Compliance

Supplier Code of Conduct

OroraTech is committed to conducting business with the highest ethical standards, fostering a responsible supply chain, and ensuring compliance with legal and ethical obligations. This Supplier Code of Conduct establishes the fundamental expectations that OroraTech places on its suppliers regarding compliance, human rights, labor standards, business ethics, environmental responsibility, and data protection. 

1. Compliance with Laws and Regulations 

Suppliers must comply with all applicable laws, regulations, and industry standards in the jurisdictions where they operate. This includes, but is not limited to, laws governing labor rights, environmental protection, health and safety, anti-corruption, anti-money laundering, and trade compliance. Suppliers must also ensure their subcontractors adhere to these laws. 

Suppliers are required to notify OroraTech of any significant legal issues or regulatory violations that may impact their business relationship. They must also maintain accurate records, ensuring that all transactions are documented transparently and retained per legal retention requirements. 

2. Human Rights and Employment Practices

Respect for Human Rights

Suppliers must uphold human rights principles as outlined in the Universal Declaration of Human Rights and international labor conventions. They must ensure a working environment that is free from discrimination, harassment, or any form of exploitation.

Child Labor

Suppliers must not employ individuals below the minimum legal working age as defined by local law or International Labour Organization (ILO) standards, whichever is higher. Special protections must be in place for workers under the age of 18 to ensure they are not exposed to hazardous work or excessive working hours.

Forced Labor and Modern Slavery

Suppliers must not use any form of forced, bonded, or indentured labor. Employment must be voluntary, and workers must have the right to leave employment with reasonable notice. Suppliers must not confiscate workers’ identity documents, impose recruitment fees, or use misleading recruitment tactics.

Fair Wages and Working Hours

Suppliers must compensate workers fairly and at least meet the legal minimum wage. Overtime work must be compensated according to legal requirements, and wage deductions must not be used as disciplinary measures. Suppliers should also ensure compliance with maximum working hours and provide workers with regular rest periods and paid leave. 

Diversity, Inclusion, and Non-Discrimination 

Suppliers must provide equal employment opportunities to all employees and applicants, irrespective of race, gender, religion, age, disability, sexual orientation, or any other protected status. Discriminatory practices in hiring, promotion, compensation, or termination are strictly prohibited. 

Health and Safety

Suppliers must provide a safe and healthy workplace and comply with all relevant occupational health and safety regulations. Adequate measures must be taken to prevent workplace hazards, including proper training, protective equipment, and emergency preparedness plans

Substance Abuse 

Suppliers must maintain a workplace free from illegal drug use, possession, or distribution. Employees must not be under the influence of controlled substances while at work. 

Freedom of Association 

Suppliers must respect workers' rights to organize, join labor unions, and engage in collective bargaining in accordance with local laws and international standards. 

3. Integrity and Business Ethics 

Anti-Corruption and Bribery 

Suppliers must comply with anti-corruption laws and avoid all forms of bribery, kickbacks, or improper payments. This includes prohibiting facilitation payments and ensuring that business transactions are conducted transparently and ethically. 

Conflicts of Interest 

Suppliers must disclose any actual or potential conflicts of interest that could impact their business relationship with OroraTech. Employees of suppliers should not engage in business decisions that could benefit them personally at the expense of OroraTech. 

Fair Competition and Anti-Trust 

Suppliers must adhere to fair competition laws and must not engage in price-fixing, bid-rigging, market allocation, or other anti-competitive behavior. 

Gifts, Hospitality, and Business Courtesies 

Suppliers may offer gifts or hospitality only if they are of modest value and comply with applicable laws. Any form of exchange that could influence business decisions or create a perception of undue influence is strictly prohibited. 

Insider Trading 

Suppliers and their personnel must not use non-publicly disclosed information obtained through business dealings with OroraTech to engage in securities trading. 

4. Environmental Responsibility 

Environmental Management 

Suppliers must comply with all environmental regulations and adopt responsible practices to minimize their environmental impact. They should implement systems for reducing emissions, managing waste responsibly, and conserving natural resources. 

Hazardous Substances and Waste Management 

Suppliers must ensure proper handling, storage, and disposal of hazardous materials in accordance with applicable environmental laws. They should strive to reduce hazardous waste and replace harmful substances with safer alternatives where possible. 

Sustainable Resource Use 

Suppliers are encouraged to adopt sustainable practices, including reducing energy and water consumption, promoting circular economy principles, and responsibly sourcing raw materials. 

5. Data Protection and Confidentiality 

Protection of Confidential Information 

Suppliers must safeguard OroraTech’s confidential and proprietary information and prevent unauthorized access, disclosure, or misuse. 

Data Privacy 

Suppliers must comply with all applicable data protection laws, ensuring that personal data is handled securely and only for legitimate business purposes. Any data breaches must be reported promptly. 

6. Global Trade Compliance 

Suppliers must comply with applicable export and import controls, trade sanctions, and embargoes. They must ensure accurate classification, licensing, and documentation of goods and services in cross-border transactions. 

7. Reporting and Compliance Monitoring 

Reporting Violations 

Suppliers must implement grievance mechanisms that allow employees and stakeholders to report ethical concerns or violations without fear of retaliation. OroraTech encourages suppliers to notify the company of any violations related to this Supplier Code of Conduct. 

Audits and Compliance Reviews 

OroraTech reserves the right to audit suppliers to verify compliance with this Supplier Code of Conduct. Suppliers must provide requested information and cooperate fully with any investigations. Non-compliance may result in corrective actions, contract termination, or other consequences. 

8. Quality Assurance 

Suppliers must have quality management systems in place to ensure the delivery of products and services that meet or exceed industry standards. They must prevent the use of counterfeit parts and conduct due diligence to maintain high-quality production and sourcing practices. 

9. Ethics Program Expectations 

Whistleblower Protection 

Suppliers must provide employees with safe and confidential reporting mechanisms for raising ethical concerns. Suppliers must prevent retaliation against whistleblowers and take appropriate action to investigate concerns. 

Consequences of Violations 

Failure to adhere to this Supplier Code of Conduct may result in contract termination, legal action, or other remedial measures at OroraTech’s discretion. 

Right to Audit 

OroraTech reserves the right to periodically review suppliers' business practices to ensure compliance with this Supplier Code of Conduct. Suppliers are expected to comply with reasonable inquiries and cooperate with audits and investigations. 

Acknowledgment and Agreement 

By engaging in business with OroraTech, suppliers acknowledge their commitment to this Supplier Code of Conduct. Suppliers must ensure that their employees, subcontractors, and business partners understand and adhere to these principles.