HighRadius Vendor Code of Conduct

Effective Date: September 18, 2024

At HighRadius, we are committed to conducting business with integrity, respect, and fairness. Our Vendor Code of Conduct outlines the principles and standards we expect from our Vendors and business partners to ensure that our collective operations uphold these values. This Code is designed to promote ethical practices, compliance with applicable laws and regulations, and a commitment to sustainable and responsible business practices. By partnering with us, you agree to adhere to these standards, fostering a mutually beneficial relationship built on trust and respect.

HighRadius reserves the right to change this Code from time to time to reflect changes in our practices, technologies, legal requirements and other factors. If we do, we will update the “effective date” at the top of this Vendor Code of Conduct to reflect when those changes began to apply.

Human Rights, Labor and Modern-Slavery

Human Rights

We respect Human Rights. Human rights are the fundamental rights, freedoms and standard of treatment to which all people are entitled. We focus on respecting labor rights, treating people with dignity and respect, enabling healthy and safe work environments, promoting ethical behavior and respecting privacy. Vendors shall uphold and respect human rights as reflected in the United Nations Universal Declaration of Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, the UN Global Compact, and the UN Guiding Principles on Business and Human Rights.

Child Labor

Vendors will not use or condone child labor in any circumstance and must abide by local minimum age laws. Vendors may use legitimate workplace apprenticeship programs, such as student internships, which may allow for fair wages to be paid to the student workers, interns, and apprentice if allowable by law.

Human Trafficking & Modern Slavery

We are committed to opposing modern slavery and human trafficking and have a zero-tolerance approach when it comes to our suppliers. As a growing company, we are continually improving our business processes and policies to ensure full compliance with applicable laws and regulations to combat human trafficking and modern slavery in our supply chain. Our Vendors shall not use slavery and human trafficking nor use the services or products of third parties which are part of the slave trade. Vendors will abide by all human trafficking and forced labor laws including the Trafficking Victims Protection Act (TVPA) of 2000 and the Uyghur Forced Labor Protection Act (UFLPA), the UK Modern Slavery Act 2015 and any other law applicable to the prevention of modern slavery and human trafficking.

Wages

Compensation paid to workers shall comply with all applicable wage laws, including those relating to minimum wages, overtime hours and legally mandated benefits. Vendors will also provide workers with regularly scheduled pay statements or similar documentation which explains the basis for compensation. Vendors must use market and industry standards to apply fair wages where no wage law is in existence. Vendors will not use wage deduction as a means of worker discipline.

Working Hours

Vendors should routinely check the working hours of their workers to ensure their safety and well-being. Working hours, breaks, holidays, and leave periods should be established in compliance with local laws and agreements.

Anti-discrimination

Vendors will not discriminate in screening, hiring, or employment practices (including recruitment, job applications, promotions, job assignments, training, wages, benefits, and termination) based on race, color, age, sex or gender (including sexual orientation, gender identity or expression (including transgender status), childbirth, pregnancy, or related medical conditions), national origin, disability, genetic information, marital status, creed, ancestry, religion, military and veteran status, or any other characteristics protected by applicable federal, state, or local laws and ordinance.

Anti-harassment & Abuse

Vendors will not permit or engage in harassment, abuse, corporal punishment, or inhumane treatment of workers. Vendors will not subject workers or potential workers to unlawful medical tests or physical exams. Vendors are required to provide reasonable accommodations for workers’ disabilities, religious practices, or pregnancy without discriminatory impact on pay or level of employment. Vendors must have an equal opportunity employment policy and will demonstrate a commitment to identify, measure, and improve a culture of diversity and inclusion through all aspects of workplace management.

Freedom of Association

Vendors’ workers will be permitted to associate freely, bargain collectively, and seek representation in accordance with local laws. Vendors must respect workers’ rights to freedom of association and collective bargaining and are expected to permit workers to openly communicate and share grievances with management about working conditions without fear of reprisal or harassment.

Foreign Contract Worker Protections

Vendors shall have a written policy that addresses Foreign Contract Worker (“FCW”) rights as required by applicable laws, rules, regulations, and legally binding procedures. This policy shall include but is not limited to: designating the individual(s) responsible for overseeing that the FCW protections policy is implemented and enforced, a properly managed employment contracting process for FCWs, and language speaking to FCW wages, compensation and benefits.

Grievance Mechanism & Reporting

Vendors’ workers must be able to raise concerns and seek resolution of issues covered by this Code of Conduct confidentially and anonymously, free from retaliation. Vendors are required to create and maintain equitable and effective grievance operations which address: workers’ submission of their grievances, maintenance of an effective resolution process, clear communication to workers, and investigations conducted in a diligent and prompt manner which address workers concerns.

