Rokt Supplier Code of Conduct

1. Introduction

Rokt values partnerships with our suppliers and believes that together, we can create a responsible and sustainable supply chain.

This Supplier Code of Conduct (Code) outlines our shared commitment to ethical business practices, human rights, labor standards, environmental stewardship, and fair business dealings. By adhering to these principles, we can make a positive impact on society while driving mutual success.

We appreciate your cooperation in implementing this Code and look forward to a successful collaboration built on trust, integrity, and shared values.

As an organization, we adhere to the highest ethical standards and conduct to fulfill our purpose by:

Abiding by all relevant laws and regulations
Respecting privacy and maintaining confidentiality
Demonstrating empathy towards the needs of others
Treating people fairly
Upholding our commitments and honoring our promises
Engaging in open and candid communication
Recognizing the significance of our shareholders, community, employees, customers, and partners, and understanding their needs

This Code outlines the expected behaviors that Rokt will exhibit and provides guidance for our suppliers concerning Environmental, Social, and Governance (ESG) matters.

‍

2. Our Commitment

At Rokt, we aim to exemplify the utmost levels of ethical conduct in our business practices. We are dedicated to responsibly and transparently managing our relationships with suppliers.

Rokt places great importance on the manner in which our suppliers conduct their operations and handle their relationships. We expect that our suppliers' actions and decisions do not harm the well-being of the individuals and communities involved in our supply chain.

In this Code, we not only outline our expectations of suppliers but also articulate Rokt's own commitments. We regularly review this document to ensure it aligns with the expectations of stakeholders and complies with relevant laws and regulations.

‍

3. Minimum Requirements

To conduct business with Rokt, it is expected that all suppliers operate in a way that either meets or surpasses our minimum requirements. Additionally, suppliers should be able to demonstrate appropriate measures in place to meet these requirements.

Suppliers must:

Adhere to applicable laws and regulations
Adhere to Rokt's ESG requirements outlined in this Code
Timely respond to information requests from Rokt, which may include questionnaires, interviews, audits, and corrective action plans
Provide an accurate and truthful account of their operations and supply chain when responding to information requests from Rokt
Promptly inform Rokt of any violations of this Code
Establish procedures that enable employees to anonymously report violations of this Code without fear of retaliation or unfavorable treatment
Address any violations of this Code with the highest priority

Our approach

The minimum requirements of Rokt are determined by taking into account relevant laws, international and industry standards, Rokt's business needs, and the expectations of our stakeholders.

At Rokt, we continually evaluate suppliers' adherence to this Code to drive ongoing improvement for Rokt and the people and communities in our supply chain.

When making decisions about sourcing and managing relationships with suppliers, Rokt will consider their performance following this Code.

If a supplier is unable to demonstrate compliance or falls short of the minimum requirements, Rokt retains the right to take appropriate action, such as implementing corrective measures or terminating the business relationship with the supplier.

4. Environmental Expectations

At Rokt, we value the environment and work diligently toward a sustainable future through eco-friendly practices, renewable energy, waste reduction programs, responsible sourcing, and community engagement.

We expect our suppliers to:

Conduct their operations in a way that minimizes the impact on natural resources and protects the environment, customers and workers.
Ensure adherence to applicable environmental protection laws, regulations, and standards related to air emissions, water discharges, toxic substances, and hazardous waste disposal.
Implement initiatives aimed at mitigating the environmental footprint of their operations and supply chain.

5. Social Expectations

We prioritize human rights and actively work to eradicate modern slavery, child labor, and human trafficking in our supply chain. We are committed to creating a responsible and ethical environment that upholds the dignity and well-being of every individual.

We expect our suppliers to:

Ensure that their operations and supply chain are conducted following the principles outlined in the United Nations' Universal Declaration of Human Rights, UN Guiding Principles on Business and Human Rights, and the International Labour Organisation's Core Conventions
Promptly address any negative effects on human rights and working conditions resulting from the supplier's decisions
Establish and uphold appropriate measures to guarantee that their operations and supply chain align with the requirements set by Rokt

6. Governance Expectations

We are committed to fostering a culture of respectful treatment of individuals and upholding ethical business practices. We believe in creating an inclusive and diverse environment where every individual is valued and treated with dignity. Additionally, we maintain the highest standards of integrity, ensuring transparency, fairness, and adherence to ethical guidelines in all our business operations.

6.1 Business Integrity

Suppliers are required to maintain the highest standards of business ethics and integrity, ensuring corporate accountability. They must adhere to the following set of minimum standards that encompass ethical conduct in all aspects of their operations:

6.1.1 Fraud

Suppliers are required to meet stringent fraud requirements to maintain the highest level of trust and reliability in our business partnerships. We prioritize the prevention and detection of fraudulent activities to safeguard our organization's assets and maintain a fair and competitive marketplace.

