GEIG – SUPPLIER CODE OF CONDUCT (v1.1)
Effective from: 01/08/2025

1.0 Purpose and Scope
1.1 This Supplier Code of Conduct (“Code”) sets the minimum standards for suppliers, contractors, distributors, agents, and any sub-suppliers engaged in providing goods or services to GeiG (“Suppliers”).
1.2 This Code works alongside the GeiG Terms of Sale (Business and Consumer), Modern Slavery & Human Trafficking Statement, Environmental / WEEE / RoHS Declaration, Export & Trade Compliance Policy, Security & Vulnerability Disclosure Policy, and Privacy & Cookie Policies.
1.3 Suppliers must ensure this Code is flowed down to their own supply chains and are responsible for their sub-suppliers’ compliance.

2.0 Legal Compliance and Ethics
2.1 Comply with all applicable laws and regulations, industry standards, and binding sanctions/export-control regimes (see Section 10.0).
2.2 Zero tolerance for bribery, corruption, extortion, embezzlement, or facilitation payments. Maintain accurate books/records.
2.3 Disclose conflicts of interest to GeiG without delay.
2.4 Fair competition: comply with antitrust/competition laws; no price-fixing, bid rigging, or market allocation.

3.0 Labour and Human Rights
3.1 No forced, bonded, trafficked, or prison labour. Workers retain control of identity documents; freedom of movement is respected.
3.2 No child labour. Minimum employment age must meet or exceed local law and ILO standards; young workers must not perform hazardous work or night shifts.
3.3 No worker-paid recruitment fees. Recruitment is employer-pays. Any fees found must be reimbursed to workers.
3.4 Working hours, rest, and overtime must comply with law; overtime must be voluntary and compensated per law.
3.5 Wages and benefits must meet or exceed legal minimums; provide clear, itemised wage statements with no unlawful deductions.
3.6 Humane treatment: no harassment, abuse, corporal punishment, or degrading practices.
3.7 Non-discrimination and equal opportunity in hiring, compensation, training, promotion, termination, and retirement.
3.8 Respect freedom of association and collective bargaining in line with local law.
3.9 Zero-tolerance breaches: forced/bonded/trafficked labour, child labour, document retention, charging recruitment fees, or retaliation against whistleblowers may result in immediate suspension or termination.
3.10 Recruitment channels: use only licensed/approved agencies. Keep agency contracts and fee schedules; passports/IDs must never be held. Workers receive contracts in a language they understand before departure/hire.
3.11 Working hours shall not exceed 60 hours per 7-day period including overtime, with at least one continuous day off every 7 days, except for narrowly defined emergencies permitted by law.
3.12 Living wage progression: where feasible, Suppliers should progress toward wages meeting basic needs plus discretionary income, evidenced through periodic wage reviews.
3.13 Young workers (under 18) must not perform hazardous work, night shifts, or overtime; school and training schedules take precedence.

4.0 Health, Safety, and Welfare
4.1 Maintain a robust H&S management system: risk assessments, safe operating procedures, incident reporting, continual improvement.
4.2 Provide appropriate PPE, training, machine guarding, chemical handling controls, and ergonomics.
4.3 Emergency preparedness: clear egress, alarms, drills, first-aid arrangements.
4.4 Housing and canteen (if provided) must be safe, clean, and meet statutory standards.
4.5 Serious incidents (fatality, amputation, hospitalisation, major chemical spill, fire) must be reported to GeiG within 24 hours, with an investigation report and corrective actions within 10 business days.

5.0 Environmental Responsibility
5.1 Comply with environmental laws/permits; prevent pollution; manage emissions, effluents, and waste responsibly.
5.2 Comply with UK/EU RoHS and REACH; manage SVHCs; provide required information within statutory timeframes.
5.3 Support lawful end-of-life treatment and take-back consistent with WEEE and batteries regulations; cooperate with GeiG take-back routes.
5.4 Packaging: minimise materials and include clear recycling guidance; support applicable Packaging EPR schemes.
5.5 Design for environment: prioritise repairability, spare parts availability, and responsible materials where commercially reasonable.
5.6 Chemical management: maintain an up-to-date chemical inventory and SDS; ensure safe storage/handling and substitution of high-risk substances. Products shall comply with GeiG restricted substances lists where provided (including REACH SVHC communication).
5.7 Environmental data and targets: upon request, provide annual data on energy use, water, waste, and GHGs for GeiG sustainability reporting and set reduction targets where material.

6.0 Materials Sourcing (Conflict Minerals and Cobalt)
6.1 Conduct due diligence on 3TG (tin, tungsten, tantalum, gold) and cobalt per the OECD Due Diligence Guidance.
6.2 Use smelters/refiners audited under recognised programmes (e.g., RMI/RMAP) where available.
6.3 Provide, on request, up-to-date CMRT/EMRT declarations and due-diligence reports.
6.4 See GeiG’s Conflict Minerals Policy; where requirements differ, the stricter applies.

7.0 Data Protection and Information Security
7.1 Protect personal data and confidential information; process only as necessary and in line with law/contract.
7.2 Maintain reasonable technical and organisational measures (access control, patching, logging).
7.3 Report any suspected personal-data breach or security incident to GeiG within 72 hours of discovery, including scope, data categories, and immediate containment steps.
7.4 Do not test GeiG systems without authorisation; coordinate findings via GeiG’s Security & Vulnerability Disclosure Policy.
7.5 Security baselines: role-based access control, MFA for admin access, timely patching, encryption in transit and at rest for sensitive data. Where proportionate, align with ISO/IEC 27001 controls.

