DANTE GENOMICS GROUP SUPPLIER CODE OF CONDUCT
(Version Effective March 15, 2023)

Introduction

Dante Genomics Group Corp. and its subsidiaries (collectively, “Dante Group”) are committed to ethical behavior in all their operations. We are committed to business integrity, responsible product sourcing, the safety and wellbeing of workers across the global supply chain and to driving compliance with the letter and the spirit of the laws and regulations that apply to our business. We hold our business partners, suppliers, contractors, and vendors (collectively “Suppliers”) to these same standards.
This Supplier Code of Conduct (Supplier Code) establishes the minimum standards that must be met by Suppliers that sell goods or services to Dante Group. Suppliers must comply with the standards established in the Supplier Code throughout their operations and ensure compliance throughout their own supply chain by their suppliers, vendors, agents, and subcontractors (Partners).

Dante Group Supplier Standards

Labor and Human Rights

No Child Labor

  • Suppliers must not employ workers younger than the greater of
    • 15 years of age or 14, where allowed by local law, and consistent with standards established by the internation labor organization core conventions
    • the age for completing compulsory education, or
    • the minimum age established by applicable local law
  • Supplier shall not, and shall ensure that its Partners do not, support or engage in, or require any hazardous labor to be perfomed by any person under the age of 18. Hazardous labor involves any work, that by its nature or the circumstances in which the work is undertaken, involves substantial risk of harm to the safety or health of the worker or coworkers if adequate protections are not taken.
  • Suppliers must comply with all local legal requirements for the work of authorized young workers, including, but not limited to the laws covering hours of work, wages, and working conditions.

No Forced Labor
All labor must be voluntary. Supplier shall not support or engage in slavery or human trafficking in any part of its supply chain.

  • Supplier shall not, and shall ensure that its Partners do not, support or engage in, or require any:
    • compelled, involuntary, or forced labor
    • bonded labor
    • indentured labor
    • prison labor.
  • Supplier shall not hold or otherwise destroy, conceal, confiscate or deny access by employees to their indentity or immigration documents, unless such holdings are required by law.
  • Supplier shall not, whether or not as a condition to the right to work, require any worker (or worker’s spouse or family member) to, directly or indirectly:
    • pay recruitment or other fees or other amounts (monetary or in-kind)
    • incur debt
    • make financial guarantees
    • incur any other financial obligation.
  • Supplier shall ensure that workers have the right to freedom of movement without:
    • delay or hindrance
    • the threat or imposition of any discipline, penalty, retaliation, or fine or other monetary obligation.
  • Supplier shall allow workers to terminate their employment or work arrangement without restriction and without the threat or imposition of any discipline, penalty, retaliation, or fine or other monetary obligation.

Compensation
Supplier must meet or exceed the minimum wage requirements as defined under applicable labor laws, applicable agreements and local regulations for regular work, overtime work, production rates and other elements of compensation and employee benefits.


Work Hours
Absent extradordinary business circumstances, Supplier shall not require or allow workers to work more than the lesser of sixty (60) hours per week, including overtime, or the maximum legally permitted number of hours worked per week permitted by local law.


No Discrimination, Abuse, or Harassment
Suppliers shall treat workers with respect and dignity. Supplier shall not subject workers to corporal punishment, or physical, verbal, sexual, or psychological abuse or harassment. Supplier must not condone or tolerate such behavior by its Partners.


Freedom of Association
Suppliers must recognize and respect the rights of workers to exercise lawful rights of free association including joining or not joining any associations. Suppliers must also respect applicable laws regarding workers’ rights related to collective bargaining.


Workplace Health and Safety

  • Supplier shall provide a safe, healthy, and sanitary working environment in accordance with applicable laws and regulations.
  • Supplier shall implement procedures and safeguards to prevent workplace hazards, and work-related accidents and injuries, including procedures and safeguards to prevent industry-specific workplace hazards, and work-related accidents and injuries.
  • Supplier shall provide workers adequate and appropriate training and personal protective equipment to protect workers against hazards typically encountered in the scope of work.