Suppliers must have robust internal controls and risk management processes in place to mitigate the risk of fraud within their operations.

Suppliers are expected to promptly report any suspected fraudulent activities and cooperate fully with any investigations conducted by our internal audit teams or authorized third parties.

6.1.2 Anti-Corruption

Suppliers are required to adhere to strict anti-corruption requirements as part of our commitment to ethical business practices. We firmly believe in maintaining the highest standards of integrity throughout our supply chain. Therefore, suppliers must demonstrate zero tolerance for bribery, kickbacks, or any form of unethical influence.

Suppliers are expected to conduct their business affairs with honesty, transparency, and fairness, and refrain from engaging in any corrupt activities that may compromise the integrity of our partnership.

6.1.3 Insider Trading

Suppliers are required to strictly adhere to insider trading requirements to ensure a level playing field and maintain the integrity of our financial markets. We place great emphasis on preventing any misuse of material non-public information that could provide unfair advantages in trading activities.

Suppliers must have clear policies and procedures in place to prevent insider trading, including restrictions on trading activities by individuals who have access to confidential information.

Suppliers are expected to educate their employees about the importance of compliance with insider trading laws and regulations, promoting a culture of ethical conduct and transparency.

Suppliers must promptly report any suspected instances of insider trading and cooperate fully with regulatory authorities in their investigations.

6.1.4 Conflicts of Interests

Suppliers are required to adhere to comprehensive conflict of interest requirements to maintain transparency and ensure unbiased decision-making in our business relationships. They must disclose any potential conflicts of interest that may arise from their activities or relationships, whether personal or professional, that could compromise their objectivity or create a perception of impropriety.

Suppliers are expected to take necessary steps to avoid and manage conflicts of interest effectively, ensuring that their actions are solely driven by the best interests of our partnership.

6.1.5 Data Privacy & Information Security

Suppliers are required to meet stringent data privacy and information security requirements to safeguard the confidentiality, integrity, and availability of sensitive information entrusted to them. They must implement robust security measures, including encryption, access controls, and regular security assessments, to protect against unauthorized access, disclosure, alteration, or destruction of data.

Suppliers must also comply with applicable data protection laws and regulations, ensuring proper handling and lawful processing of personal information.

Furthermore, suppliers are expected to promptly report any data breaches or security incidents and cooperate fully in investigations and remediation efforts.

6.1.6 Confidential Information

Suppliers are required to adhere to strict confidential information requirements to protect the sensitive and proprietary information shared with them throughout our business relationship. They must treat all confidential information as highly confidential and use it solely for the purpose of fulfilling their obligations to our organization.

Suppliers are prohibited from disclosing or sharing such information with any unauthorized third parties without our explicit consent. They must implement appropriate security measures to prevent unauthorized access, loss, or theft of confidential information.

Additionally, suppliers must ensure that their employees and subcontractors are bound by confidentiality obligations and take necessary steps to educate and enforce compliance with these requirements.

6.1.7 Antitrust & Competition Laws

Suppliers are required to adhere to stringent antitrust and competition laws requirements to promote fair and competitive business practices. They must conduct their operations in full compliance with applicable laws and regulations, refraining from engaging in any anti-competitive behaviors such as price fixing, bid rigging, market allocation, or abusing their dominant market position.

Suppliers must compete fairly and honestly, avoiding any agreements or practices that may limit competition or harm consumer interests.

Suppliers are expected to promptly report any potential violations and cooperate fully with regulatory authorities in their investigations.

6.1.8 Trade Compliance Laws & Regulations

Suppliers are required to comply with trade compliance laws and regulations to ensure adherence to international trade standards and promote fair and lawful business practices. They must accurately classify and declare goods, in accordance with applicable customs regulations, ensuring proper valuation and adherence to import and export controls.

Suppliers are expected to screen transactions and business partners against relevant sanction lists, ensuring compliance with anti-money laundering and counter-terrorism financing regulations.

Additionally, suppliers must maintain accurate records and provide necessary documentation to support compliance with trade laws and regulations.

6.1.9 Anti-Money Laundering Compliance & Reporting

Suppliers are required to strictly adhere to anti-money laundering (AML) compliance and reporting requirements to prevent the misuse of our business relationships for illicit financial activities. They must establish robust AML policies, procedures, and controls to identify, assess, and mitigate money laundering risks effectively.

Suppliers are expected to conduct due diligence on their customers, partners, and transactions, ensuring that they are legitimate and free from any suspicious activities.

Suppliers must promptly report any suspicious transactions or activities to the relevant authorities, in compliance with applicable laws and regulations. Suppliers are also required to cooperate fully with any AML investigations and audits, providing necessary documentation and support.