8.0 Product Safety, Quality, Continuity, and Traceability
8.1 Deliver goods/services that meet agreed specifications, safety standards, and certifications (e.g., UKCA/CE).
8.2 Maintain traceability (batch/lot/serial) sufficient for targeted recalls/corrective actions.
8.3 Promptly notify GeiG of non-conformances and implement corrective/preventive actions.
8.4 Counterfeit parts prevention: operate controls to prevent counterfeit parts (authorised sourcing, incoming inspection, quarantine/reporting).
8.5 Product Change Notification (PCN/EOL): provide ≥ 90 days’ notice for form/fit/function changes, site moves, or end-of-life affecting GeiG products, with risk assessment and last-time-buy options.
8.6 Business continuity: maintain BCP/DR plans for critical operations (fire, flood, pandemic, geopolitical disruption) and test them at least annually.

9.0 Sub-Suppliers, Transparency, and Outsourcing
9.1 Obtain GeiG’s prior written consent before outsourcing critical processes or changing approved manufacturing sites.
9.2 Ensure sub-suppliers comply with this Code and all referenced policies; maintain documented due diligence and monitoring.
9.3 Keep records evidencing sub-supplier compliance and corrective actions.
9.4 On request, disclose critical tier-2 suppliers and manufacturing locations. Geographical shifts of production require prior written approval.

10.0 Export Controls and Sanctions
10.1 Comply with UK export control law, the UK Sanctions and Anti-Money Laundering Act, and applicable US/EU/UN sanctions and dual-use measures.
10.2 Do not supply GeiG Items to denied/restricted parties or embargoed territories; screen transactions and escalate red flags.
10.3 Provide accurate shipping documents (HS codes, value, origin) and observe licence requirements where applicable.

11.0 Business Integrity, Gifts, and Hospitality
11.1 Gifts, hospitality, or expenses must be modest, lawful, infrequent, and never intended to improperly influence.
11.2 Prohibit kickbacks and third-party channels used to disguise improper payments.
11.3 Thresholds: any gift/hospitality over £50 (or local equivalent) requires disclosure to GeiG and must never be in cash or equivalents.

12.0 Grievance, Worker Voice, and Non-Retaliation
12.1 Provide confidential worker-voice channels and communicate them in local language(s).
12.2 Retaliation against anyone raising a concern in good faith is prohibited.
12.3 Cooperate with GeiG’s 24/7 web chat or email channels for concerns related to GeiG production.
12.4 Track and, on request, provide grievance KPIs: number of grievances, time to first response ≤ 5 business days, and closure within 30 days, with non-retaliation evidence.

13.0 Transparency, Audits, Access, and Retention
13.1 GeiG (or a designated third party) may conduct announced or unannounced assessments, including site visits, document reviews, and worker interviews, subject to safety and confidentiality.
13.2 Provide full, timely access to facilities, records, and personnel; falsification or obstruction is a material breach.
13.3 Keep due-diligence, payroll, time, age/ID, H&S, environmental, and training records for at least six (6) years or longer where required by law.
13.4 Where material non-conformance is found, Suppliers shall bear reasonable re-audit costs and implement corrective actions without delay.

14.0 Corrective Action, Remedies, and Consequences
14.1 Where non-conformance is identified, implement a Corrective Action Plan (CAP) with time-bound milestones and report progress to GeiG.
14.2 GeiG may suspend orders, re-source, reduce volumes, or terminate contracts for material or repeated breaches.
14.3 In serious cases, remedies may include fee repayment to workers, back pay, improved housing/transport, or funding third-party audits—without unreasonable delay.
14.4 CAP quality: identify root cause, owner, milestones, and verification evidence. Failure to meet milestones may trigger volume reduction, hold, or termination.

15.0 Training and Awareness
15.1 Train relevant staff (management, HR, supervisors, EHS, procurement) on this Code, forced-labour red flags, grievance handling, and anti-bribery.
15.2 Higher-risk sites must deliver annual training and retain attendance records.
15.3 Training materials must be local-language and literacy-appropriate; keep attendance logs and content summaries for at least six years.

16.0 Communications and Notification
16.1 Provide, on request, policies referenced in this Code (anti-bribery, recruitment, H&S, environment, minerals).
16.2 Promptly inform GeiG of material changes (ownership, site relocation, major incidents, regulatory actions).

17.0 Governing Law, Precedence, and Dispute Resolution
17.1 This Code is governed by the laws of England and Wales unless the underlying supply agreement specifies otherwise.
17.2 Disputes may be addressed through the escalation path in the supply agreement; nothing limits GeiG’s right to seek injunctive relief for serious breaches.
17.3 Precedence: if this Code conflicts with a signed supply agreement, the stricter obligation applies unless otherwise agreed in writing.

18.0 Acceptance and Flow-Down
18.1 Acceptance is deemed upon any of: signing this Code, acknowledging purchase orders referencing this Code, or commencing supply to GeiG after the Effective Date.
18.2 Suppliers must flow down these requirements to all sub-suppliers involved in GeiG production, assembly, or services.

19.0 Definitions (Quick Reference)
19.1 “Supplier” includes all tiers providing goods/services to GeiG.
19.2 “Sub-supplier” includes contract manufacturers, component vendors, labour agencies, logistics providers, and service subcontractors.
19.3 “3TG” means tin, tungsten, tantalum, and gold; “OECD Guidance” means the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals.

20.0 Contacts
20.1 Questions: support@geig.co.uk (operated by Computerko Limited for GeiG) or 24/7 web chat on GeiG.co.uk.
20.2 Postal: GeiG, 27 Old Gloucester Street, London, WC1N 3AX, United Kingdom.