour to meet applicable environmental and social standards.
3. CORPORATE GOVERNANCE AND FAIR BUSINESS PRACTICES
3.1 Anti-Competition. The Group strictly prohibits Suppliers from engaging in any form of anti-competitive behaviour, including price fixing, bid rigging, market allocation, or other anti-competitive practices. Additionally, Suppliers must refrain from any involvement in insider trading or market manipulation.
3.2 Anti-Corruption. The Group strictly prohibits any form of fraud or bribery, and is committed to their prevention, deterrence, detection, reporting, and investigation.¹ Suppliers must not engage in any form of bribery, corruption, fraud, extortion, kickbacks, and grease payments. Suppliers shall not solicit or accept advantages such as gift, loan, money, hospitality, or entertainment, whether financial or non-financial, that may or may appear to influence decisions in business dealings.
3.3 Anti-Money Laundering & Terrorist Financing. The Group strictly prohibits any involvement in money laundering and terrorist financing activities. Suppliers must not engage in activities that may involve the Group in money laundering and terrorist financing. It is crucial for Suppliers to comply with relevant laws and regulations aimed at preventing money laundering and terrorist financing, and to actively mitigate any risks associated with such activities.
3.4 Conflict of Interest. The Group strictly prohibits Suppliers from engaging in any activity that may lead to a conflict of interest. Suppliers are required to disclose any situation that may appear as a material conflict of interest. They are also expected to disclose to us if any of the Group’s directors, officers, or employees have a material interest of any kind in the Supplier’s business or any kind of economic ties with the Supplier.
3.5 Whistleblowing. Suppliers should report to us any suspicious activity of impropriety, misconduct, or malpractice related to the Group and/or its directors, officers, or employees. One may do so by following the Group’s whistleblowing procedure.² Suppliers should also have in place effective communication mechanisms for staff, including grievance and whistleblowing procedures to handle workplace complaints and concerns.
4. SUPPLY CHAIN MANAGEMENT
4.1 The Group is committed to the responsible and ethical sourcing of materials and services used in our products. We will have a strong preference for Suppliers whose goods or services can make a significant difference in reducing our environmental impact.
4.2 Sustainable Development. Suppliers should have in place policies intended to ensure the sustainable development of their businesses. The policies should cover climate, water, waste, people, communities, and other sustainability matters relevant to their businesses.
4.3 Environmental Impact. Suppliers should identify the environmental impact associated with their operations and take measures to control any negative impacts. Suppliers must apply for and obtain all necessary environmental registrations, approvals, and permits/licences that remain valid during operations.
4.4 Waste Control. Suppliers shall observe proper consideration for safety and environmental impact in handling, transportation, storage, as well as disposal methods of hazardous materials, chemicals, and waste. They should seek to reduce (or eliminate) and should deal appropriately with all waste, in particular hazardous waste and wastewater generated within their own operations.
4.5 Conflict Minerals. The Group expects its Suppliers to undertake due diligence to ensure that any minerals used in the products they supply to us are sourced from responsible supply chains. We may ask our Suppliers to provide information on the origin of the materials they supply to us and conflict minerals survey(s) in conformance with the IPC-1755 standard (or such standard the Group may designate).
5. LABOUR PRACTICES
5.1 Labour Practices. The Group strives to provide a safe and healthful work environment for our employees, and we seek to work with Suppliers that also prioritise their employees’ health and safety. The Group adopts a zero-tolerance approach towards slavery (including child labour, forced labour, and human trafficking) and expects all our Suppliers to do the same.
5.2 Working Conditions. Suppliers must ensure that their employees receive just compensation and benefits in accordance with relevant laws and regulations. Additionally, Suppliers should guarantee their employees reasonable working hours and adequate time off in compliance with applicable laws and regulations.
