Supplier Code of Conduct

This Supplier Code of Conduct applies to suppliers of Flowmax Limited and all its subsidiaries, who are collectively referred to as “the Group”.

Introduction

The Group’s reputation, credibility, and long-term success depend on our total commitment to ethical business practices. We conduct our business with transparency, honesty, and accountability, and we expect the same from every supplier with whom we work.

This Supplier Code of Conduct (“Code“) has been developed to communicate our expectations to all suppliers, including their parent companies, subsidiary entities, affiliates, subcontractors, and other third parties within their supply chain.

This Code functions as a supply chain initiative. The Group expects that its suppliers will cascade equivalent expectations throughout their own supply chains.

This Code supplements, but does not replace, any other contractual agreements between the Group and its suppliers, including product-specific standards or quality requirements.

Scope

The standards set out in this Code apply to all Group suppliers, including their directors, officers, employees, agents, subcontractors, and any other parties acting on their behalf.

Suppliers are expected to communicate, educate, and verify compliance with this Code within their own organisations and supply bases.

The Group expects its suppliers to provide, upon reasonable request, complete, accurate, and timely information regarding their products, services, contractual conditions, and any transactional or compliance data relevant to this Code.

The Group reserves the right to verify compliance with this Code through internal reviews, third-party assessments, or independent audits. In the spirit of continuous improvement, the Group is committed to engaging constructively with suppliers to address any areas of non-compliance.

Where a supplier is found to be in material breach of this Code and fails to remedy such breach within a reasonable timeframe, the Group reserves the right to terminate its commercial relationship with that supplier.

Key Principles

The Group is committed to maintaining and perpetuating the highest standards of ethics and business conduct. These principles apply universally across all of our operations and geographies, and we expect our suppliers to uphold equivalent standards.

Our values are grounded in the following commitments, which we ask our suppliers to reflect in their own conduct:

• acting with honesty and integrity in all business dealings;
• treating all people — employees, customers, suppliers, and communities — with fairness, dignity and respect;
• taking responsibility for the social and environmental impact of business activities;
• maintaining transparency in all commercial and financial dealings;
• supporting the communities in which we and our suppliers operate; and
• striving to deliver superior value to customers and stakeholders while upholding ethical standards at all times.

The Group and its suppliers operate across various geographic areas and cultural contexts, these values and the expectations set out in this Code have universal application.

Social Responsibility

The Group expects all suppliers to comply with, and preferably exceed, all applicable social legislation and regulations in the jurisdictions in which they operate. This includes a commitment to monitor and comply with new and evolving regulations.

Human Rights and Labour Standards: Suppliers shall acknowledge and uphold the principles of the United Nations Global Compact, the Universal Declaration of Human Rights (UDHR), and the International Labour Organization (ILO) Fundamental Principles and Rights at Work, including the prohibition of:

• forced, compulsory, or trafficked labour in any form;
• child labour, as defined by applicable ILO conventions;
• unlawful or unjustified restrictions on freedom of association and collective bargaining;
• discrimination in hiring, remuneration, training, promotion, or dismissal on grounds of race, colour, sex, sexual orientation, gender, religion, nationality, disability, age, marital status, or any other characteristic protected by applicable law.

Employment Practices: Suppliers shall adhere to the principle of good employment, ensuring that labour conditions and the well-being and development of employees are guaranteed. In particular, suppliers shall:

• offer employment agreements that comply with all applicable laws and regulations, including those relating to wages, working hours, and rest periods;
• ensure that any collective labour agreements comply with applicable laws and regulations;
• treat all employees with dignity and respect, and provide a workplace free from harassment, bullying, intimidation, or abuse;
• commit to equal opportunity employment practices, recruiting and managing employees without unlawful discrimination; and
• take all reasonable steps to maintain a safe and healthy working environment for all employees.

Community Engagement: The Group expects its suppliers to be responsible corporate citizens. Suppliers shall:

• design and implement policies that comply with international, national, and local laws relating to community engagement and social responsibility;
• strive to contribute positively to the communities in which they operate, including through social responsibility programmes and support for local initiatives; and
• actively encourage employee participation in community activities, including volunteer programmes and the transfer of skills and knowledge for the benefit of local communities. 
  
  Environmental Responsibility

The Group expects all suppliers to comply with, and preferably exceed, all applicable environmental laws and regulations. This includes a commitment to monitor and comply with new and evolving environmental requirements.

Suppliers must demonstrate a positive and proactive approach to environmental management, including with respect to issues directly related to their products, services, and operations.

Suppliers shall take active steps to reduce their environmental impact, including in relation to:

• energy consumption and greenhouse gas emissions;
• waste generation, recycling, and responsible disposal;
• transport and logistics efficiency;
• packaging design and use of sustainable materials; and
• the efficient use and conservation of natural resources.

Suppliers shall implement and maintain sustainable solutions across their products, services, and processes, consistent with the principles of a circular economy and responsible resource use.

Preference will be given to suppliers who hold, or are actively working towards, a certified environmental management system, such as BS EN ISO 14001, the EU Eco-Management and Audit Scheme (EMAS), or an equivalent system validated by a recognised third party (such as SEDEX, EcoVadis, or Achilles).

Health, Safety and Welfare

The Group expects all suppliers to comply with, and preferably exceed, all applicable health and safety legislation and regulations, and to commit to monitoring and implementing new health and safety requirements as they emerge.

Suppliers shall demonstrate a positive and proactive approach to health, safety, and welfare across their operations. In particular, suppliers shall:

• provide clear instructions, adequate information, and appropriate training to ensure all employees are competent to perform their roles safely;
• consult and engage with employees on day-to-day health and safety matters;
• implement an active programme to achieve zero workplace accidents, including through the reporting and investigation of accidents, incidents, near misses, and dangerous occurrences;
• maintain plant, equipment, and machinery in good condition to reduce risk and ensure worker safety; and
• ensure the safe handling, storage, and use of all substances hazardous to health.

