Supplier Code of Conduct

Uplands OneTelco Ltd is committed to conducting business with integrity, transparency, and responsibility. We expect our suppliers, subcontractors, service providers, and partners to meet the same high standards. This Supplier Code of Conduct outlines the ethical, environmental, and social expectations we place on our supply chain.

This Code applies to all suppliers working with or on behalf of Uplands OneTelco Ltd and should be communicated within their own organisations and supply networks.

1. Legal and Regulatory Compliance

Suppliers must comply with all applicable local, national, and international laws and regulations. This includes, but is not limited to:

• Labour, employment, and human rights legislation

• Health and safety regulations

• Environmental protection laws

• Anti-bribery and anti-corruption legislation, including the UK Bribery Act 2010

• The UK Modern Slavery Act 2015

• Data protection and privacy laws

2. Labour and Human Rights

Suppliers must respect and uphold fundamental human rights in line with international standards, including:

• No use of forced, bonded, or involuntary labour

• No child labour under the minimum legal working age

• Fair working hours, wages, and conditions that meet or exceed legal requirements

• A working environment free from harassment, abuse, and discrimination

• Respect for freedom of association and the right to collective bargaining

3. Health, Safety, and Wellbeing

Suppliers must ensure a safe and healthy working environment for all workers. This includes:

• Assessing and managing health and safety risks

• Providing appropriate personal protective equipment (PPE)

• Maintaining emergency procedures and first aid measures

• Supporting employee wellbeing and access to relevant support resources

4. Environmental Responsibility

Suppliers must actively manage and reduce their environmental impact. This includes:

• Compliance with environmental laws and regulations

• Efficient use of energy, water, and raw materials

• Waste reduction and responsible disposal of hazardous materials

• Reduction of greenhouse gas emissions where possible

• Adoption of environmentally friendly products and packaging where feasible

5. Ethical Business Conduct

Suppliers are expected to act with integrity and transparency in all business dealings. This includes:

• Zero tolerance for bribery, corruption, fraud, or unethical practices

• Avoidance of conflicts of interest in dealings with Uplands OneTelco

• Honest and accurate financial and business reporting

• Compliance with competition and anti-trust laws

• Responsible marketing and advertising practices

6. Responsible Sourcing and Supply Chain Transparency

• Suppliers must ensure their own supply chains are transparent and ethical. This includes:

• Cascading similar expectations to their own suppliers and subcontractors

• Avoiding the use of suppliers that violate human rights or environmental standards

• Cooperating with Uplands OneTelco on any due diligence, audits, or assessments when requested

• Taking action to identify and mitigate risks related to modern slavery or environmental harm

7. Confidentiality and Data Protection

• Suppliers must safeguard confidential information and comply with all applicable data protection laws. This includes:

• Protecting personal and commercial data against loss, misuse, or unauthorised access

• Ensuring only appropriate individuals have access to sensitive information

• Reporting any breaches or risks in a timely manner

8. Whistleblowing and Reporting Concerns

Suppliers must foster a culture where concerns about unethical, illegal, or unsafe conduct can be reported without fear of retaliation. Any concern related to this Code of Conduct or involving Uplands OneTelco Ltd should be reported to:

b.hooper@uplands.co.uk

9. Compliance and Enforcement

Uplands OneTelco Ltd reserves the right to review compliance with this Code. Failure to comply may result in corrective actions, suspension of business, or termination of the supplier relationship.

Acknowledgement

By continuing to supply goods or services to Uplands OneTelco Ltd, suppliers confirm that they understand and accept the principles outlined in this Code of Conduct.