Pisano Supplier Code of Conduct

1. Human Rights Policy

At Pisano, we are deeply committed to the protection and promotion of human rights within our operations and business relationships. Every employee is responsible for upholding the dignity, respect, and rights of their colleagues, customers, and partners. This policy applies to all levels of the organization and our supply chain. We follow the United Nations Guiding Principles on Business and Human Rights, ensuring that our company is free from any practice that may undermine basic human rights.

Key points include:

Ensuring freedom from discrimination, harassment, and abuse.
Providing safe and healthy working conditions for all.
Engaging in continuous evaluation of our operations to assess potential human rights risks.
Offering training and awareness sessions to all employees on human rights issues relevant to our industry.

Any violations of this policy will result in investigation and corrective action. Employees are encouraged to report concerns regarding human rights violations to management or the People and Culture (P&C) department, where confidentiality will be respected.

2. Child Labour Policy

Pisano upholds the highest ethical standards in relation to child labour. We strictly comply with international conventions, such as the International Labour Organization’s (ILO) Minimum Age Convention, and we adhere to local laws governing the employment of minors.

Key principles include:

We do not hire anyone below the legal working age of the country in which we operate.
All suppliers and partners are required to follow the same standards regarding child labour. Contracts with suppliers include clauses preventing the use of child labour, and audits are conducted to ensure compliance.
If any instance of child labour is discovered, Pisano will take immediate action to address the issue, which may include terminating the relationship with the offending supplier or partner.

Employees should report any suspicion of child labour practices either internally or externally to People and Culture. Pisano is committed to taking swift action to rectify such situations.

3. Pisano Modern Slavery and Human Trafficking Policy

At Pisano, we are committed to respecting human rights and upholding ethical business practices. We take a zero-tolerance approach to modern slavery, forced labour, and human trafficking in all forms.

This policy brings together our approach to forced labour, anti-slavery, and anti-human trafficking in one framework, for full compliance with international standards and ethical best practices.

Our Commitment

All employment at Pisano is voluntary; we do not tolerate forced, bonded, or involuntary labour.

Employees have the right to terminate their employment after giving reasonable notice, as outlined in their contracts.

Recruitment is fair and transparent; no worker is ever charged recruitment fees.

All employment contracts are entered into freely and with full consent and will; no one is forced to work under duress or threat.

We do not engage in or support slavery, servitude, or practices depriving individuals of their liberty.

We do not knowingly work with any individual, company, or organisation involved in human trafficking activities.

Governance and Oversight

This policy is reviewed and approved by the Company Signatory Director.

If any incident or activity occurs during the year, a confidential Modern Slavery Statement is shared with the Board of Directors and Company Executive Committee.

Supply Chain Due Diligence

Pisano applies a risk-based approach to supply chain management:

New suppliers undergo vetting and contractual checks.

We apply risk scoring in supplier assessments.

Suppliers are required to share their own modern slavery statements or policies with Pisano.

Pisano may conduct audits to verify supplier compliance with anti-slavery and human trafficking standards.

All business partners, vendors, and suppliers must comply with anti-slavery laws and Pisano’s Supplier Code of Conduct.

Training and Awareness

All employees receive mandatory ethics and modern slavery training as part of onboarding.

Finance and People & Culture teams receive specialised training to identify risk indicators in recruitment and supply chains.

Employees are prohibited from engaging in or supporting forced labour; violations will result in immediate disciplinary action, including termination of employment and potential legal measures.

Reporting and Whistleblowing

Pisano provides a confidential whistleblowing channel, available 24/7 to employees, contractors, and suppliers.

Reports can be made anonymously and are treated seriously, without retaliation.

The whistleblowing channel is independently managed by a third-party consultant within the People & Culture department to ensure neutrality and trust.

Concerns or reports related to modern slavery, forced labour, or human trafficking must be escalated immediately to the People & Culture department or via the whistleblowing channel.

Pisano will take swift and decisive action in response to any violations, including terminating contracts with offending third parties or pursuing legal measures.

Monitoring

In the event of a verified incident, Pisano will take immediate action, including disciplinary measures, contract termination, or legal action if required.

Approval

This policy has been approved by the Company Signatory Director of Pisano.

4. Freedom of Association Policy

Pisano respects and upholds the right of all employees to form, join, and participate in trade unions or employee associations of their choosing. We support collective bargaining to ensure fair working conditions and wages for all employees.

Key policy aspects include:

Employees may engage in lawful trade union activities without fear of retaliation, discrimination, or harassment.
Pisano encourages open communication between employees and management to resolve workplace issues, but we respect the right to escalate such concerns through formal collective bargaining processes.
Any employee who believes their rights to freedom of association are being violated should report the matter to People and Culture or management for investigation.

Pisano provides training on employee rights concerning freedom of association and actively monitors compliance with this policy across all levels of the organization.

5. Non-Discrimination Policy

Pisano is committed to providing a workplace that is free from discrimination. We believe that all employment decisions should be based on qualifications, skills, and abilities, and that personal characteristics unrelated to job performance should never influence employment-related decisions.

Key guidelines include:

Pisano prohibits discrimination on the basis of race, colour, national origin, gender, gender identity, sexual orientation, religion, disability, age, veteran status, or any other characteristic protected by law.
Our recruitment, promotion, compensation, and termination policies are designed to promote fairness and equality.
Any discriminatory behaviour, including harassment or victimization, will not be tolerated and may lead to disciplinary action, up to and including termination of employment.

