Unbabel prides itself in upholding social, ethical and environmental practices to satisfy the expectations of our shareholders, customers, employees, suppliers and society as a whole.

To achieve and maintain this, we recognise that activities conducted through our supply chain can have a direct/indirect impact on Unbabel’s social, ethical and environmental performance.

This Code of Conduct sets out to our suppliers, and in turn their suppliers, Unbabel’s basic requirements which must be met in order to engage with us. This Code should be read in conjunction with our contractual documentation and terms and conditions unique to each supplier (if available and in place).

All Unbabel suppliers shall abide by this Code of Conduct, maintaining documentation to demonstrate compliance and providing access to this documentation upon request.

A process of self evaluation and, as required, independent inspection, is in place to ensure its proper and practical application.

We expect all of our suppliers to comply with their national laws and regulations. Where the code or national law addresses the same issue, the supplier is expected, as a minimum, to be in compliance with the applicable laws, including, but not limited to the US Foreign Corrupt Practices Act (FCPA), the UK Bribery Act 2010, International Labour Organization (ILO) standards, the EU’s REACH regulation, the UN Guiding Principles on Business and Human Rights, the Criminal Finances Act 2017, and relevant health and safety regulations as well as with the ESGs rules and guidelines specifically applicable to the concerned supplier.

Act ethically

When conducting business with Unbabel customers or on behalf of, or in connection with Unbabel, suppliers will conduct all activities in accordance with law, and with integrity, fairness, respect and in an ethical manner.

Do not give/ receive bribes

Unbabel suppliers shall not engage in corruption, extortion, embezzlement or money laundering in any form. They shall not offer, give, receive or solicit any bribes, or employ other means to obtain any improper benefit or advantage in the conduct of their business.

Maintain accurate accounting records

Unbabel suppliers accounting records must be:

• Kept and presented according to all applicable laws and regulations;
• In reasonable detail, accurately and fairly reflect transactions, assets, liabilities, revenues and expenses; and
• Free from any false or misleading statements or entries.

Respect IP rights

Unbabel suppliers shall always respect IP rights. Any transfer of knowledge and/or technology must be carried out in a manner which protects these rights. Unbabel suppliers will only use software and assets which have been legitimately acquired and licensed. They will only use lawful methods of gathering competitive intelligence.

Recognise and protect Unbabel’s assets and information

On occasion, Unbabel suppliers may have access to confidential information and/or personal data that belongs to Unbabel, or its employees, customers and/or other suppliers. This information should be appropriately categorised by Unbabel suppliers, and preventative actions taken to protect it from any misuse and/or unauthorised disclosure.

Avoid conflicts of interest

Unbabel suppliers shall avoid conflicts between them and Unbabel by ensuring they disclose any potential, perceived or actual conflicts of interest immediately when identified. Further, they shall ensure that they have adequate processes in place to assess, manage and report conflicts of interest.

Do not discriminate in employment or hiring

This includes discrimination based on gender, race, age, gender identity, sexual orientation, religion, ethnicity, disability, pregnancy, political affiliation, marital status or any characteristic which does not relate to the individual’s qualifications or the requirements for the role.

Respect employees rights

This includes womans rights, and rights of minorities.

Do not use child labour

Defined as a person that is:

• Younger than 15 years old;
• The minimum age for completing compulsory education in their country of potential employment; or
• The minimum age for employment in the country of employment, whichever is highest.

Provide adequate compensation and benefits

Unbabel suppliers shall provide all employees at least the minimum compensation and benefits as defined by local law.

Provide adequate time off

Unbabel suppliers shall take all appropriate steps to ensure that working hours of employees do not exceed the maximum working hours as defined by local laws, except in emergency situations and only with the consent of the employee in question.

Unbabel suppliers shall provide their employees with a safe and healthy working environment in compliance with all applicable laws and regulations.

We expect Unbabel suppliers to have effective programs covering areas such as human safety, first aid and emergency preparedness.

Do not pollute the environment or waste resources

Unbabel suppliers shall assess their environmental impact and implement and maintain environmental management systems. This can include, but is not limited to:

• Greenhouse gas emissions;
• Carbon footprint;
• Water, plastic and waste consumption;
• Air pollution;
• Noise pollution; and
• Biodiversity and Deforestation.

Control hazardous substances

Unbabel suppliers shall ensure that chemicals and other substances that pose a hazard to the environment are identified and managed to ensure their safe handling, storage, use and disposal.

Implement proper waste management processes

Any waste water and/or solid waste shall be treated in accordance with local laws and good environmental practices.

Maintaining a strong control environment

Controls shall be in place to ensure compliance with laws, regulations and standards. Unbabel suppliers shall ensure that the controls are designed adequately, operating effectively, and are regularly independently assessed and audited.

Assess and manage risks

A Risk Management Framework shall be implemented and maintained, with risks regularly assessed. In the case that there are risk exposures, Unbabel suppliers shall ensure that these are properly managed and mitigated to an acceptable level.

Maintain proper documentation and records

Unbabel suppliers shall ensure that they (and their suppliers) maintain accurate, complete and current documentation and records to satisfy regulatory requirements, whilst ensuring that confidentiality is consistently maintained.

Provide adequate training

Unbabel suppliers shall ensure that all employees receive continuous training, in that they are able to consistently deliver the responsibilities and skill sets commensurate with their role(s).

Prompt in addressing non conformities

Any non conformities should have an action plan, owner and timeline documented and tracked through to completion. The timeline should be driven by the severity of the non conformity and the risk associated with it.

Flow through to sub processors and business providers

Unbabel suppliers should ensure that their suppliers are compliant with this Code of Conduct, and perform appropriate assessments (upon onboarding and then at a stipulated review frequency) to confirm their policies, procedures, control environment and business operations meet the requirements of this Code.

Any violation of this Code of Conduct may result in corrective action, which will depend on the nature and severity of the Code violation and the circumstances surrounding the situation, and can result in the termination of the relationship between Unbabel and the supplier.

Unbabel suppliers must communicate to Unbabel any known or suspected improper behaviours, or any behaviours which are in violation of this Code of Conduct.

If you have questions regarding this Code of Conduct, please contact our Legal & Compliance team at compliance@unbabel.com