Supplier Code of Conduct

MWINGZ – Supplier Code of Conduct


MWingz considers that people, society and planet are its core pillars and aims to contribute to
economical, environment, technological and social progress while achieving sustainable development.

MWingz aims to ensure sustainable growth by making social, societal and environmental issues a

MWingz wants technological contribution to be beneficial, ethical and respectful of human rights and
kinder to the environment to give individuals, communities and whole nations the confidence to take
advantage of the digital world.

MWingz strives to reducing digital inequalities by offering inclusive solutions that are accessible to as
many people as possible. Therefore, MWingz requires the Supplier to implement these Principles (see 2.Underlying Principles
below) through its whole supply chain.

This Supplier Code of Conduct is not intended to replace the laws and regulations in force in the
country where MWingz suppliers operate. It seeks to encourage and respect these laws and
regulations, and ensure that they are faithfully and effectively enforced.

1. Relationship with National and International Law

In addition to complying with the following provisions as detailed in sections 1 to 6 below, the Supplier
shall always comply with applicable laws, regulatory provisions and all contractual obligations as
agreed between the Supplier and MWingz (“the Parties”).
In the event of a discrepancy between national laws and the standards in this policy, the former shall
prevail, although the standards in this policy must be adhered to insofar as possible.
The Parties agree that adhering to this Supplier Code of Conduct is an essential contractual obligation
under the Contract. A Contract meaning an agreement between MWingz and the Supplier regardless
of the form of such Agreement (T&C, master agreement, oral agreement etc.).
The Supplier shall bind its contractors and/or subcontractors (herein after referred to as
“Subcontractors”) to the Principles of this Supplier Code of Conduct insofar as they are involved in
provisioning deliverables under the Contract.

2. Underlying Principles

MWingz considers that sustainable business goes hand in hand with a firm adherence to human rights
and therefore requires the Supplier to equally respect and adhere to human rights and in particular,
the Universal Declaration of Human Rights, the European Convention on Human Rights and the United
Nations Convention on the Rights of the Child.
The Supplier shall respect the integrity, personal dignity and the rights of each individual.

3. Corporate Social Responsibility, Health and Safety

3.1 Freedom of Association and the Right to Collective Bargaining
MWINGZ respects the right to freedom and the right to collective bargaining and requires its Suppliers
to act accordingly.
The Supplier shall seek to implement internationally recognized standards, such as ILO Conventions,
and will not violate national legislation. It shall ensure that its employees and representatives including
temporary (agency) workers may openly express themselves in their company concerning matters
related to their working conditions.

3.2 Child Labour
Child labour is strictly prohibited. “Child labour” means the definition of ILO-IPEC and of Article 32 of
the United Nations Convention on the Rights of the Child (UNCRC). The Supplier shall not engage in
child labour or any form of forced labour, as defined by ILO conventions.

3.3 Anti-slavery and forced labor
MWingz requires the Supplier to take a firm stance against every for of slavery and/or human
trafficking and urges the Supplier to join MWINGZ in the fight against such practices.
The use of forced, bonded or compulsory labor is prohibited, and employees are free to leave their
employment after reasonable notice. Employees are not required to lodge deposits of money or
identity documents with their employer.
Each and every form of slavery is forbidden. The Supplier shall also adhere to all standards drawn up
by the International Labour Organization (ILO).

3.4 Diversity and Non-Discrimination
The Supplier shall prohibit and fight discrimination based on race, colour, sex, sexual orientation,
language, disability, religion, political or other opinion, national or social origin, property, birth or
other status.
The Supplier shall promote diversity, equality of opportunity and treatment in all employment
The Supplier shall treat all employees with respect and shall not use corporal punishment, mental or
physical coercion, any form of abuse or harassment or threat of such treatment.

