Supplier code of conduct al pack limited liability company , SuboticaAdopted on the 6th of July 2021

I. ESG Statement

Al Pack liability company, with registered seat in Subotica, St. Tolminska no. 14, registration no. 08587574 (hereinafter referred to as “Al Pack ”), has had its own expansive business flow for more than 25 years, in which it gradually developed its infrastructure, technology and professional staff. Al Pack was established to manufacture aluminium packaging, such as lids, containers, lacquered and laminated aluminium foil, and labels. The company orients its business politics towards the individual needs of its customers, from tailored offers to custommade product development.

Al Pack is committed to advancing the highest standards for human rights, social and environmental responsibility and ethics in its governance and therefore expects that its suppliers are committed to the same philosophy and governance.

The Supplier Code of Conduct (hereinafter: Code) is an expression of our principles and values and it is intended for all our supply chain partners on how to fulfil our vision. The Code is of utmost importance to our corporate governance strategy.

The Supplier Code of Conduct is based on the principles of the Serbian Labor Law, Occupational Safety and Health Law, ILO Basic Terms and Conditions of Employment, ILO Declaration on Fundamental Principles and Rights at Work, European Convention on Human Rights.

II. Application

This Code applies to all suppliers, contractors and sub-contractors of goods and services (hereinafter referred to collectively as “Suppliers”).

III. Responsibilities and sanctions

Suppliers shall observe the provisions of this Code and shall ensure that their operations are not only in full compliance with applicable laws and regulations, but that they also adhere to the internationally recognized sustainability standards listed in the Policy Statement section above. If there are discrepancies between national laws and the terms of the Code, Suppliers must adhere to the higher requirements.

This Code sets specific conditions to evaluate the social, environmental and ethical performance of our Suppliers and their value chain. Al Pack may at any time demand that Suppliers complete self-assessments and reserves the right to conduct audits on Suppliers and their value chain regarding compliance to the Supplier Code of Conduct and any agreed upon corrective action plan.

Suppliers are responsible for ensuring compliance throughout their own value chain. In case of non-compliance, including withholding audit rights or failing to meet any agreed upon commitment, Al Pack reserves the right to terminate the contract immediately withholding the right to claim damages and/or to initiate a procedure at competent authorities in order to establish any responsibility for wrong doing.

IV. Labor and human rights

Al Pack acknowledges potential and real risks related to labor, human rights and occupational health and safety issues associated with the aluminium packaging manufacturing sector. Al Pack s’s responsibility is to identify, prevent, mitigate and address these risks throughout our supply chain.

1. Freedom of Association and the Right to Collective Bargaining

Suppliers shall respect the basic right of employees to freely and without interference or retaliation establish and join unions or employee representation and collectively bargain.

2. Forced Labour

Suppliers shall ensure that they do not engage in any form of forced, bonded, compulsory, trafficked, modern slavery or non-voluntary labour.

Suppliers shall provide all employees with a written contract, that clearly conveys the conditions of the employment in a language understood by them and shall provide for their social insurance in the cases defined by the law. Suppliers shall only employ workers who are legally entitled to work in the country. Supplier shall not impose unreasonable restrictions on movement within the workplace or upon entering or exiting company-provided facilities. Suppliers shall not withhold employee’s original identification or travel documents.

Workers shall never be required to pay the Supplier or agent a fee or cost for uniforms, personal protective equipment of other expenses need for employment. If such fees are found to have been paid by workers, such fees shall be repaid to the worker.

3. Child labour and young workers

Child labour is not tolerated in any form. Suppliers shall not directly or indirectly employ children below the minimum age of 15, unless exceptions under ILO Minimum Age Convention No. 138 Article 6-7 apply. Suppliers should have a child labour policy and a plan for remediation if applicable. If a child is found working at a site associated with a Supplier, all remedial actions taken must be in the best interest of the child. It is of the highest importance to always protect children from being forced into harmful work.

Supplier may employ young workers who are older than the applicable legal minimum age but younger than 18 years of age, provided they do not perform work that might jeopardize their health or safety, consistent with ILO Minimum Age Convention No. 138. Suppliers shall not require juvenile workers to work overtime or perform nighttime work.

4. Wages and benefits

Suppliers shall pay wages and benefits at a minimum according applicable laws, industry standards and relevant collective agreements, whichever is highest. The level of wages shall reflect the level of skills and qualifications of regular working time regardless of gender. Overtime should be paid according to local regulation. Suppliers shall pay accurate wages in a timely manner, and wage deductions shall not be used as a disciplinary measure.

5. Non-Discrimination

Suppliers shall not discriminate based on race, color, age, gender, sexual orientation, gender identity and expression, ethnicity or national origin, disability, pregnancy, religion, political affiliation, union membership, covered veteran status, protected genetic information or marital status in hiring and employment practices unless such distinction is required by local law.

