Code of Conduct

1. Scope and principles

This Code of Conduct applies to all OXORY employees, freelancers, partner specialists, subcontractors and suppliers. It is based on the Ten Principles of the UN Global Compact, the UN Guiding Principles on Business and Human Rights, the OECD Guidelines for Multinational Enterprises and the ILO core labour standards.

• Comply with the law: We comply with applicable law at all times. Where these principles go further, they apply in addition.

• Customer requirements: Stricter contractual or customer sustainability requirements take precedence and are passed on to everyone involved.

• Leadership responsibility: Management embeds these values in day-to-day business, appoints a responsible person and ensures training.

2. Human rights and working conditions

• No child or forced labour: We observe the minimum employment age and tolerate no forced or compulsory labour, debt bondage, modern slavery or human trafficking – in our own area and at our partners.

• Fair recruitment: We do not mislead anyone about the nature of the work, charge no placement fees to specialists and never retain identity documents. Contracts are written or electronic, understandable and set out rights and obligations clearly.

• Fair compensation: We pay at least the statutory minimum wage or the agreed fees – directly, in full and on time.

• Working hours, health and safety: We comply with working-time rules, provide safe and healthy workplaces (including home office and customer sites) and promote a healthy work-life balance.

• Respect and diversity: We tolerate no discrimination, harassment or intimidation – in particular on grounds of origin, skin colour, gender, gender identity, sexual orientation, religion, age, disability, pregnancy or parenthood, union membership or political persuasion. Work of equal value receives equal pay.

• Freedom of association: We respect the right to form and join employee representation bodies and to bargain collectively.

• Protect human rights: We do not contribute to human rights violations, tolerate no threats against human rights or environmental defenders, and exclude corporal punishment and violence.

3. Integrity and business ethics

• No corruption: We reject bribes, kickbacks and facilitation payments. Gifts and hospitality are appropriate, transparent and never tied to a favour in return.

• Avoid conflicts of interest: Decisions are based on objective criteria, not on personal interests or relationships.

• Fair competition: We enter into no anti-competitive agreements, exchange no competitively sensitive information and do not abuse a market position.

• Trade controls, sanctions, money laundering: We comply with import, export and sanctions rules and with legal provisions against money laundering.

• Confidentiality, data protection, IP: Trade secrets and personal data are lawfully collected, processed, protected and deleted. We respect the intellectual property of others.

• Responsible AI: We use AI only within applicable law, design it to be reliable and non-discriminatory, and keep control with humans. Confidential customer or personal data does not belong in unapproved AI tools.

• No support for armed groups: Our business does not contribute, directly or indirectly, to supporting non-state armed groups.

4. Environment and resources

• Conserve resources: We use energy, water and materials efficiently, avoid waste and dispose of electronics and equipment properly.

• Reduce emissions: We cut emissions, for example through remote and nearshore delivery, combined travel, energy-efficient IT and – where possible – renewable electricity. On request we give customers the available data on energy use and CO₂ emissions.

• Responsible procurement: When procuring, for example hardware, we look for responsibly sourced raw materials – free of conflict minerals, deforestation and deep-sea mining – and protect biodiversity, water, soil and air.

5. Responsible supply chain and partners

• Pass requirements on: We contractually pass these requirements on to subcontractors, freelance partners and suppliers and work to ensure they reach the wider supply chain.

• Risk-based checks: We assess partners appropriately (e.g. self-assessment, risk analysis) and disclose relevant supply chain information to customers on request.

• Remedy violations: We address identified or imminent violations without delay, stop them or minimise their impact, implement a time-bound action plan where needed and take part in customer training.

6. Reporting, grievances and implementation

• Raise concerns: Anyone who suspects a violation can contact info@oxory.net in confidence – anonymously if preferred. Whistleblowers are protected from retaliation.

• Access to reporting channels: We do not hinder access to grievance procedures – neither our own nor our customers' whistleblower systems – and pass this obligation on to partners.

• Consequences: Reports are examined promptly, fairly and confidentially. Violations may have employment or contractual consequences, up to termination of the relationship.

• Audits: We enable customer audits within the legal framework – during normal business hours and in compliance with data protection.