6.1.10 Anti-Boycott Compliance Laws & Regulations

Suppliers are required to comply with anti-boycott compliance laws and regulations to ensure adherence to international trade practices that promote fairness and prevent discrimination. They must refrain from participating in any boycotts that are inconsistent with applicable laws and regulations.

Suppliers are expected to conduct their business affairs without engaging in any activities that support or further the objectives of a boycott against any country or entity.

Suppliers must promptly report any requests or demands to participate in a boycott to the appropriate authorities, as required by law.

6.2 Inhumane Treatment

Suppliers are required to guarantee the absence of corporal punishment, physical abuse or discipline, verbal or mental abuse, sexual abuse, or any form of exploitation towards workers.

6.3 Modern Slavery

Suppliers are required to refrain from employing any form of modern slavery in their operations or supply chain. Modern slavery encompasses practices such as human trafficking, forced labor, slavery, servitude, debt bondage, child labor, forced marriage, or deceitful recruitment of workers for labor or services.

Suppliers must ensure that workers are not required to provide deposits or surrender government-issued identity documents, such as passports, as a prerequisite for employment.

To actively contribute to the eradication of modern slavery, suppliers must proactively identify and mitigate modern slavery risks throughout their supply chain.

6.4 Child Labour

Suppliers are prohibited from employing individuals below the legally prescribed minimum working age for the specific work being performed. Furthermore, suppliers must not involve children in any form of modern slavery practices.

Additionally, suppliers must not subject children to hazardous work that could jeopardize their health, safety, or moral well-being.

6.5 Anti-Harassment & Anti-Discrimination

Suppliers are required to adhere to strict anti-harassment and anti-discrimination requirements as part of our commitment to maintaining an inclusive and respectful work environment. They must foster a workplace free from any form of harassment, including but not limited to sexual harassment, discrimination, or any other behavior that creates a hostile or offensive work environment.

Suppliers must ensure that their employees are treated fairly and equitably, irrespective of race, gender, age, religion, disability, or any other protected characteristic. They are expected to have comprehensive policies in place, providing clear guidance on prohibited behaviors and mechanisms for reporting and addressing complaints.

Suppliers must promptly investigate any allegations of harassment or discrimination and take appropriate corrective actions.

6.6 Diversity & Inclusion

Suppliers are required to uphold diversity and inclusion requirements as part of our commitment to fostering an inclusive and equitable business environment. They must actively promote diversity and inclusion within their own organizations by adopting fair employment practices that value and respect individuals from diverse backgrounds.

Suppliers are expected to create opportunities for underrepresented groups, ensure equal access to employment and advancement, and proactively seek diverse perspectives in decision-making processes. They should provide a workplace that is free from discrimination and bias, fostering a culture of inclusivity and belonging.

Suppliers are encouraged to engage in diversity and inclusion training programs and initiatives to raise awareness and build a more inclusive business ecosystem.

6.7 Working Hours & Compensation

Suppliers are required to comply with strict working hours and compensation requirements to ensure the fair and respectful treatment of their employees. They must adhere to applicable laws and regulations regarding maximum working hours, breaks, and rest periods, providing a safe and healthy work environment.

Suppliers are expected to compensate their employees fairly and in accordance with legal requirements, including minimum wage laws and overtime provisions. They should ensure transparent and accurate record-keeping of working hours and remuneration, avoiding any form of wage theft or unfair labor practices.

Suppliers are encouraged to promote work-life balance and employee well-being, supporting initiatives that prioritize the physical and mental health of their workforce.

6.8 Worker Entitlements

Suppliers are required to adhere to the relevant labor laws and applicable industrial regulations of the country where the work is carried out, ensuring that workers receive their rightful entitlements.

It is the responsibility of the suppliers to accurately determine and classify workers as either employees or independent contractors, treating them accordingly. Moreover, suppliers must fulfill all legal obligations owed to the workers to comply with the law.

6.9 Freedom of Association

Suppliers must guarantee the respect of workers' rights to freedom of association and collective bargaining. This includes ensuring that workers have the right to form and join trade unions, as stipulated by local laws.

6.10 Safety, Reporting & Quality

Suppliers will provide their workers with a healthy and safe work environment, and take proactive measures that support accident prevention and minimize health risk exposure.

Suppliers must obtain and keep current all required environmental permits, approvals, and registrations, and follow their operational and reporting requirements.

Suppliers’ materials and products must meet regulatory quality and safety standards, in addition to our internal quality standards, policies, specifications, procedures, and contract requirements.

6.11 Sub-contractors

Suppliers are required to maintain a record of subcontractors and make this register accessible to Rokt upon request.

‍

7. Questions & Feedback

While this Code cannot encompass every possible scenario that suppliers may face, there will be occasions where suppliers must exercise judgment to determine the appropriate course of action. During such instances, we encourage suppliers to engage in open dialogue with us to address the matter. If you have any questions or feedback regarding this Code, please reach out to compliance@rokt.com.