3.4 Remuneration
The Supplier shall provide remuneration according to national legal standard on minimum wage and
avoid any wage deductions as disciplinary measure. Where no national legal standards exist, the
remuneration shall be sufficient to meet basic needs (ILO C131 – Minimum Wage Fixing Convention).
The basis on which workers are paid be clearly conveyed to them in a timely manner. The Supplier
shall not use deductions from wages as a disciplinary measure.

3.5 Working hours
Working hours, including overtime, shall comply with applicable local laws. Where no national legal
standards exist, ILO standards shall apply. The Supplier shall respect the individual worker’s need for
recovery and secure that all workers have the right to adequate leave from work with pay.

3.6 Health and Safety
The Supplier shall provide its workers with a safe and healthy workplace and should implement
effective programs to – where necessary – improve the working environment. The Supplier shall do its
utmost to control hazards and take necessary precautionary measures against accidents and
occupational diseases. The Supplier shall provide adequate and regular training to ensure that workers
are educated on health and safety issues. This shall include provision and instructions to use
appropriate personal protective equipment. The Supplier shall secure that, where it provides
accommodation, it shall be clean, safe and meet the basic needs of the workers, and, where
appropriate, for their families. The Supplier is encouraged to implement a Health & Safety
Management System based on international standards such as OHSAS 18001 or similar.

3.7 Disciplinary practices
Employees must be treated with respect and dignity. Physical or verbal abuse, including sexual
harassment and sexual abuse or any other form of harassment is prohibited. Any threats or other
forms of intimidation are prohibited

4. Environmental Responsibility Practices

4.1 Environmental protection
MWingz is devoted to do business with respect for the environment and requires the Supplier to act
The Supplier shall undertake initiatives to promote greater environmental responsibility, and
encourage the development and diffusion of environmentally friendly technologies.
The Supplier shall act in accordance with relevant local and internationally recognized environmental
standards and applicable local laws, whereby the highest standard shall be applied especially including
ROHS and WEEE (as detailed further in the respective Contract).
The Supplier shall minimize its environmental impact and should implement measures contributing to
the protection of the environment.
MWingz expects Suppliers to follow the rules of circular economy during the whole product life-cycle:
conception, development, production, transport, use and disposal and/or recycling. The Supplier shall
minimize or strive to avoid hazardous air emissions, energy consumption and CO2 emissions.
In particular, the Supplier shall develop products and services that feature low energy consumption
and CO2 emission reduction during the whole life cycle.
The Supplier shall obtain and adhere to all necessary permits and strive for the implementation of an
Environmental Management System based on international standards such as ISO 14001.

4.2 Natural Resources and waste management
The Supplier shall limit the use of materials and resources when sourcing or producing goods in order
to minimize its environmental impact.
The Supplier is encouraged to track the source of conflict minerals, to promote transparency along its
own supply chain and to put in place measures for this purpose.

All laws and regulations must be obeyed and all actions conducted in a manner that conserves
resources. Processes must be in place to actively improve the efficient use of finite resources (energy,
water, raw materials). Measures must be in place to minimize the release of harmful emissions and
the impact of products and services on the environment. All waste materials must be disposed of
properly and in an environmentally responsible manner.
The use of rare resources shall be limited or avoided where possible. If used, these rare materials or
components containing such materials should be visually identifiable, and easily extractible as far as
possible to ease the recycling.
The waste produced by all its activities, shall be identified, monitored and managed. The Supplier shall
strive to reduce the waste. Waste treatment shall be in accordance with applicable environmental

5. Prohibited Business Practices

5.1 Anti-Corruption
MWingz firmly opposes and bans every form of corruption and handles a zero tolerance standard in
this regard. The Supplier shall refrain from any form of corruption or actions that could potentially be construed
as such. The Supplier may not offer, promise or grant illegal benefits to national or international public officials
or decision-makers operating in the private sector in order to achieve a preferential treatment or
favorable decision; same applies when dealing with donations, gifts or invitations to business meals
and events.

