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Suppliers Code of Conduct

Introduction

Galooli and its subsidiaries (collectively, the “Company” or “Galooli”) are committed to upholding the highest standards of integrity and corporate governance practices. This commitment is mirrored in our comprehensive Code of Conduct available on the Company’s website (https://galooli.com/code-of-conduct/).

This Suppliers Code of Conduct is an extension of our overarching Galooli Code of Conduct, ensuring ethical, legal, sustainable, and respectful business interactions with our suppliers.

Galooli is dedicated to ongoing enhancement in preventing modern slavery and maintaining ethical practices across its supply chain. Galooli will review this Supplier Code of Conduct annually and reserves the right to amend, modify, or otherwise change this code at its sole discretion whenever necessary.

1. Purpose and Scope

Galooli has created this Supplier Code of Conduct to outline the Company’s expectations for how suppliers should operate to uphold internationally recognized human and labor rights, ensure ethical conduct, and minimize environmental impact. All suppliers supplying products and services to or on behalf of Galooli are expected to comply with this Supplier Code of Conduct.

Suppliers are accountable for complying with this Code and must ensure that it is enforced throughout their entire production and procurement processes, including all employees, partners, suppliers, and subcontractors. Additionally, this Supplier Code of Conduct must be considered in conjunction with local laws and any other contractual obligations agreed upon between the supplier and Galooli. It is not intended to conflict with or alter the terms and conditions of any existing contract. Unless otherwise specified in such a contract, in the event of a conflict, suppliers shall adhere to the contract terms.

If a supplier fails to comply with this Supplier Code of Conduct, the Company may review the business relationship with that supplier and take corrective action as necessary, subject to any applicable contract and arrangement. This may include, but is not limited to, the termination of such contract or arrangement.

2. Labor and Human Rights

Galooli is fully committed to protecting human rights and employee rights. The importance of these topics is highlighted in the Company’s Code of Conduct. The Company expects its suppliers to share its commitment to human rights, employee rights, and equal opportunity in the workplace and encourages suppliers to have similar policies and practices.

  • 2.1 Freely Chosen Employment: All employment with the supplier must be voluntary. All Galooli suppliers are expected to abstain from directly or indirectly relying on, engaging in, or allowing any form of slavery, forced labor, or human trafficking. Additionally, they must not use any partners, suppliers, or subcontractors who engage in forced labor. Galooli suppliers are expected to provide their workers, as part of their hiring process, with a written employment agreement in their native language that contains a description of the terms and conditions of employment. Galooli suppliers are also expected to abstain from holding or otherwise destroying, concealing, confiscating, or denying access to employees’ identity or immigration documents.
  • 2.2 Child Labor: Child labor is strictly prohibited. Galooli suppliers are not allowed to employ children under any circumstances and must adhere to all relevant laws and regulations regarding working age. This commitment requires verification of all workers’ ages and the maintenance of accurate records to eliminate child labor. In addition, suppliers must avoid any collaboration with partners, suppliers, or subcontractors known to utilize child labor. Suppliers are responsible for taking preventative actions to guarantee they do not employ anyone below the legal minimum working age in the location where the work is performed.
  • 2.3 Working Hours: Workweeks must not surpass the maximum limit established by local law. Employees must be allowed at least one day off every seven days. Additionally, any practices that prevent workers from sleeping, such as mandatory overtime or excessive work hours, are strictly prohibited. Suppliers are expected to monitor and regulate working hours to ensure compliance with these standards, promoting a healthy and sustainable work environment for all employees.
  • 2.4 Wages and Benefits: Galooli suppliers must ensure that the compensation paid to their workers complies with all applicable wage laws in their countries, including those related to minimum wages, overtime hours, and legally mandated benefits. Workers must be compensated for overtime at the appropriate rate. Deductions from wages as a form of disciplinary action are strictly prohibited. For each pay period, workers must be provided with a timely and understandable wage statement that includes sufficient information to verify the accuracy of the compensation for work performed. Suppliers are expected to maintain transparent and fair wage practices to promote worker satisfaction and trust.
  • 2.5 Humane Treatment: Galooli suppliers must abstain from any form of harsh or inhumane treatment of their employees. This includes, but is not limited to, any form of sexual harassment, sexual abuse, corporal punishment, mental or physical coercion, or verbal abuse. Suppliers are expected to foster a work environment that respects the dignity and rights of all employees. Any actions or behaviors that undermine these principles are strictly prohibited. Suppliers must implement clear policies and training programs to prevent such misconduct and ensure that any violations are promptly addressed and rectified.
  • 2.6 Non-Discrimination: Galooli suppliers must be committed to maintaining a workforce free from harassment and unlawful discrimination. Suppliers shall not engage in any form of discrimination based on race, ethnicity, national origin, religion, age, color, sex, sexual orientation, gender identity, disability, pregnancy, political affiliation, union membership, protected veteran status, or any other category protected under local law, regulation, or ordinance. This commitment requires creating an inclusive work environment where all employees are treated with fairness and respect. This includes implementing policies and practices that promote equality and prevent discrimination in all aspects of employment, from hiring and promotion to compensation and termination.
  • 2.7 Freedom of Association: Suppliers must acknowledge employees’ legal rights to form and join trade unions of their choice and to engage in collective bargaining. Additionally, suppliers should not discriminate against or favor members of employee organizations or trade unions. Employees and/or their representatives must be able to openly communicate and share ideas and concerns with management regarding working conditions and management practices without fear of discrimination, retaliation, intimidation, or harassment. 

