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Oktopost Business Ethics Code

Last Updated: September 23, 2026

At each step of its way, Oktopost endeavors to conduct its business in an honest manner and with good judgment while complying with the laws, rules and standards of conduct that apply to us wherever we do business. We are also committed to developing strong business relationships with high quality Business Partners that have committed to operate under ethical standards equivalent to our own.

This Oktopost Business Code of Ethics applies specifically to our suppliers and business partners worldwide (each, a “Business Partner”) and seeks to apply adherence with comparable standards of behavior, thereby producing ethical responsibility through our business channel.

Business Partner Requirements

As an Oktopost Business Partner, you are required to comply with the provisions of this Code.

Definitions

In this Code:

  • “Business Partner” means a company, partnership or individual that is supplying goods and/or services to an Oktopost entity, or to which an Oktopost entity is providing its services.
  • “Worker” means any individual whom the Business Partner employs, hires, engages or otherwise uses to conduct its business.

Scope

The terms of this Code apply equally (i) to any affiliated company of the Business Partner and (ii) to any agent or subcontractor of the Business Partner to the extent that such agent or sub-contractor is performing services for the Business Partner or its affiliated company.

Accordingly, the term “Worker” may also include any individual employed, hired or otherwise engaged by the Business Partner’s affiliated companies or by the Business Partner’s or its affiliated companies’ subcontractors or agents.

Oktopost has taken upon itself to adhere to the provisions of this Code and is in full compliance with its requirements.