Environmental Stewardship

  • Suppliers must have an understanding of their environmental impact, responsibilities and risk and are encouraged to address their commitment to greenhouse gas emission reductions and engage in the development of climate-friendly technologies and/or practices.
  • Suppliers shall conduct their operations in compliance with all applicable environmental laws, including laws and international treaties relating to waste disposal, emissions, discharges, and hazardous and toxic material handling.
  • Suppliers must ensure that any goods sold to Dante Group (including the inputs and components that it incorporates into its goods) comply with all applicable environmental laws and treaties.

Lawful and Ethical Business Practices

  • Supplier shall comply with all applicable national and local laws and regulations, including but not limited to the laws and regulations relating to the topics covered in this Supplier Code. Where this Supplier Code requires a higher standard than set out by law or regulation, Supplier shall meet the higher standard.
  • Supplier shall comply with Dante Group’s Anti-Bribery Policy policy and all applicable anti-bribery laws including the US Foreign Corrupt Practices Act, the UK Bribery Act, and local laws addressing the bribery of government and/or non-government officials.
  • Suppliers must avoid conflicts of interest in their relations with Dante Group. Business decisions must not be influenced by personal, family or other outside considerations.
  • Suppliers must comply with and have appropriate policies governing all import and export controls, sanctions and other trade compliance laws.

Confidentiality and Data Protection

  • Suppliers must protect Dante Group’s confidential information, including intellectual property and personal information.
  • Suppliers shall apply adequate data privacy and security protection to individuals’ personal information processed on behalf of Dante Group and will operate in a manner consistent with applicable data protection laws.

Questions, Concerns and Violations

Communications and Reporting
Suppliers must self-report any actual or suspected violations of the Supplier Code. Supplier can also submit questions and comments regarding the Supplier Code via any of the following channels:

  • Your Dante Group Supply Chain representative
  • The Dante Group Ethics and Compliance Office via legal@dantelabs.com

Dante Group will review all concerns received and expect Suppliers to coorperate fully to ensure a meaningful and thorough investigation. Suppliers should have their own systems to receive concerns, conduct investigations, and take corrective measures when appropriate.


Good Faith Reporting and Retaliation
Supplier shall not retaliate or take disciplinary action against any worker who has, in good faith, reported violations or questionable behavior, or who has sought advice regarding this Code of Conduct. Suppliers must take appropriate measures to prevent retaliation and address confirmed allegations as necessary.


Right to Audit
Dante Group reserves the right to audit for Dante Group, or an appointed agent, Suppliers’ adherence to this Code of Conduct, including by requesting (and receiving) documents providing evidence, such as wage and time records, personnel information, or purchasing records, or by visiting Suppliers on-site. Dante Group expects its Suppliers to also reserve the right for such audits of their suppliers.


Indemnification
Dante Group reserves the right to request indemnification for any costs incurred as a result of Suppliers’ non-compliance with this Policy or its non-compliance with the audit requests made by Dante Group.


Termination
Dante Group may immediately terminate its business relationship with Supplier if Supplier or its Partners fail to comply with the Supplier Code.

Adherence to the Supplier Code of Conduct.
I declare that I have received the Dante Group Supplier Code of Conduct and that after reading and understanding its contents, I agree to the rules contained in this document and assume the commitment to follow the principles of this Code in my relationship with Dante Group.
I assume responsibility and commitment to report any behaviour or situation that is contrary to the principles established in this Code to my Dante Group professional designated to oversee the contract between the parties and/or Dante Group’s Ethics and Compliance Office.
At this time, I am unaware of any circumstances that might generate any conflicts with the rules contained in the Dante Group Supplier Code of Conduct, or any situations that violate it, except those stated below in the appropriate field.

Finally, regarding possible conflicts, I hereby inform the following:

i. Provision of services or supplies to companies in the public sector or public agencies;
ii. All relevant information about any investigation or proceeding, in case the company or any of its legal representatives, administrators, consultants, etc. under investigation or responding for any legal action related to corruption, bribery, fraud, money laundering, breaches of human rights or applicable environmental law or regulation.
iii. Potential or actual conflict of interest:
iv. Further violations of the Code of Conduct.

 

 

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