3. Environment and Sustainability

At Galooli, sustainability isn’t just a goal; it’s part of our vision and organizational DNA. Galooli is dedicated to conducting its business in an environmentally responsible manner from start to finish. We are committed to minimizing adverse effects on and beyond our immediate working environment, from the inception of our operations to the delivery of our solutions. Galooli encourages its suppliers to make similar efforts, appropriate to their businesses, and to actively participate in our journey toward Net Zero. Additionally, we urge our suppliers to adopt practices that align with relevant international standards.

  • 3.1 Waste: Galooli is committed to minimizing waste throughout its supply chain. We expect our suppliers to adopt practices that reduce or eliminate waste, ensuring its safe and compliant handling, storage, transportation, and disposal. This includes prioritizing recycling, reuse, and responsible management of all waste, with particular emphasis on hazardous materials. Suppliers must adhere to all relevant environmental laws and regulations regarding waste management and restricted substances.
  • 3.2 Energy and Greenhouse Gas Emissions: Suppliers should seek cost-effective ways to enhance energy efficiency. They are encouraged to regularly monitor their energy consumption to identify areas for improvement. It is recommended that suppliers set specific, measurable targets for reducing greenhouse gas emissions and track their progress toward these goals. Additionally, suppliers are urged to increase their use of renewable energy sources wherever feasible, integrating sustainable practices into their operations to support a reduction in their overall environmental impact.
  • 3.3 Wastewater: Wastewater from operations, industrial processes, and sanitation facilities must be properly managed to minimize environmental impact. This includes characterizing, monitoring, controlling, and treating wastewater to meet all applicable standards and regulations before discharge or disposal. Suppliers are expected to implement advanced treatment processes to ensure that wastewater does not harm the environment. Additionally, proactive measures should be taken to reduce the volume of wastewater generated at the source through process optimization, water recycling, and conservation initiatives.
  • 3.4 Storm Water Management: Suppliers are encouraged to adopt a comprehensive and systematic approach to prevent contamination of storm water runoff. This includes implementing best practices for managing storm water to ensure that pollutants and hazardous substances do not enter storm drains. Suppliers should establish procedures to prevent illegal discharges and spills, ensuring that any potential contaminants are properly contained and treated. Regular monitoring and maintenance of storm water management systems should be conducted to identify and address any issues promptly.
  • 3.5 Materials Restrictions: Suppliers must comply with all applicable laws and regulations regarding the prohibition or restriction of specific substances in products and manufacturing processes. This includes adhering to guidelines that limit the use of hazardous or environmentally harmful materials. Suppliers are highly encouraged to use environmentally friendly materials in their production processes and ensure that all products are accurately labeled for recycling and disposal to facilitate proper end-of-life management, in line with directives such as the European Waste from Electrical and Electronic Equipment (WEEE). Additionally, suppliers are encouraged to stay informed about and implement best practices for material restrictions, continuously seeking safer and more sustainable alternatives.

4. Health and Safety

Galooli suppliers are committed to creating a safe and healthy work environment for their employees. This commitment extends to requiring all employees, partners, suppliers, and subcontractors to comply with applicable safety and health regulations wherever they operate. Additionally, suppliers are expected to provide training to educate their workforce on health and safety best practices.

