Supplier Code of Conduct

Purpose

The ESG Institute Limited ("the Company") is committed to operating responsibly, ethically and sustainably. This Supplier Code of Conduct ("the Code") sets out the minimum standards we expect from all suppliers, subcontractors and other third parties (collectively "Suppliers") who provide goods or services to the Company or its customers anywhere in the world. Compliance with this Code is a contractual requirement; failure to adhere may result in termination of business and removal from approved‑supplier lists.

Scope and Legal Framework

The Code applies to the Supplier’s own operations, its group companies and its supply chain involved in the production or delivery of goods and services to the Company. Suppliers must comply with all applicable laws and regulations, including—but not limited to—the Modern Slavery Act 2015 (UK), the Human Rights Act 2001 (Isle of Man), the Bribery Act 2013 (Isle of Man), the Data Protection Act 2018 (Isle of Man), the Health and Safety at Work etc. Act 1974 (as applied in IoM) and relevant environmental, labour and trade regulations. Where this Code is stricter than local law, Suppliers are expected to meet the higher standard.

Labour and Human‑Rights Standards

Suppliers shall respect the human rights of workers and:

  • Prohibit forced, bonded or involuntary labour, human trafficking and child labour; minimum employment age shall align with ILO Convention 138 or local law, whichever is higher.

  • Provide fair wages that meet or exceed legal minimums and ensure working hours, overtime and rest periods comply with law and collective agreements.

  • Treat workers with dignity and respect; physical abuse, harassment, discrimination or intimidation are forbidden.

  • Recognise and respect freedom of association and the right to collective bargaining, in accordance with local law.

  • Provide written employment contracts in a language understood by the worker and honour all contractual terms.

Health, Safety and Well‑being

Suppliers must provide a safe and healthy workplace. Hazards shall be identified, risk controls implemented, and emergency preparedness procedures established. Appropriate personal protective equipment (PPE) must be supplied free of charge. Where Suppliers provide on‑site services at the Company’s or client premises, they must comply with all local safety rules and cooperate in joint risk assessments.

Environmental Responsibility

Suppliers are expected to manage and minimise their environmental impact by:

  • Measuring and reducing greenhouse‑gas emissions, energy and water consumption.

  • Reducing waste through prevention, reuse and recycling; disposing of hazardous waste responsibly.

  • Avoiding the use of substances of very high concern and complying with chemical‑management regulations (e.g., REACH).

  • Protecting biodiversity and avoiding unnecessary harm to ecosystems in sourcing raw materials.

  • Obtaining and maintaining all required environmental permits, licences and registrations.

Ethical Business Practices

Suppliers shall conduct business with integrity:

  • Prohibit all forms of bribery, corruption, kickbacks, facilitation payments and money‑laundering.

  • Maintain accurate and transparent records that reflect actual transactions and comply with accounting standards.

  • Avoid conflicts of interest in dealings with the Company; disclose any actual or potential conflict promptly.

  • Compete fairly and comply with antitrust and competition laws.

  • Protect the intellectual‑property rights and confidential information of the Company and others.

  • Respect data‑protection laws and implement appropriate security measures when processing personal data on behalf of the Company.

Diversity, Equity & Inclusion

Suppliers must provide equal opportunities and must not discriminate on grounds of sex, gender identity, race, colour, ethnicity, religion, age, disability, sexual orientation, marital or parental status, union membership or any other protected attribute. Inclusive recruitment, training and progression practices are encouraged.

Animal Welfare

If Suppliers handle animal‑derived products or testing, they shall adhere to internationally recognised animal‑welfare standards and minimise animal suffering.

Sub‑Suppliers and Due Diligence

Suppliers are responsible for cascading these requirements to their own suppliers and subcontractors and for monitoring compliance. The Company may request evidence of due‑diligence processes, supplier audits and corrective‑action plans.

Audits and Assessment

The Company reserves the right to assess Supplier compliance through questionnaires, document reviews, on‑site audits or third‑party assessments with reasonable notice. Suppliers shall cooperate fully and provide access to relevant facilities, records and personnel. If non‑compliance is identified, Suppliers must implement corrective actions within an agreed timeframe.

Reporting Concerns

Suppliers and their workers may raise concerns confidentially via the Company’s Speak‑Up channel: email mail@the-esg-institute.com. Reports can be made anonymously and in local languages. Retaliation against whistleblowers is prohibited.

Continuous Improvement

The Company favours Suppliers who continuously improve their social, ethical and environmental performance, set science‑based targets and disclose progress publicly (e.g., CDP, EcoVadis). Where gaps exist, Suppliers are encouraged to collaborate with the Company on capacity‑building and improvement initiatives.

Breach and Termination

Failure to meet the obligations of this Code or to demonstrate genuine efforts toward compliance may result in remedial action, suspension of new orders or termination of contract. Serious breaches—such as proven use of forced labour or bribery—will trigger immediate termination and may be reported to authorities.

Acknowledgement and Acceptance

By accepting a purchase order, contract or framework agreement from the Company, the Supplier confirms that it has read, understood and will comply with this Supplier Code of Conduct. The Supplier shall provide evidence of compliance upon request and will communicate the requirements of this Code to its employees and supply chain.

This Code is non‑contractual and may be amended at the Company’s discretion. It will be interpreted in accordance with Isle of Man law and any stricter mandatory standard imposed by applicable legislation or the Company’s clients.

Review

This policy is to be reviewed every two years, or earlier if there are significant changes in law or our operations.

Latest update: June 30, 2025.