Pisano provides regular diversity and inclusion training for employees to foster a culture of respect, and any concerns regarding discrimination should be reported directly to People and Culture.

6. Disciplinary Practices Policy

At Pisano, we believe in maintaining a positive and respectful workplace where all employees are treated fairly. When disciplinary action is necessary, it will be conducted in a transparent, respectful, and fair manner, with employees given the opportunity to respond to concerns about their conduct.

Key points include:

All disciplinary actions will be based on clear evidence and aligned with company policies and local laws.
Disciplinary measures range from verbal or written warnings to suspension or termination, depending on the severity of the issue.
Employees have the right to appeal any disciplinary action through the internal grievance process, and Pisano will ensure a fair hearing of all cases.
We do not tolerate any form of physical punishment, mental or verbal abuse, or coercion in the workplace.

Employees are encouraged to maintain open communication with People and Culture or their supervisors if they have concerns about potential disciplinary actions.

7. Working Hours Policy

Pisano values work-life balance and ensures that all employees work within legal limits for working hours and rest periods.

Policy provisions include:

Employees should not be required to work more than the standard working hours as defined by local law, except in cases of voluntary overtime, which must also comply with legal limits.
All employees are entitled to appropriate rest breaks, holidays, and leave as per local regulations and their employment contract.
Pisano offers flexible working arrangements where possible to support employees in balancing their work and personal lives.

Employees who feel their working hours exceed legal or reasonable limits should raise the issue with their supervisor or People and Culture.

8. Wages Policy

Pisano is dedicated to ensuring that all employees receive fair and equitable wages. Compensation will always meet or exceed the minimum wage requirements of the jurisdiction in which we operate.

Key elements include:

Salaries are based on role, experience, and performance, ensuring internal equity and compliance with market standards.
Pisano offers comprehensive benefits, including health insurance, retirement savings plans, and paid time off, in line with local legal requirements.
Employees are paid on time and in full, with any discrepancies being addressed promptly by the Finance or People and Culture departments.

Employees who have concerns about their wages or benefits are encouraged to speak with People and Culture for resolution.

9. Individual Conduct Policy

At Pisano, we expect every employee to adhere to the highest standards of conduct, both personally and professionally.

The policy covers:

Integrity: Employees must act with honesty and uphold Pisano’s ethical standards in all dealings.
Conflict of Interest: Employees must avoid conflicts of interest and disclose any personal interests that could influence their professional decisions.
Professionalism: Employees must treat each other, customers, and business partners with respect and professionalism at all times.

Failure to comply with these conduct expectations may result in disciplinary action. All employees are encouraged to report any breaches of the conduct policy to People and Culture.

10. Health & Safety Policy

Pisano prioritizes the health, safety, and well-being of all employees. We are committed to providing a safe work environment that meets or exceeds local health and safety regulations.

Policy provisions include:

Pisano conducts regular risk assessments to identify potential hazards in the workplace and implements measures to mitigate these risks.
All employees are required to follow safety protocols and report any unsafe conditions or practices immediately.
Pisano provides health and wellness resources, including mental health support and access to wellness programs, to ensure the overall well-being of our workforce.

All employees must participate in health and safety training and are encouraged to suggest improvements to our safety programs.

11. Environmental Policy

Pisano is committed to environmental sustainability and minimizing our ecological footprint.

Key principles include:

Reducing energy consumption and waste through efficient business practices.
Recycling and promoting the use of sustainable materials wherever possible.
Encouraging employees to engage in environmentally friendly practices, both at work and in their personal lives.

Employees are encouraged to participate in our sustainability initiatives and share ideas for reducing Pisano’s environmental impact.

12. Diversity in Supplier Engagement Policy

Pisano promotes diversity and inclusion not only within our workforce but also in our supplier relationships. We are committed to working with suppliers that reflect our values and contribute to our mission of supporting underrepresented groups.

Key guidelines include:

Actively seeking suppliers owned by women, minorities, and underrepresented groups.
Evaluating suppliers based on their commitment to ethical, environmental, and social standards.
Ensuring transparency and fairness in the procurement process.

Employees involved in procurement should follow these guidelines and report any concerns to the Finance or People & Culture departments.

13. Anti-Bribery and Corruption Policy

Pisano enforces a zero-tolerance policy on bribery and corruption in all areas of our business.

Policy provisions include:

Employees are prohibited from offering, accepting, or requesting bribes, kickbacks, or any other form of improper payment or advantage.
Pisano will not engage with any suppliers, partners, or customers who engage in corrupt practices.
All employees must complete anti-bribery training and adhere to local and international anti-corruption laws.

Employees who suspect bribery or corruption are required to report it immediately to People and Culture or use the company’s confidential whistleblower system. Pisano will take swift action, including legal action, if necessary, to address any violations of this policy.

14. Supply Chain Responsibility

Suppliers must ensure that their own suppliers, subcontractors, and business partners comply with the same standards set out in this Code. Pisano expects Suppliers to cascade these requirements throughout their supply chains and take corrective action if any violations are identified.

15. Monitoring and Audits

Pisano reserves the right to monitor compliance with this Code. This may include requesting documentation, conducting assessments, or performing audits, either directly or through an independent third party. Suppliers must provide full cooperation and access to relevant information during such processes.

16. Acknowledgement

By entering into a business relationship with Pisano, Suppliers acknowledge and agree to comply with this Supplier Code of Conduct. Suppliers also commit to ensuring that their own employees, contractors, and supply chain partners are informed of and act in line with these requirements.