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SPARESTO SOLUTIONS PRIVATE LIMITED

Supplier Code of Conduct

1

INTRODUCTION

Sparesto Solutions Private Limited (“Sparesto”) is committed to conducting business with integrity, transparency, sustainability, and respect for human rights. Our suppliers, contractors, consultants, service providers, and business partners play a critical role in supporting our operations and maintaining our reputation.

This Supplier Code of Conduct (“Code”) establishes the minimum standards and expectations that all suppliers must comply with while conducting business with Sparesto.

2

LEGAL AND REGULATORY COMPLIANCE

Suppliers shall comply with all applicable national, state, and local laws, regulations, rules, and industry standards relevant to their operations.

This includes, but is not limited to:

  • • Labour laws and employment regulations
  • • Environmental regulations
  • • Occupational health and safety requirements
  • • Anti-corruption and anti-bribery laws
  • • Taxation and statutory compliance
  • • Data protection and privacy regulations

Suppliers must maintain all required licenses, permits, registrations, and certifications necessary for their business activities.

3

HUMAN RIGHTS AND LABOUR PRACTICES

3.1 Respect for Human Rights

Suppliers shall uphold internationally recognized human rights and treat all employees with dignity, fairness, and respect.

3.2 Forced Labour

Sparesto strictly prohibits any form of forced, bonded, trafficked, involuntary prison, or compulsory labour.

Employees shall have the freedom to leave employment after reasonable notice in accordance with applicable laws.

3.3 Child Labour

Suppliers shall not employ any person below the legal minimum working age prescribed by applicable law.

Appropriate age verification procedures shall be maintained.

3.4 Fair Compensation and Working Hours

Suppliers shall provide wages, benefits, and working conditions that comply with applicable labour laws.

Employees shall receive compensation for overtime work and adequate rest periods.

3.5 Non-Discrimination

Suppliers shall provide equal employment opportunities without discrimination based on:

  • • Gender
  • • Age
  • • Religion
  • • Caste
  • • Nationality
  • • Disability
  • • Marital status
  • • Ethnicity
  • • Political affiliation
  • • Any other legally protected characteristic

3.6 Freedom of Association

Employees shall have the right to freely associate, join trade unions, and engage in collective bargaining in accordance with applicable laws.

4

HEALTH, SAFETY AND WELLBEING

Suppliers shall provide a safe and healthy working environment for all employees and visitors.

This includes:

  • • Compliance with occupational health and safety regulations
  • • Provision of suitable Personal Protective Equipment (PPE)
  • • Hazard identification and risk mitigation
  • • Emergency preparedness and response plans
  • • Regular safety training and awareness programs
  • • Safe handling, storage, transportation, and disposal of hazardous materials
  • • Access to clean drinking water, sanitation facilities, and hygienic working conditions

Suppliers operating in industrial, manufacturing, or renewable energy sectors shall maintain robust safety management systems.

5

ENVIRONMENTAL RESPONSIBILITY

Sparesto encourages suppliers to minimize environmental impacts and promote sustainable business practices.

Suppliers shall:

  • • Comply with environmental laws and regulations
  • • Reduce energy consumption and greenhouse gas emissions
  • • Optimize water usage
  • • Reduce waste generation
  • • Promote recycling and reuse initiatives
  • • Properly manage hazardous substances
  • • Prevent pollution and environmental damage
  • • Support sustainable sourcing practices

Environmental performance improvement shall be encouraged through measurable objectives and continuous monitoring.

6

BUSINESS ETHICS AND INTEGRITY

6.1 Anti-Bribery and Anti-Corruption

Suppliers shall not engage in bribery, corruption, fraud, extortion, embezzlement, or money laundering.

No supplier shall offer, provide, solicit, or accept any improper payment, gift, entertainment, or benefit intended to influence business decisions.

6.2 Fair Competition

Suppliers shall comply with all applicable competition and antitrust laws.

Practices such as bid rigging, market allocation, collusion, and price fixing are strictly prohibited.

6.3 Conflict of Interest

Suppliers shall avoid situations that create actual or perceived conflicts of interest.

Any potential conflict involving Sparesto personnel must be disclosed immediately.

6.4 Intellectual Property Protection

Suppliers shall respect and protect intellectual property rights, proprietary information, trademarks, copyrights, patents, and confidential business information.

6.5 Counterfeit Materials

Suppliers shall implement controls to prevent counterfeit, unauthorized, or substandard materials from entering the supply chain.

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RESPONSIBLE SUPPLY CHAIN MANAGEMENT

Suppliers shall promote responsible sourcing and ethical supply chain practices.

Suppliers are expected to:

  • • Source materials responsibly
  • • Ensure transparency and traceability
  • • Avoid materials linked to human rights abuses
  • • Conduct due diligence on their own suppliers
  • • Comply with applicable conflict minerals regulations

Suppliers shall take reasonable measures to ensure their subcontractors and vendors comply with standards equivalent to this Code.

8

DATA PRIVACY AND CONFIDENTIALITY

Suppliers shall protect confidential information belonging to Sparesto, its customers, employees, and business partners.

Suppliers shall:

  • • Maintain appropriate information security controls
  • • Prevent unauthorized access, disclosure, alteration, or loss of data
  • • Protect personal information in accordance with applicable privacy laws
  • • Use confidential information only for authorized business purposes

Confidential information shall not be disclosed without prior written authorization.

9

GRIEVANCE AND WHISTLEBLOWER PROTECTION

Suppliers shall establish appropriate mechanisms allowing employees and stakeholders to report concerns without fear of retaliation.

Reports may include concerns relating to:

  • • Human rights violations
  • • Workplace misconduct
  • • Fraud or corruption
  • • Safety violations
  • • Environmental non-compliance

Suppliers shall investigate reported concerns promptly and fairly.

Retaliation against whistleblowers is strictly prohibited.

10

MONITORING, AUDIT AND COMPLIANCE

Sparesto reserves the right to assess supplier compliance through:

  • • Supplier evaluations
  • • Documentation reviews
  • • Site inspections
  • • Compliance audits

Suppliers shall cooperate fully with such assessments.

Failure to comply with this Code may result in:

  • • Corrective action requirements
  • • Suspension of business activities
  • • Removal from approved supplier lists
  • • Termination of contractual relationships
11

REPORTING VIOLATIONS

Any violation of this Supplier Code of Conduct may be reported to:

Sparesto Solutions Private Limited

Email: purchase@sparesto.com

Attention: Legal & Compliance Department

12. ACKNOWLEDGEMENT

By conducting business with Sparesto Solutions Private Limited, suppliers acknowledge and agree to comply with the requirements of this Supplier Code of Conduct and to promote these principles throughout their organization and supply chain.

Sparesto Solutions Private Limited reserves the right to amend, revise, or update this Code from time to time.