Ethical Business Practices Guide for Suppliers

Effective Date: 22 July 2025

Antvora mandates that all entities providing goods or services to us, including vendors, service providers, and contractors (herein referred to as “Suppliers”), operate with the utmost integrity and adhere to sound ethical principles. This document, the Ethical Business Practices Guide for Suppliers (“Guide”), articulates the minimum standards Antvora expects. It’s designed to work in conjunction with the Supplier’s own operational guidelines, legal obligations, and contractual agreements with Antvora.

  1. Legal Compliance

Suppliers must fully comply with all applicable laws, regulations, and standards in the jurisdictions in which they operate. For Suppliers operating in or with ties to Belgium, this includes (but is not limited to):

  • The Code of Economic Law (Code de droit économique)
  • The Act of 4 August 1996 on Well-being at Work and associated Royal Decrees
  • The Belgian Criminal Code, particularly regarding corruption and fraud
  • The Law of 30 July 2018 on the protection of natural persons with regard to the processing of personal data (implementing the EU General Data Protection Regulation – GDPR)
  • The Labour Code and applicable collective labour agreements (CLAs)
  • The Law of 13 April 1995 on the suppression of human trafficking and exploitation
  1. Commitment to Labor and Human Rights

Antvora stands for human rights and fair treatment. We expect our Suppliers to demonstrate the same commitment. Suppliers must implement and maintain policies and practices that protect the rights and dignity of all individuals in their operations and supply chains. Key principles include:

  • Voluntary Employment: Suppliers must not engage in or benefit from any form of forced, bonded, or involuntary labour, including modern slavery and human trafficking. Full compliance with Belgian and EU human rights and anti-trafficking legislation is mandatory.
  • Fair Wages and Working Conditions: Suppliers must pay employees lawfully, provide legally mandated benefits, and ensure that working hours and conditions meet or exceed Belgian labour law and applicable collective agreements.
  • Respectful Workplace: Suppliers must provide a work environment free from discrimination, harassment, and abuse. Employment decisions must be based on merit and comply with anti-discrimination legislation such as the Gender Act and Anti-Racism Act.
  • Health and Safety: Suppliers must offer a safe and healthy workplace in accordance with occupational health and safety legislation, including the Well-being at Work Act and relevant Royal Decrees.
  1. Upholding Ethical Standards

Antvora expects the highest standards of ethical conduct from its Suppliers in all business dealings. This includes:

  • Anti-Corruption: Suppliers must not participate in bribery, corruption, facilitation payments, or other unlawful influence. Full compliance with anti-corruption laws under the Belgian Criminal Code and applicable EU directives is required.
  • Intellectual Property: Suppliers must respect and protect Antvora’s intellectual property rights and those of third parties. Unauthorized use of Antvora trademarks or proprietary materials is strictly prohibited.
  • Data Protection: If handling personal data or confidential information, Suppliers must comply with the GDPR and Belgian privacy laws. They must implement appropriate technical and organisational measures to ensure data security.
  • Accurate Records: Suppliers must maintain transparent, complete, and accurate records of all financial and operational activities.
  • Gifts and Hospitality: Suppliers must not offer or accept gifts, benefits, or hospitality that could improperly influence business decisions. All interactions must comply with Antvora’s internal policies.
  • Conflicts of Interest: Suppliers must disclose any actual or potential conflict of interest, such as family or close personal relationships with Antvora employees, which may affect objectivity or impartiality.
  1. Environmental Stewardship

Antvora is committed to reducing its environmental impact and expects Suppliers to:

  • Manage and minimise their environmental impact;
  • Comply with applicable Belgian and EU environmental laws and regulations, such as the Environmental Code and EU Green Deal provisions;
  • Promote responsible resource use and environmentally friendly practices throughout their operations.
  1. Confidential Information

Suppliers must protect Antvora’s confidential information. “Confidential Information” means any non-public data relating to Antvora that could be used by competitors or cause harm to Antvora or its users if disclosed. Suppliers may not disclose, share, or use this information unless expressly authorised in writing by Antvora or legally required to do so. Confidential data may only be used for the purposes of fulfilling contractual obligations to Antvora. Additional obligations may be set out in individual contracts.

  1. Raising Concerns

Antvora encourages Suppliers to report any ethical concerns, potential violations of this Guide, or other inappropriate conduct. Reports should be submitted to the Supplier’s Antvora contact or via [email protected]. All concerns will be handled confidentially and investigated appropriately.

  1. Enforcement and Review

Antvora reserves the right to monitor Supplier compliance with this Guide. Non-compliance may result in corrective measures, up to and including the termination of the business relationship. This Guide may be updated periodically. Antvora will inform Suppliers of material changes where necessary.