Suppliers shall maintain documented health and safety policies, risk assessments, and emergency procedures, and shall make these available to the Group upon request.

Preference will be given to suppliers who hold, or are actively working towards, a certified health and safety management system, such as BS EN ISO 45001, OHSAS 18001, or an equivalent system validated by a qualified third party.

Quality

The Group expects all suppliers to comply with, and preferably exceed, all applicable quality-related legislation, regulations, and standards, and to commit to ongoing monitoring of new quality requirements.

Suppliers shall maintain suitable, auditable quality management systems, policies, procedures, and records, and shall make these available to the Group upon request.

Suppliers shall engage with the Group as a genuine partner in the development and continual improvement of processes, products, and services to exceed the expectations of our customers.

Suppliers are encouraged to collaborate with the Group on the innovation and development of new technologies, products, and services that improve efficiency, reliability, and sustainability, and that minimise waste and prevent pollution.

Suppliers shall develop and maintain effective strategies to identify, prevent, and address the counterfeiting of their products, and shall provide prompt support and assistance to the Group to detect and manage any such issues.

Preference will be given to suppliers who hold, or are actively working towards, a certified quality management system, such as BS EN ISO 9001, or an equivalent system validated by a qualified third party.

Business Ethics and Responsibility

Anti-Bribery and Anti-Corruption: The Group has a zero-tolerance policy towards bribery and corruption in all forms. Suppliers shall not offer, give, request, or accept any bribe, financial inducement, or improper advantage, whether in cash or in any other form, to or from any individual or organisation, including public officials, private individuals, or employees of any other business. This prohibition:

• applies in every jurisdiction in which a supplier operates;
• applies to all directors, officers, employees, agents, and representatives of the supplier; and
• extends to all dealings with third parties, including public authorities and regulatory bodies.

Conflicts of Interest: Business decisions made by a supplier’s employees must not be influenced by personal interests or other factors unrelated to legitimate business considerations. Suppliers shall take all reasonable steps to identify, disclose, and manage conflicts of interest within their organisations.

Gifts and Hospitality: Suppliers shall not seek or offer gifts, hospitality, or any other form of compensation to employees of the Group or its subsidiaries that could influence, or appear to influence, a business decision. Any exception must be modest in value, transparent, and consistent with applicable laws and the policies of both parties.

Confidentiality: Suppliers shall protect the confidentiality of all information received from the Group. Confidential information, including technical, financial, commercial, and employee information, must not be disclosed to any third party without the prior written consent of the Group, and must be used solely for the purpose for which it was shared. Suppliers shall implement appropriate measures to protect such information from loss, theft, misuse, or unauthorised access.

Accurate Record-Keeping: Suppliers shall maintain honest, accurate, and complete business records and financial accounts in accordance with applicable accounting principles and legal requirements. No secret funds or unrecorded assets shall be maintained under any circumstances.

Competition and Fair Trade: Suppliers shall comply with all applicable competition, fair trade, and anti-trust laws and regulations in the jurisdictions in which they operate.

Political Neutrality: The Group does not make financial contributions to, or provide support for, any political party, and expects its suppliers to maintain equivalent political neutrality in their commercial dealings. Suppliers’ employees are free to engage in lawful personal political activity in a manner that respects the views and beliefs of others.

Business Continuity: Suppliers shall maintain a business continuity plan that includes provisions for the safeguarding, storage, and recovery of documentation relevant to any contract or transaction with the Group. The plan shall also include contingency measures to maintain supply chain capability in the event of significant disruptions, including utility interruptions, labour shortages, equipment failure, or logistics failures.

Anti-Money Laundering: Suppliers shall comply with all applicable anti-money laundering laws and regulations, including, where relevant, the Proceeds of Crime Act 2002, the Terrorism Act 2000, the Fraud Act 2006, and the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (as amended). Suppliers shall not engage in, facilitate, or knowingly benefit from any transaction that constitutes or involves the proceeds of criminal activity.

Use and Protection of Assets: Suppliers shall ensure that all corporate assets, whether tangible (including property, vehicles, and equipment) or intangible (including intellectual property, business information, and customer data), are used responsibly and protected from loss, misuse, or unauthorised disclosure.

Data Protection and Privacy

Where suppliers process personal data on behalf of, or in connection with, the Group, they shall do so in accordance with all applicable data protection laws and regulations, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

Suppliers shall implement appropriate technical and organisational measures to protect personal data against unauthorised access, loss, destruction, or disclosure.

Where personal data is transferred outside the United Kingdom or the European Economic Area, suppliers shall ensure that appropriate safeguards are in place, including reliance on European Commission adequacy decisions or equivalent approved transfer mechanisms.

Compliance and Reporting

All suppliers are expected to understand, accept, and adhere to this Code.

Suppliers shall promptly report to the Group any actual or suspected breach of this Code, whether within their own organisation or their supply chain.

If any employee or representative of a supplier has knowledge of or reasonable suspicion of non-compliance with this Code, they are encouraged to raise such concerns through appropriate internal channels and, where appropriate, directly with the Group.

Failure to comply with this Code may result in:

• a requirement to implement a corrective action plan within a timeframe agreed with the Group;
• suspension of the commercial relationship pending resolution of the non-compliance; or
• termination of the commercial relationship in cases of serious or persistent non-compliance.

The Group is committed to working constructively with suppliers to address concerns and support improvement, and will not treat good-faith reports of concerns as grounds for adverse commercial action.