Supplier Code of Conduct

1. Overview

This Supplier Code of Conduct applies to Message4U Pty Ltd t/a ClickSend and its Related Bodies Corporate (“ClickSend”, “we” or “us”).The purpose of this Code of Conduct is to:

• ensure that each of our suppliers (i.e. any entity who does business with any company or division of ClickSend including any vendor or business partner) (a "Supplier") adheres to the same ethical standards; and

• prescribe a set of minimum standards for doing business with any Suppliers.

We will assess adherence to this Code by our Suppliers whether or not this Code is incorporated into our supplier contracts. The Supplier Code of Conduct also applies to conduct related to all personnel engaged by the Supplier, regardless of whether they be casual, short-term or contracted workers or where they may be located.

2. Law and ethical standards

The Supplier must comply with all laws applicable to its business. The Supplier should support the principles of the United National Global Compact, the UN Universal Declaration of Human Rights and the 1998 International Labour Organisation Declaration on Fundamental Principles and Rights at Work. This specifically applies to all aspects of human rights and fair labour practices set out below.

3. Modern Slavery

ClickSend is committed to a zero-tolerance approach to all forms of modern slavery practices in its supply chain. ClickSend defines modern slavery in accordance with the definition provided in the Modern Slavery Act 2018 (Cth),that is including slavery, servitude, forced labour, deceptive recruiting, forced marriage, debt bondage, trafficking in persons and child labour.

Child labour

The Supplier must operate in accordance with ILO Convention 138. Suppliers must not employ children under the legal age of employment in any country or local jurisdiction. If the minimum age of employment is not defined, it will be 15 years of age.

Forced Labour

The Supplier must not use any form of forced, bonded or involuntary labour. Workers must be allowed to maintain control over their identification documents (e.g. passports, work permits or any other personal legal documents). The Supplier must ensure that workers do not pay fees or make any payment connected to obtaining employment throughout the hiring process and the employment period. Punishment and/or mental or physical coercion are prohibited. Disciplinary policies and procedures must be clearly defined and communicated to the workers.

Compensation and working hours

The Supplier must comply with all applicable national laws and mandatory industry standards regarding working hours, overtime, wages and benefits. The Supplier must pay workers in a timely manner and clearly convey the basis on which workers are being paid. Deductions from wages as a disciplinary measure must not be allowed if not legally permitted and, even where legally permitted, should be minimised.

Freedom of association and collective bargaining

The workers of the Supplier must be free to join or not to join a union/employee representation of their choice, free from threat or intimidation. The Supplier must recognise and respect the right to collectively bargain in accordance with applicable laws.

Discrimination

The Supplier must not discriminate or tolerate discrimination with respect to gender, race, religion, age, disability, sexual orientation, national origin or any other characteristic protected under applicable laws.

4. Work Health and Safety

The Supplier must comply with applicable occupational health and safety regulations and provide a work environment that is safe and conducive to good health, in order to preserve the health of employees, safeguard third parties and prevent accidents, injuries and work-related illness. This includes regular workplace risk assessments and the implementation of adequate hazard control and precautionary measures. Workers are to be adequately educated and trained in health and safety issues.

5. Data protection and disclosure information

The Supplier must adhere to relevant data protection and security laws and to respective regulations, in particular with regard to personal data of customers, consumers, employees and shareholders. The Supplier must comply with all said requirements when personal data is collected, processed, transmitted, used or retained.

6. Bribery and corruption

The Supplier must comply with all national and international anti-bribery regulations as well as applicable anti-corruption laws, regulations and standards. The Supplier must not (either directly or indirectly) offer or promise to provide anything of value to improperly influence an official or act to secure improper advantage in order to obtain or retain business.

The Supplier must comply with applicable laws and regulations designed to combat money laundering activities. The Supplier must maintain financial records and reports according to international laws and regulations.

7. Conflicts of interest

A conflict of interest arises when an individual has a private/personal interest which could appear to influence their decisions. Such conflict of interest situations include a relationship by blood or marriage, partnership, business relationship, business partnership or investment. The Supplier must disclose any actual or potential conflict of interest with ClickSend personnel of which it is or becomes aware.

8. Environment

The Supplier shall comply with all applicable environmental laws, regulations and standards as well as implement an effective system to identify and eliminate potential hazards to the environment. ClickSend expects Suppliers to strive to support national climate protection goals and initiatives through the products and services they deliver (e.g. by providing relevant data on climate protection).

9. Business continuity planning

The Supplier must be prepared for any disruptions of its business (e.g. natural disasters, terrorism, software viruses, illness, pandemics, infectious diseases, worker shortages). This preparedness especially includes business continuity and disaster recovery plans to protect both employees as well as the environment as far as possible from the effects of possible disasters that arise within the domain of operations.

10. Code of conduct governance

ClickSend reserves the right, upon reasonable notice, to check compliance with the requirements of the Supplier Code of Conduct. We encourage our Suppliers to implement their own binding guidelines for ethical behaviour.

Any material breach of the obligations stipulated in this Supplier Code of Conduct is considered a material breach of the contract by the supplier.