Business Code of Conduct 2023

The information captured in the sections below is intended as a reference point, but it is not exhaustive and is liable to change as corporate social responsibilities evolve.

Hutchison Technologies Ltd promotes fair working practices across our businesses. Our Business Code of Conduct outlines the principles, practices and behaviours that we are committed to upholding in all of our operations. This includes a supplier framework, environmental policy, health & safety policy, an employment framework and our commitment to the Modern Slavery Act of .2015

1.0 Supplier Framework
Effective co-operation between ourselves and our suppliers is critical to the sustainable success of our supplier framework relationship. A core value of our supplier relationship is our shared commitment to conduct our respective businesses with uncompromising integrity and professionalism whilst meeting ethical expectations, Hutchison Technologies’ colleagues are required to comply with the ethical rules set out in our code of conduct in addition to other legal business practices.

We expect our supplier, global partners, vendors, agents and contractors with whom we do business to operate to the same exacting legal and ethical standards. Integrity in our supply chain is of vital importance to our business and other stakeholders. Any queries about adhering to the expected standards of ethical practices should be referred to me, Mark Hutchison.

1.1 Environmental Policy
Our environmental policies and management procedures are targeted at reducing the environmental impacts affected by our activities. Our environmental impact minimisation practices include the addition of electric vehicles to our company fleet, and the installation of a range of environmental measures in our new head office premises in the UK including enhanced energy- efficiency, the use of sustainable materials, and eco-friendly lighting. In addition to these measures, Hutchison Technologies pledge to do the following:

• Integrate environmental awareness into our decision-making and operations.
• Engage in ethical waste management practices.
• Engage in working practices that minimise the use of pollutants wherever possible.
• Recycle or reuse as much as possible.
• Minimise energy usage, water usage, and natural resource consumption within our facilities and processes.
• Train and educate our employees on environmental issues surrounding their work.

1.2 Health & Safety Policy
Hutchison Technologies Ltd are committed to ensuring safety is the first priority in everything we do. Managers work with our colleagues to ensure that health and safety considerations are the first priority at every level of our planning and decision-making. Our values expect our colleagues to take personal responsibility for securing their own safety and the safety of others, stopping unsafe acts when safe to do so. Our commitment to safety includes:

• Named persons have been appointed for emergency response, health and safety, and fire marshal responsibilities in each of our facilities.
• Named persons appointed as first aiders in each of our facilities.
• Accident reporting, accident investigation and lessons learned practices are operated.
• Safety training delivered to colleagues and personal protective equipment supplied.
• An appropriate system is in place for the disposal of hazardous materials in all of our facilities.
• Our electrical components and the systems used in our facilities or during contracted works offsite, are properly maintained and meet legal required for annual testing.
• Working environments meet standards for noise control, ventilation, cleanliness, heat control, facilities provision, etc. to provide comfortable and safe working conditions.

1.3 Our Recruitment Policy
Hutchison Technologies Ltd promotes employee welfare and protects workers’ rights, believing that this has a positive impact on personal wellness, productivity, workplace culture and our business success. We operate legally compliant employment practices with enhanced protections a common feature. We will ensure the following:
• Discrimination on the basis of age, disability, sex, sexual orientation, gender reassignment, ethnicity, race, marital status, religious or philosophical belief, pregnancy or maternity, or other individual difference is not acceptable within our business.
• People are treated fairly, equally, without prejudice and with care to avoid any unconscious bias.
• We will treat personal data in accordance with the Data Protection Act 2018.
• We are committed to providing a balanced and healthy work environment.
• We exceed statutory requirements regarding working hours, pay, and entitlement to leave.
• Induction practices support new team members settle into our business.
• Learning and development is at the heart of our growth mindset.
• Our vacancies are open to internal and external candidates.
• Training is provided to our employees undertaking recruitment activities.
• We will use technologies to help deliver our fair recruitment practices.

1.4 Equal Opportunities and Diversity Policy
Hutchison Technologies are committed to:
• Promote and maintain an inclusive and supportive work environment, protecting the rights of individuals to equal, fair and respectful treatment; enabling people to reach their potential.
• Investing in development and learning to encourage an open and honest culture.
• Provide policies, procedures and ways of working that protects fair and a consistent treatment for all.
• Act promptly and consistently to address breaches of conduct standards we expect.
• Support managers, colleagues and our external partners to value and proactively support the unique characteristics of the people with whom we work and conduct business with.
• Upholding a workplace culture that understands, protects and promotes diversity and equal treatment.

1.5 Whistleblowing Policy
Under certain circumstances, colleagues are protected from suffering any detriment or termination of employment if they make disclosures about organisations for whom they work. Although certain circumstances are covered by law, Hutchison Technologies maintains a policy on safeguarding its colleagues.

1.6 Anti-Slavery Policy
Hutchison Technologies complies with the Modern Slavery Act 2015 and operate a zero-tolerance approach to modern slavery and human trafficking. We are committed to upholding and respecting human rights. We recognise that the practice of modern slavery takes varying forms including servitude, forced labour, child labour, human trafficking, and any and all forms of the deprivation of one’s liberty by another for personal or commercial gain. We pledge to act ethically and with integrity in all our business dealings and supply chain relationships, and never to knowingly use products or services derived in any part from the practice of modern slavery in any of its forms. Our anti-slavery policy forms part of our contract with all suppliers and they are required to confirm that no part of their business operations contradicts this policy. We may terminate contracts at any time should any instances of modern slavery come to light.