Origina – Supplier Code of Conduct

 

1. INTRODUCTION

Origina is a global software services provider committed to conducting business with honesty, integrity, and respect for human rights, while also upholding environmental sustainability and supporting local communities. Our relationships with suppliers are built on fairness and transparency, and we view our suppliers as key partners in delivering our services and achieving our goals in a responsible and ethical manner. We expect all suppliers to comply with all applicable laws, regulations, and codes of practice in every country where they operate or do business with us. This expectation is overarching and applies to every section of this Code.

This Supplier Code of Conduct (the “Code”) applies to all suppliers in Origina’s supply chain, including both direct and indirect suppliers, contractors, partners, subcontractors, agents, recruitment agencies, and consultants. Suppliers must ensure that their own subcontractors and related parties are made aware of and adhere to this Code’s principles, and suppliers should inform Origina of any subcontractors they engage for work related to us. We also expect our suppliers to make all reasonable efforts to conduct business in a way that respects internationally recognized human rights norms, such as the United Nations Universal Declaration of Human Rights, the UN Guiding Principles on Business and Human Rights, and the International Labour Organization’s core conventions.

Adherence to this Code is a condition of doing business with Origina. We expect our suppliers to acknowledge and take all reasonable steps to follow this Code as they enter and maintain a business relationship with us. If a supplier identifies any non-compliance with this Code, it must promptly inform Origina and implement corrective actions to address the issues. Origina may monitor supplier compliance and may request periodic self-assessments or audits to verify adherence and support continuous improvement.

 

2. BUSINESS ETHICS

Origina upholds the highest standards of ethics and integrity in our business, and we expect our suppliers to do the same. Suppliers must conduct all business activities in an honest, responsible, and ethical manner in compliance with applicable laws and this Code.

2.1 Data Protection and Information Handling

Suppliers must protect any data or confidential information provided by Origina or its customers, using it responsibly and securely. We expect suppliers to maintain appropriate data protection, privacy, and security measures, including confidentiality safeguards, and to only collect, use, store, and dispose of information as necessary for the agreed purpose. Any personal or sensitive information must be handled in compliance with applicable data protection and privacy laws. Suppliers should have written processes or controls in place to ensure data integrity and security throughout their operations.

2.2 Conflicts of Interest

Suppliers should avoid any actual or potential conflicts of interest in their dealings with Origina. They must disclose any situation in which personal, financial, or other interests may conflict (or appear to conflict) with their duties to Origina. Suppliers shall not engage with Origina employees or representatives in ways that compromise, or seem to compromise, the impartiality and objectivity of business decisions.

2.3 Anti-Bribery and Anti-Corruption

Bribery and corruption in any form will not be tolerated. Suppliers must never offer, promise, give, request, or accept bribes or improper payments (directly or indirectly) to influence business decisions or obtain unfair advantage. This includes any kickbacks, “facilitation” payments, lavish gifts, hospitality, loans, or favours that could be perceived as bribery. All business entertainment, gifts, or hospitality must be appropriate, lawful, and modest, and must comply with all relevant laws and regulations. Suppliers are expected to have adequate internal controls and approval processes to prevent and detect bribery, corruption, or fraudulent activities in their operations. They must also comply with all applicable anti-corruption and anti-bribery laws in the countries where they operate and should report any known or suspected bribery related to Origina as outlined in Section 5 of this Code.

2.4 Tax Compliance

Suppliers must comply with all applicable tax laws and regulations and never participate in or facilitate tax evasion. Suppliers are expected to maintain accurate business and financial records to demonstrate their full compliance with tax obligations and commitment to ethical business conduct.

 

3. HUMAN RIGHTS AND LABOUR STANDARDS

Origina is committed to promoting and protecting human rights throughout our operations and supply chain. We expect our suppliers to uphold the dignity, rights, and fair treatment of all workers. This includes the following key principles:

3.1 Non-Discrimination and Fair Treatment

Suppliers must provide a workplace free of discrimination, abuse, or harassment. All employees should be treated fairly and with respect, without any discrimination based on personal characteristics such as race, age, gender, sexual orientation, ethnicity, disability, religion, or any other protected status. Harassment, bullying, intimidation, or any type of physical, sexual, psychological, or verbal abuse is strictly prohibited, and clear preventative and disciplinary policies and procedures must be maintained.