Health & Safety

Occupational Safety & Health

Vendors will comply with all applicable safety and health laws and regulations, and shall identify, evaluate, and manage occupational health and safety hazards through a prioritized process of hazard elimination, substitution, engineering controls, administrative controls, and/or personal protective equipment. Where the foregoing cannot adequately address hazards, vendors will provide workers with appropriate personal protective equipment and information on the potential hazards to them.

Safe Working Conditions

Vendors shall provide and maintain a safe working environment including by providing safe Vendor-controlled facilities, facility infrastructure, and machines. Facilities and vendor-controlled worker environments must meet all legal requirements and integrate prudent health and safety practices.

Emergency preparedness

Vendors shall identify, assess, and plan for potential emergency situations and then implement proper emergency plans and response systems. These emergency plans and response procedures should be designed to minimize harm to life, environment, and property. Additionally, vendor workers should be trained in the response systems and emergency plans on an annual basis.

Sanitation, food & housing

Vendors must provide workers with ready access to clean toilet facilities (which account for the number of onsite workers and individual privacy), safe potable drinking water, and sanitary food preparation, storage, and eating facilities while onsite. If vendors provide workers with residential facilities, those facilities will be clean and safe, with respect for worker’s privacy, entry and exit privileges, emergency egresses, heat and ventilation, hot water for bathing and showering, security, and reasonable travel to and from work locations if not within a reasonable walking distance.

Environmental

Permits & Reporting

Vendors shall obtain, keep current, and comply with all required environmental permits, approvals, and registrations and comply with all applicable operational and reporting requirements.

Waste management: Wastewater, Solid Waste, and Stormwater Management

Vendors are encouraged to implement a systematic approach to identify, monitor, control, and reduce wastewater produced by its operations including seeking opportunities to conserve water. Vendors are encouraged to implement a systematic approach to identify, manage, reduce, responsibly dispose of or recycle, and minimize waste to landfills from their operations.

Resource Efficiency & Clean Energy

Vendors are encouraged to reduce consumption of resources, including fossil fuel, hazardous substances, and water through conservation efforts, reuse, recycling, substitution, or other considerations. We encourage vendors to continuously improve energy efficiency and reduce energy consumption and greenhouse gas emissions.

Pollution Prevention & Air Emissions

Vendors are encouraged to use pollution control equipment, maintenance, and facility processes to help minimize or eliminate air and greenhouse gas emissions, the discharge of air pollutants, and generation of waste. Vendors are also encouraged to establish a greenhouse gas reduction program and publicly report their progress and goals.

Ethics & Compliance

Bribery, Anti-corruption, & Whistleblower Protections

HighRadius is committed to acting fairly and with integrity in all its business dealings and relationships wherever it operates, and we expect the same level of behavior by our Vendors. Vendors should take a zero-tolerance approach to bribery and corruption of any kind, whether committed by its employees or by third parties acting for or on behalf of the vendor and requires that its business be conducted in compliance with all applicable domestic and international anti-corruption and bribery laws, including the US Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act. Bribery of any individual, governmental official or otherwise, is a serious matter, which can lead to criminal sanctions and financial penalties against the vendor and its employees.

Further, vendors should provide workers with a confidential and anonymous complaint mechanism to report suspected or improper conduct such as violations of worker rights, workplace grievances, and unethical business practices. Vendors should also protect whistleblower confidentiality and prohibit retaliation against worker whistleblowers, who in good faith report misconduct by the vendor or an employee or officer of the vendor.

Responsible Artificial Intelligence

Vendors that develop (or contribute to developing), train, or use artificial intelligence (AI) should do so according to legal requirements and should strive to develop and follow an AI code of conduct which addresses: ethical use, privacy protection, bias mitigation, accountability, and setting of AI principles.

Trade Sanctions

Vendors must be committed to complying with all applicable trade sanctions regulations in the countries of operation. Sanctions are regulatory restrictions on dealings with certain countries, governments, groups, entities or individuals (and those acting on their behalf). For example, sanctions lists have been issued by the UN, the EU, and the US (including the US Office of Foreign Asset Control (OFAC)) which include Cuba, Iran, North Korea, Sudan, Syria, the Crimea Region of Ukraine, narcotics traffickers, human rights abusers, and terrorists, among others. This list is meant to be illustrative and not exhaustive. Vendors should implement, maintain, and enforce policies to prohibit or restrict transactions or business relationships that may violate applicable sanctions laws.