nLighten Supplier Code of Conduct

1. Introduction

This Supplier Code of Conduct (“Code”) applies to nLighten HQ BV and its affiliates (collectively, the “Company” or “nLighten”).

nLighten is committed to conduct business in a legal, ethical, transparent and professional manner. The Company operates a growing business and expects the highest ethical behavior from its suppliers according to the rules which are set forth in this Code. The Code specifies requirements applicable to our suppliers and other third-party conducting business with or on behalf of nLighten in the areas of compliance with laws, human rights, safe working conditions, business integrity, environment and secure supply chains (a “Supplier” or more “Suppliers”).

2. Compliance with laws

Suppliers must obey all international, national and local laws, rules, and regulations applicable in the territories where they operate, while conducting business on behalf or at the request of nLighten.

3. Intellectual property

Intellectual property of nLighten includes, among other things:

• copyrights
• patents
• trademarks
• trade secrets and other intangible property

Suppliers may only use nLighten’s intellectual property to the extent permitted under agreements concluded (and in force) with nLighten and must not infringe or misuse the intellectual property of nLighten or any other party.

In case the Supplier is aware of any unauthorized use of nLighten’s intellectual property by a third party or by a representative of a Supplier, the Supplier has the obligation to notify nLighten as soon as practically possible via email to compliance@nlighten.eu.

4. Non-discrimination and anti-harassment

Suppliers must not engage in any form of unlawful discrimination based upon sex, race, color, ethnicity, national origin, age, disability, religion, or any other basis protected by law. In addition, Suppliers must maintain a workplace environment free from unlawful harassment.

5. Health, safety and human rights

Suppliers shall comply with all applicable laws, including laws on modern slavery and human trafficking. Suppliers must provide safe working conditions and a healthy work environment. Suppliers must also respect and support the protection of human rights and business integrity. Under no circumstances will a Supplier employ workers under the minimum age for work or mandatory schooling, whichever is greater, as specified by the Modern Slavery Act.

Without limitation, Suppliers shall:

1. comply with all applicable occupational health and safety laws and regulations, including but not limited to laws and regulations that address occupational safety, emergency preparedness, occupational injury and illness, industrial hygiene, physically demanding work, machine safeguarding, sanitation, food and housing;
2. allow under no circumstance any physical abuse or discipline, or the threat of physical abuse, sexual abuse or other sexual harassment, verbal abuse, or other forms of intimidation.

In cases when a Supplier does not meet our standards we will implement an action plan, which may include the termination of the relation with the Supplier.

6. Governance & compliance

Suppliers must undertake the following actions to maintain the security of our offices and data centers and the protection of our records, data and information:

1. Screening of Supplier’s personnel performing services for nLighten to ascertain such person’s trustworthiness;
2. Notifying nLighten within 72 hours of discovering any breach or loss of nLighten records, data, or information in your possession; and
3. Providing certain identifying information to nLighten, upon a legitimate request and in compliance with the GDPR, regarding any persons who may have access to our communications infrastructure or our data, records, or information.

7. Anti-corruption, anti-bribery, gifts and anti-money laundering

Suppliers must comply with all applicable national and supranational anti-corruption and anti- bribery laws. Suppliers shall not offer or provide nLighten employees gifts or kickbacks to obtain favorable treatment from nLighten. All employees, officers and directors of the Company shall comply with the Code of Conduct of nLighten. Any attempts of bribery or alike  aimed at nLighten employees, officers or directors will lead to termination of the relationship between the Company and such Supplier.

Suppliers should prevent and monitor for possible money laundering, terrorist financing or activity violating any applicable sanctions or export-based restrictions. Suppliers should ensure they are conducting business only with reputable business partners, for legitimate business purposes, and with funds derived from legitimate sources.

8. Sanctioned countries and trade controls

Suppliers must comply with all applicable laws and regulations relating to sanctions and export and trade control laws. Suppliers must not take any action which may cause nLighten to breach sanctions and/or trade control laws. It is a duty of Suppliers to monitor and be compliant with relevant national and international sanctions regulations and in case of potential breaches nLighten shall be notified in a timely manner.

9. Environment

nLighten is committed to reducing our consumption of all resources. We are continuously seeking to reduce our use of scares resources and of our carbon footprint and we expect our Suppliers to follow the same pattern of operations and, at a minimum, comply with all local, state, federal and supra national environmental regulations.

nLighten operates an Environmental Sustainability Policy and Suppliers shall act in compliance with this policy at all times. In the spirit of collaboration and promoting continuous improvement, the Company may request the Suppliers' participation on an annual basis to share sustainability-related data, which nLighten may use to report on its sustainability goals.

10. Reporting illegal or unethical behavior

If Suppliers become aware of violations or suspected violations of this Code, they can inform nLighten by contacting our compliance officer at compliance@nlighten.eu.

11. No Third Party Rights

The Code does not confer, nor shall it be deemed to confer, any rights on the part of third parties, including any third-party beneficiary rights. For example, no employees of any Supplier shall have any rights against the Company by virtue of this Code, nor shall such employees have any rights to cause the Company to enforce any provisions of this Code, the decision with respect to any such actions being reserved by the Company in its sole discretion.

12. Enforcement

nLighten takes compliance with this Code very seriously. nLighten shall determine appropriate actions to be taken in the event of violations of this Code, including possible termination of a Supplier’s business relationship with nLighten. This Code supersedes and replaces any previous versions of the Code.

Please direct any questions about this Code to compliance@nlighten.eu.