3.2 No Forced or Child Labour (Prevention of Modern Slavery)

Suppliers shall not use or tolerate any form of modern slavery, including forced, bonded, indentured or involuntary labour, human trafficking, or exploitative prison labour. All work must be voluntary, and workers must have the freedom to leave their employment without penalty, consistent with local laws. Child labour is strictly forbidden and suppliers should have robust age-verification processes in place. If any instance of forced or child labour is identified, suppliers must take immediate remedial action to protect the individuals involved and prevent recurrence.

3.3 Fair Wages and Working Hours

Suppliers must compensate their employees fairly and at least at the legal minimum wage or prevailing industry standard, whichever is higher. Wages should be paid on time and in full to workers (at least monthly) and should be sufficient to meet basic needs where local legal minimums are not adequate. Suppliers must ensure that working hours and rest days comply with local law and relevant international standards (e.g. International Labour Organization conventions). Overtime work should be voluntary and compensated fairly, following local regulations on overtime pay or ILO guidelines.

3.4 Transparent Employment Terms

All workers should be employed under clear and fair written contracts that detail their employment conditions in a language they understand. Suppliers must ensure all workers know their rights, responsibilities, wages, and working conditions. Employment terms should not be unilaterally changed to worsen conditions, and any changes should be communicated to workers in advance and comply with law.

3.5 Freedom of Association and Collective Bargaining

Suppliers shall respect employees’ rights to join or not join trade unions and to engage in collective bargaining where permitted by law. Suppliers must not interfere with or retaliate against workers for organizing or participating in lawful collective activities. In countries where these rights are legally restricted, suppliers should facilitate alternative means for worker representation and dialogue.

3.6 Worker Grievance Mechanisms

Suppliers should provide a safe, confidential, and effective channel for employees to report grievances or concerns without fear of reprisal. Whistleblower confidentiality must be protected, and retaliation against workers who raise concerns in good faith is prohibited. Suppliers must have procedures to investigate and address worker complaints fairly.

3.7 Health and Safety

Suppliers are expected to provide a clean, safe, and healthy work environment for their employees. There should be a designated manager responsible for health and safety compliance, and the supplier must implement reasonable measures to prevent accidents, injuries, and workplace hazards. Suppliers must ensure appropriate safety training for employees and conduct regular risk assessments to identify and mitigate potential hazards, maintaining documented health and safety procedures and making them available upon request. All operations should comply with applicable health and safety laws.

 

4. ENVIRONMENT

Origina is dedicated to reducing the environmental impact of our operations and expects our suppliers to share this commitment. Suppliers must comply with all applicable environmental laws and regulations in the regions where they operate, and should demonstrate care for the environment by identifying and responsibly managing their environmental impacts. We encourage our suppliers to implement measures to minimize energy and water consumption, reduce greenhouse gas emissions, limit waste and pollution, and safely handle hazardous materials, as appropriate to their business. Wherever possible, suppliers should set targets to continuously reduce their environmental footprint (e.g. improving energy efficiency, reducing waste, protecting biodiversity) and track and share progress towards these goals. Suppliers are also encouraged to publicly disclose their environmental commitments and performance where feasible.

 

5. REPORTING CONCERNS

Origina wants an open and honest partnership with its suppliers. If suppliers or their employees have any questions or concerns about complying with this Code or observe any potential misconduct, they should contact their usual Origina representative or raise the issue through designated reporting channels (which may include anonymous reporting avenues). We take such reports seriously and will ensure that any suspected ethical, legal, or Code violations are reviewed and addressed appropriately, with no retaliation against those who report concerns in good faith. Suppliers can also find more information on related Origina Whistleblowing processes through our Whistleblowing policy, a copy of which can be made available upon request.