The Supplier may not allow itself to be promised or offered advantages, and shall not accept the same
if this may or shall create the appearance to the party bestowing the advantages that it can thus be
influenced in business decisions. Likewise, the Supplier may not request advantages. The Supplier shall
avoid conflicts of interest that may lead to risks of corruption.
If the Supplier is also a customer of MWingz, it shall not draw any unfair advantages from this and
shall keep procurement and sales strictly separate.
Supplier undertakes, and requires its directors, officers, employees, suppliers, affiliates,
Subcontractors and each respective representative (hereinafter the “Third Parties”):
– to respect the rules of this Section 5.1 together with the regulations as stated in Section 1
(“the Rules”), by appropriate means for the effective implementation and maintaining of a
compliance framework;
– that (i) Third Parties involved in the performance of the Contract comply with the Rules and
that (ii) every necessary means used by Third Parties for the performance of the Contract
comply with the Rules. In order to ensure compliance with the Rules for the duration of the
Contract, the Supplier shall provide on demand and at all time to MWingz all elements
requested to establish such compliance, and shall inform MWingz without any delay, when it
knows or has reason to know, of any failure to comply with the Rules by itself or any Third
Party, as well as the corrective measures adopted to ensure compliance with the Rules. A
material non-compliance with the Rules may trigger a termination of the Contract in
accordance with its provisions.

5.2 Competition
The Supplier shall respect and adhere to national, European and international competition law.

5.3 Sponsorship
All sponsoring measures by Suppliers must be in accordance with current legislation.

5.4 Political Contributions
The Supplier shall not donate money or grant any monetary benefits to any political party unless
permitted by law.

5.5 Money Laundering
The Supplier shall take all measures to prevent money laundering within its sphere of influence.

5.6 Data Security and Data Protection
The Supplier shall adhere to all applicable data protection laws (including the GDPR) and all specific
data protection and security requirements agreed to in the Contract.
The Supplier commits to only process personal data to the extent strictly necessary to execute the

6. Monitoring and Social, Environmental, Compliance Audits

In order to ensure compliance with the Principles as outlined in the Supplier Code of Conduct for the
duration of the Contract, the Supplier shall provide on demand all elements requested to establish
such compliance, and shall inform MWingz without any delay, when it knows or has reason to know,
of any failure to comply with the Principles by itself or by any Subcontractor, as well as the corrective
measures adopted to ensure compliance with the Principles.

In case of modification of the legal and/or regulatory framework as well as any judicial decision that
would imply violation of the Principles by one of the Parties, MWINGZ may introduce the relevant
modifications that the Supplier shall adhere to.
If not covered in the Contract, the following shall apply for Social, Environmental and Compliance

MWingz and/or its authorized representative are entitled to conduct monitoring activities
towards the Supplier and its Subcontractors to evaluate the Supplier’s and Subcontractors’
actual conformity with the Principles. This includes the MWINGZ’s and/ or its authorized
representative’s right to perform audits including on-site inspections, questionnaires and/ or
interviews with selected employees at Supplier’s premises, construction sites and/ or other
locations where work is carried out on behalf of the Supplier.

The Supplier acknowledges that MWingz has the right to request and receive further
information (e.g. EcoVadis/E-TASC/ self-assessments), if deemed necessary. At the request of
MWingz, the Supplier shall inform MWingz of the measures adopted to ensure compliance with the Principles. In the case of non-conformity with the Principles, any non-conformity shall
be notified to MWINGZ and followed by a dedicated improvement plan that needs to be
fulfilled in due course.

MWingz also reserves the right to ask any documented evidence (procedure, certification,
report, …) linked to a CSR (Corporate Social Responsibility) evaluation. For any contract
amounting to min 125.000 € MWingz reserves the right to request a CSR evaluation delivered
by any third party professional CSR organization (e.g. Ecovadis, Achilles, Oekom Research,
Enablon, SMETA audit by SEDEX, …), and this within 3 months from contract signature. This
third party questionnaire is at the cost of the Supplier.

Version 1 – 15/03/2021

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