6. Working hours

Suppliers shall ensure that a regular working week is in accordance with the provisions of ILO 1 Hours of Work Convention. Overtime should be voluntary and be restricted to the specifications defined in ILO conventions. Supplier must give breaks, annual paid leave and one day off every week unless collective agreement defines exceptions.

7. Harassment and mobbing

The employees shall be treated with full respect of their dignity.

There shall be no harsh and inhumane treatment including any sexual harassment, sexual abuse, corporal punishment, mental or physical coercion or verbal abuse of workers, nor the threat of any such treatment.

V. Health and safety

1. Occupational Health and Safety Management

Suppliers shall obtain, keep current, and comply with all required health and safety regulations. Suppliers shall provide and maintain a safe work environment and integrate sound health and safety management practices into their business. Workers shall have the right to refuse unsafe work and to report unhealthy working conditions.

Suppliers shall identify, evaluate, and manage occupational health and safety hazards through a prioritized process of hazard elimination, substitution, engineering controls, administrative controls, and/or personal protective equipment.

Suppliers shall provide a safe and healthy environment in order to prevent workplace accidents and injuries. Occupational exposure to potential safety hazards and emergency situations shall be controlled through proper design, risk assessment, engineering controls, safe work procedures, emergency plans and response procedures, and mandatory trainings. Suppliers should implement a Health & Safety Management System, including accident and near accident reporting.

Facilities and onsite accommodation for employees must safeguard individuals’ dignity, hygiene and safety. Their conditions must comply with national laws and international health and safety standards.

VI. Environment

Al Pack has a leading role in environmental protection among packaging companies in Serbia. As one of the fastest growing companies in the region, we build on the sustainable interaction with man and nature. We continuously assess our processes and our suppliers play a critical role in achieving our environmental and circularity ambitions.

1. Environmental responsibility and Management systems

Suppliers shall maintain an effective environmental policy and environmental management system, consistent with according to local regulation and ISO 14001 or EMAS, that promotes environmental responsibility and enables continuous improvement of their environmental performance and impact. Al Pack reserves the right to ask for evidence of, and the possibility to audit, the environmental management system.

2. Resource Efficiency

Suppliers shall control and implement actions to reduce their use of energy, water, raw material and should strive to reduce their reliance on fossil fuels.

3. Emissions and waste handling

Suppliers shall control and implement actions to reduce emissions to air, water and waste of all types. Waste handling management for hazardous and non-hazardous material must be developed and monitored.

4. Life Cycle and Circularity

Suppliers shall provide information regarding their carbon footprint and calculation methodology. In addition, Suppliers shall assist Al Pack in the evaluation of the products and services they delivered, including all data to evaluate life cycle assessment as well as end of life scenarios to follow. Suppliers should strive to reduce the impact of their operations from a circularity perspective. Our Environmental Requirements can be found in Annex A.

VII. Ethics

Al Pack has a zero-tolerance policy towards any and all forms of bribery, corruption, extortion, money laundering, and embezzlement. Suppliers shall adhere and reject all corrupt practices, including but not limited to facilitation of payments and receipt of improper gifts. Suppliers are responsible for ensuring that their employees, subcontractors and other representatives comply with the Anti-Corruption Policy when acting in relation to, or on behalf of Al Pack. The Anti-Corruption Policy is available at www.northvolt.com.

Personal interest or relationships shall not influence Suppliers in decision making. Suppliers shall be proactive in managing potential conflicts of interest in collaboration with Al Pack. All business dealings should be transparently performed and accurately reflect Suppliers’ financial records. Standards of fair business, advertising and competition should be upheld. Suppliers shall provide notification to Al Pack of counterfeit product(s) when warranted. Suppliers are expected to provide their employees with ways for raising legal or ethical issues or concerns without fear of retaliation.

1. Privacy

Suppliers shall comply with privacy and information security laws and regulatory requirements when personal information is collected, stored, processed, transmitted, and shared. Suppliers shall commit to protecting the reasonable privacy expectations of personal information of everyone they do business with.

2. Intellectual Property

Intellectual property rights are to be respected; transfer of technology and know-how is to be done in a manner that protects intellectual property rights.

VIII. Management system and implementation of the supplier code of conduct

Al Pack encourages Suppliers to continuously improve the management systems related to the areas described in this Code. A successful implementation of the Code requires risk assessments, implemented policies, processes and routines, clearly communicated roles and responsibilities, relevant training and instructions, establishment and performance evaluation of measurable goals, and well-functioning control systems.

The Director of Al Pack is responsible for reviewing this Code on a regular basis and proposing updates or amendments as deemed necessary.

A suspected breach of this Code shall be reported to the Director at Al Pack or via Al Pack ’s Whistleblowing system in accordance with Al Pack ’s Whistleblowing Guidelines available at whistleblowing.elevenes.com

Supplier code of conduct.pdf

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