5.3 Occupational Health and Safety. Suppliers should:-
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a. follow applicable health and safety laws and regulations;
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b. provide their employees with a safe and hygienic workplace, including facilities and amenities such as potable water, sanitary facilities, fire safety, ventilation, and lighting that meet the legal requirements of a healthy and safe workplace;
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c. identify, monitor, and control associated hazards;
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d. provide their employees with regular training and adequate resources; and
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e. promote a strong safety culture within their organisation.
5.4 Equal Opportunities. Suppliers should ensure a discrimination and harassment-free workplace. Suppliers must not discriminate or tolerate discrimination of any kind, including but not limited to those based on age, gender, sexual orientation, relationship, family status, disability, race, ethnicity, nationality, political opinions, or religious beliefs. Suppliers are encouraged to embrace diversity and nurture upward social mobility among vulnerable groups.
5.5 Child Labour. Suppliers must not employ any person:-
- a. in a manner which conflicts with completion of their compulsory schooling;
- b. below the age of 16 years (or the legal age of employment in the countries in which they are employed, whichever is higher) on a full-time basis; or
- c. in hazardous conditions unless they are employed via recognized apprenticeship programmes.
5.6 Forced Labour. Suppliers must not employ or tolerate forced labour, including prison, indentured, bonded, military, or slave labour. Physical punishment, threats of violence, or other forms of physical, sexual, or psychological abuse must not be employed as a means of enforcing discipline or control in the workplace. All statutory and contractual entitlements should be honoured.
5.7 Human Trafficking. Suppliers must not engage in any form of human trafficking, including recruitment, transportation, transfer, harbouring, or receipt of persons through threat or use of force, coercion, abduction, fraud, deception, abuse of power or vulnerability, or giving payments or benefits to a person in control of the victim.
5.8 Industry Relations. Suppliers should respect their employees’ right to join, form, or not join labour unions in accordance with local law without fear of reprisal, intimidation, or harassment. Suppliers should comply with applicable laws and regulations relating to freedom of association.
6. CONFIDENTIAL INFORMATION AND DATA PRIVACY
6.1 Confidential Information. Ensuring the security and confidentiality of our business information is paramount. With this in mind, we require that Suppliers refrain from disclosing confidential information regarding the Group’s business without our prior written consent. It is essential for Suppliers to establish their own policies and procedures to prevent unauthorised leakage of any confidential information.
6.2 Data Privacy. The Group takes data privacy and security seriously. Suppliers are expected to protect the privacy of any personal data they handle and adhere to the highest standards of data protection when handling any personal or user data they obtain in the course of their business relationship with the Group. This includes, but is not limited to, maintaining strict confidentiality, implementing appropriate security measures, and complying with all relevant data protection laws and regulations. Any use of personal or user data obtained must be solely for the purposes of their supply of services or goods to us, and it must not be shared with third parties without explicit consent from us.
6.3 Intellectual Property Rights. The Group expects all Suppliers to recognize and respect the intellectual property rights of the Group and other owners with regard to their trademarks, service marks, logos, copyrights, trade secrets, designs, inventions, and patents. It is imperative that Suppliers uphold these rights and refrain from any unauthorised use or infringement of intellectual property belonging to us or other entities.
7. COMPLIANCE AND AUDITING
7.1 Suppliers shall identify, monitor, and rectify any activities that have fallen below the standard of this Policy as soon as possible. The Group will monitor compliance with this Policy and reserves the right to conduct audits of Suppliers. Suppliers and contractors are expected to cooperate with the Group in any such audit.
7.2 Any failure to comply with these expectations may result in the Group requiring the Suppliers to carry out remedial actions and/or a reassessment of our business relationship, which could lead to the termination of our engagement with the non-compliant Supplier.
8. FINAL REMARKS
8.1 The Group will review this Policy from time to time in accordance with its corporate strategies and development on governance issues relating to its operations. Questions in relation to this Policy should be directed to the Group’s compliance team at [email protected].
Remarks
- See also our Anti-Corruption Policy.
- Anyone who intends to lodge a report may do so by writing to the Group’s compliance team by email at [email protected]. Please refer to our Whistleblowing Policy for more details.