  • 4.1 Potential Safety Hazards: Potential safety hazards, including but not limited to electrical, electronic, chemical, machinery, and other dangers, must be effectively controlled through proper design, engineering, logistics, and administrative controls.
  • 4.2 Preventive Maintenance and Emergency Preparedness: Preventive maintenance and safe work procedures and practices should be established and regularly updated. Furthermore, Galooli suppliers should identify and assess potential emergency situations and events associated with their operations, as well as implement measures to minimize their impact. This includes developing comprehensive emergency plans and response procedures, such as employee evacuation protocols, regular worker training and drills, effective fire detection systems, adequate exit facilities, and recovery strategies. These plans and procedures should prioritize minimizing harm to life, protecting the environment, and safeguarding property. Suppliers must ensure that all emergency preparedness practices are regularly reviewed and updated to maintain a high level of readiness and resilience.
  • 4.3 Industrial Hygiene: Galooli suppliers must strive to minimize workers’ exposure to chemical, biological, and physical hazards. To control and mitigate exposure, suppliers should implement appropriate administrative, logistical, and engineering controls. This includes measures such as ventilation systems, safe handling procedures, and the substitution of less harmful substances where possible.
  • 4.4 Injury and Illness Prevention: Galooli suppliers will seek to establish and maintain robust procedures and systems to prevent, manage, monitor, and report occupational injuries and illnesses. This includes the implementation of comprehensive protocols for tracking and documenting incidents, ensuring timely and effective responses. When occupational injuries or illnesses occur, suppliers are required to conduct thorough investigations to identify root causes and implement corrective actions to prevent recurrence. These measures should aim to create a safer work environment and promote the health and well-being of all employees.
  • 4.5 Human Factors: The ergonomics of the employees’ working environment is of paramount importance. Suppliers should take steps to ensure that workspaces are designed to minimize physical strain and discomfort. Furthermore, workers should be encouraged to raise safety concerns without fear of retaliation, fostering a culture of continuous improvement and vigilance in workplace safety.
  • 4.6 Physically Demanding Work: Galooli suppliers must identify, evaluate, and manage employees’ exposure to physically and non-physically demanding tasks that pose potential risks. This includes, but is not limited to, activities such as manual material handling, heavy or repetitive lifting, prolonged standing, and highly repetitive or forceful assembly tasks. Suppliers should implement measures to assess these risks and introduce controls to minimize the impact on workers. This can include ergonomic interventions, task rotation, mechanical aids, and proper training to ensure that employees can perform their duties safely and efficiently.

5. Ethics

Galooli prioritizes ethical conduct and legal compliance in all aspects of its business. This commitment extends to our suppliers, who are expected to ensure their employees, partners, and subcontractors understand and follow these same principles. We require our suppliers to conduct business with integrity, fairness, honesty, and avoid conflicts of interest. Bribery, corruption, fraud, money laundering, and any other form of illegal and unethical activity are strictly prohibited.

  • 5.1 Transparency: Galooli requires transparency in all business dealings, with accurate reflection in suppliers’ financial records. To ensure compliance with anti-corruption laws, suppliers must implement monitoring and enforcement procedures.
  • 5.2 Confidentiality and Data Protection: To ensure confidentiality, Galooli requires suppliers to protect all shared business information. This includes following data protection laws to safeguard personal and sensitive data. In some cases, Galooli may request a Non-Disclosure Agreement (NDA) for additional protection.
  • 5.3 Fair Competition: Galooli requires suppliers to uphold fair competition laws. This means avoiding practices like price fixing, dividing up markets or customers, or rigging bids with competitors.
  • 5.4 Intellectual Property: Galooli expects suppliers to respect intellectual property rights, including patents, copyrights, trademarks, and trade secrets. This includes protecting intellectual property during technology transfers, and safeguarding customer information.
  • 5.5 Grievance Mechanism and Identity Protection: Suppliers must ensure confidentiality, anonymity, and protection for employee whistleblowers, unless restricted by law. Employees of suppliers should feel free to raise workplace concerns without fearing retaliation or facing any direct or indirect penalties, sanctions, or punishment.
  • 5.6 Protection from Land Grabbing: Suppliers must respect the land rights of local communities and individuals. Suppliers are required to ensure that all land acquisitions and use are conducted in a lawful, ethical, and transparent manner. This includes obtaining free, prior, and informed consent from affected communities and ensuring fair compensation for any land acquisitions. Suppliers must not engage in or support practices that result in the involuntary displacement of people or expropriation of land without proper consultation and agreement with the rightful landowners and occupants. 

6. Reporting Code Violations

Galooli’s Partnerships and Operations departments oversee this Supplier Code of Conduct as necessary. For any questions regarding this document, please contact the Chief Partnership Officer in Tel-Aviv, Israel, at +972.3.565.6900. Suppliers are required to report any known violations of this Suppliers Code of Conduct. They may do so confidentially or anonymously, by contacting Galooli at: