Supplier Code of Conduct

ADM_KPD_20250624_1.01

Supplier Code of Conduct C&F (hereinafter also referred to as the “Supplier Code of Conduct“) defines the principles and standards of behavior expected by C&F S.A., its affiliated and subsidiary companies from their suppliers (“Suppliers“).

C&F S.A. and its affiliated and subsidiary companies are collectively referred to in the further content of the Code as “C&F“.

C&F expects all Suppliers to act in accordance with the highest ethical, legal, and social standards.

The Supplier Code of Conduct defines C&F’s expectations towards Suppliers in three key areas:

1. Formal commitment,
2. Resources and mechanisms ensuring compliance with local and international legal regulations,
3. Transparency and cooperation in the supply chain.

Formal commitment of Suppliers

Suppliers are obliged to:

1. Compliance with the Supplier Code of Conduct and the Code of Ethical Conduct (“Ethical Code“), as well as the policies referenced in the Ethical Code (“Policies“), the content of which indicates that they apply to Suppliers,
2. Promptly inform C&F of any identified or potential violations of the provisions of the Supplier Code of Conduct, the Ethical Code, or the Policies, in connection with the cooperation between the Parties, in the manner specified therein,
3. Make every effort to become familiar with and adhere to the standards provided to them by C&F’s clients,
4. Fully cooperate with C&F and its clients in the process of verifying compliance with the Supplier Code of Conduct, including providing explanations and making available the necessary documents; such verification may take the form of an audit (upon explicit request of C&F’s client), conducted by authorized representatives of C&F, its clients for whom the Supplier provides services, or an external auditor acting on their behalf. The Ordering Party will inform the Supplier of the planned audit with appropriate advance notice, no less than 10 business days,
5. Officially confirm compliance with the Supplier Code of Conduct.

Resources and mechanisms ensuring compliance with legal regulations

C&F expects that Suppliers should have and implement within their own organizations:

1. Policies and procedures implementing the principles and requirements set out in the Supplier Code of Conduct, the Ethical Code, and the Policies,
2. Risk assessment systems and control measures adequate to the scale and nature of their activities,
3. Training for employees and management in the area of legal compliance,

An approach to conducting business in line with the continuous improvement model and documenting actions in this regard.

Transparency, cooperation, and responsibility in the supply chain

C&F expects that Suppliers:

1. Will be open to cooperation in case of any doubts regarding the interpretation of the standards and guidelines contained in the Supplier Code of Conduct, the Ethical Code, or the Policies,
2. Will communicate the principles of the Supplier Code of Conduct to their subcontractors (so-called cascading of requirements),
3. Will implement an effective and secure grievance mechanism, including the option to report anonymously.

Final provisions

1. Suppliers who do not meet these requirements are obliged to promptly implement C&F’s recommendations or, within the specified timeframe, present a corrective action plan and ensure its implementation.
2. The Supplier Code of Conduct forms the foundation of a shared culture of ethics, transparency, and responsibility throughout the entire C&F supply chain.
3. Each Supplier may submit C&F comments, concerns, and objections regarding the content and application of the Supplier Code of Conduct. For this purpose, please contact us by email at: legal@candf.com.