Obligations

  1. Employment is Chosen Freely
    • Workers work voluntarily and are neither forced nor bonded to work nor work in an involuntary capacity in prison labor. Business Partner will not use, participate in, or benefit from, any form of human trafficking.
    • Workers are not required to pay Business Partner or its agents recruitment fees or other fees. Workers are also not required to lodge “deposits” or their identity papers (such as passports or drivers’ licenses) with Business Partner and Business Partner may not deny access to such identity papers. Workers are free to terminate their employment or other working relationship with Business Partner at any time after reasonable notice without reprisal.
    • To every extent possible, work performed must be done on the basis of a recognized employment or independent contractor relationship established in accordance with law, regulations and practice applicable to the Business Partner.
  2. Freedom of Association and Right to Collective Bargaining
    • Workers have the right to (or the right to not) associate freely, join or form trade unions or works councils of their own choosing and to bargain collectively in accordance with legislation applicable to the Business Partner.
    • Business Partner will comply with all applicable legislation regarding the activities of trade unions and works councils and their organizational activities.
    • Workers’ representatives shall be able to openly communicate and share ideas and concerns with management regarding working conditions and management practices without fear of discrimination, reprisal, intimidation or harassment.
  3. Safe and Healthy Working Conditions
    • Workers will be provided with a safe, healthy and hygienic working environment, bearing in mind the prevailing knowledge of the industry and of any specific hazards. Adequate steps will be taken to prevent accidents and injury to Workers arising out of, associated with, or occurring in the course of work carried out by the Workers, by minimizing, so far as is reasonably practicable, the causes of hazards inherent in the working environment. Where hazards cannot be adequately controlled, Workers are to be provided with appropriate, well-maintained, personal protective equipment. Workers will not be disciplined for raising safety concerns. Business Partner will identify and address potential emergency situations and events and will implement emergency plans and response procedures.
    • Workers shall receive appropriate health and safety training. Health and safety-related information will be clearly posted in Business Partner facilities in appropriate languages.
    • Workers will be provided with access to clean toilet facilities and drinkable water, and, if appropriate, sanitary facilities for food storage shall be provided.
    • Living accommodation, where provided, shall be clean, safe and meet the basic needs of the Workers.
    • Business Partner will assign responsibility for health and safety to a senior management representative.
    • Business Partner is expected to operate in a manner that complies with health and safety laws and regulations applicable to the Business Partner.
  4. Prohibition of Child Labor
    • Business Partner will not use child labor. The term “child” means any person who is (a) under the age of 15 or (b) under the minimum age for employment in the country, whichever is greatest.
    • Workers under the age of 18 will not perform work that is likely to jeopardize their health or safety, including shifts at night or working in hazardous conditions.
  5. Wages and Benefits
    • Wages and benefits paid to Workers shall comply with applicable wage laws, including those related to minimum wages, overtime hours and legally mandated benefits.
    • All Workers will be provided with written and understandable information about their wages and benefits before they enter employment and about the particulars of their wages for the pay period concerned each time that they are paid through a pay stub or other documentation.
    • Deductions from wages as a disciplinary measure shall not be permitted, nor shall any deductions from wages not provided for by applicable legislation be permitted without the express permission of the Worker concerned.
  6. Working Hours are not Excessive
    • Working hours shall not exceed the maximum set by local legislation. Workers shall be allowed at least one day off per seven day week, or as set forth in local employment legislation, whichever greater.
  7. No Discrimination is Practiced
    • Business Partner will be committed to a workforce free of harassment and unlawful discrimination. Business Partner will not engage in discrimination in hiring and employment practices, such as compensation, access to training, promotion, termination or retirement based on race, color, religion, age, sex, gender, pregnancy, marital status, sexual orientation, gender identity and expression, national origin, citizenship status, disability, veteran status or any other classification protected by applicable laws or regulations.
  8. No Harsh or Inhumane Treatment is Allowed
    • Physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal abuse or other forms of intimidation shall be strictly prohibited.
  9. Whistleblowing
    • Oktopost respects the rights of employees, staff and contractors to raise their concerns about possible wrongdoing within the business. Oktopost has well established procedures in place allowing for the confidential and anonymous disclosure of such concerns in order to examine the matter thoroughly and provide an appropriate solution as required.
    • Business Partner shall establish and implement procedures to ensure the protection of whistle-blower identities, including the ability to make a confidential and anonymous disclosure to the relevant team member and safeguarding against retaliatory actions which may take place as a result of whistleblowing made in good faith.
  10. Modern Slavery Act
    • Business Partner undertakes to comply, at all times, with applicable local legislation designed for the prevention of modern slavery.
    • To the extent Business Partner is located and/or operating from the United Kingdom, it undertakes to comply, at all times, with the provisions of the Modern Slavery Act 2015, and demonstrate a commitment to such compliance upon Oktopost’s request.
  11. Anti-bribery and Anti-corruption
    • Business Partner will comply at all times with all applicable anti-bribery and anti-corruption laws, including, but not limited to, the U.S. Foreign Corrupt Practices Act and the U.K. Bribery Act.
    • Business Partner will engage reputable Workers and ensure they understand and adhere to these requirements.
  12. International Trade Control, Sanctions and Anti-Money Laundering
    • Business Partner will comply with all applicable import, export, customs, and trade control laws and regulations, including economic and trade sanctions laws, antiboycott laws, and any other related requirements.
    • Business Partner will comply with all applicable anti-money laundering laws and regulations. Therefore, all payments and transactions with customers, vendors, suppliers, agents, and affiliates will be scrutinized.
  13. Conflicts of Interest and Fair Competition
    • Business Partner will avoid any actual or potential conflicts of interest, such as personal or financial interests, that interfere or appear to interfere with the business relationship, making it difficult for Business Partner to perform its organizational duties objectively and effectively or preventing Business Partner from making the right decision for the engagement. Any actual or potential conflicts of interest must be promptly reported to Oktopost.
    • Business Partner will comply with all applicable antitrust and competition laws, including without limitation, ensuring it does not enter into formal or informal agreements with competitors regarding price fixing, market or customer allocation, bid rigging, or any other anti-competitive behavior.
  14. Environment
    • Business Partner will comply with all applicable environmental laws, and obtain, keep current, and comply with all required environmental permits and licenses needed for their operations.
    • Oktopost expects its Business Partners to strive to improve the overall environmental impact of its operations and products along the value chain.
  15. Data Protection and Information Security
    • Business Partner will comply with all applicable data protection laws and regulations, including security of personal data.
    • Business Partner will comply with any contractual requirements on data protection and information security.
    • Business Partner will implement and obtain appropriate safeguards and accreditations to protect personal information and systems from unauthorized access, misuse, or harm (e.g., malware or data breaches).
  16. Ensuring Compliance, Questions and Reporting Concerns
    • On request, Business Partner will furnish Oktopost with relevant information and data to support its compliance with this Code.
    • Subject to local laws and any legal restrictions applicable to such reporting, business Partner is expected to promptly report to Oktopost any violation of this Code that it becomes aware of by emailing [email protected] with the subject ‘Ethics Code Compliance Concern’. Confidentiality will be maintained to the fullest extent possible, consistent with the need to conduct an adequate review. Business Partner agrees not to retaliate against any of its Workers who, acting in good faith, report what they reasonably believe is a violation of this Code.