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Sustainable Procurement Policy

Version: 1.0

Revision History

Version	Date (DD/MM/YYYY)	Prepared / Revised by	Reviewed By	Approved By	Reason for Change
1.1	03/10/2024	Bhupendar Bhandari	Management Committee	Governance Body	New Policy

Table of Contents

1	Introduction	Page 3
2	Expectation from Vendors	Page 3
2.1	Environmental Commitment	Page 3-5
	a) Protecting our environment	Pages 3-4
	b) Waste Management Pag	Page 4
	c) Energy Efficiency	Pages 4-5
2.2	Socially Responsible	Pages 5-6
	a) Human Rights & Labour	Page 5
	b) Child Labour	Page 6
	c) Occupational Health & Safety	Page 6
2.3	Good Governance	Pages 6-8
	a) Ethical Business Conduct	Page 7
	b) Product Quality & Safety	Page 7
	c) Information Security	Page 7
	d) Business Continuity	Pages 7-8
3	Accreditations	Page 8
4	Vendor Registration Questionnaire	Page 8
5	Compliance with Vendor Code of Conduct	Page 8

1. INTRODUCTION

• 1.1

  At Velocis Systems Private Limited, including all its subsidiaries and Group Companies (hereafter called “the Company”) we are guided by our company values. These values guide our conduct and interactions within the Company and with our clients, members, suppliers, shareholders, and other stakeholders. The Company acknowledges that our vendors' social and environmental performance significantly contributes to our long-term business success. We are dedicated to identifying and minimising adverse social and environmental impacts throughout our supply chain. We have developed the Sustainable Procurement Policy to uphold this commitment, reflecting our core values.

• 1.2

  The policy applies to all our new and existing vendors, suppliers, distributors and service providers (collectively, “Vendors” and each “a Vendor”) supplying products, equipment, materials, or providing services, including software solutions under a contract, agreement, or arrangement. This also includes employees, workers, agents, and representatives of such vendors.

• 1.3

  Our sustainable supply chain strategy outlines a comprehensive, long-term approach to managing and maintaining vendor relationships. This strategy is supported by a robust set of business procedures that guide vendor screening, selection, and engagement.

2. EXPECTATION FROM VENDORS

The Company is committed to managing its business in an environmentally and socially responsible manner. The procurement of all products, equipment, materials, services, and software solutions will adhere to the following principles. We expect our vendors to collaborate on these aspects and partner with us to advance sustainable business practices.

• 2.1

  Environmental Commitment: Procurement offers strategic opportunities to reduce Greenhouse Gas (GHG) emissions and we aim to make use of the potential of procurement to fully contribute to the climate mitigation objectives. In this regard, the climate impact of products, equipment, materials, services, and software solutions may be considered during the procurement process whenever feasible. This includes prioritising low-carbon solutions and evaluating suppliers' carbon footprints where possible.

• • a)

    Protecting our environment: It is expected that vendors -

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    Comply with all applicable local, regional and international environmental health and safety laws and regulations of their respective countries and localities. This includes compliance with laws related to hazardous materials, air emissions, sludge, waste, and wastewater discharges, including the manufacture, transportation, storage, disposal, and release of such materials into the environment

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    Obtain the necessary environmental permits and approvals, and ensure proper registration and reporting as required by local regulations relevant to their business location

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    Adopt sustainable environmental practices in their daily operations, including the use of renewable energy sources, durable, reusable, and energy-efficient products, software, and hardware equipment

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    Adopt sustainable environmental practices in their product manufacturing and development, operations, including the use of low-emission manufacturing practices, the use of renewable energy and the implementation of eco-friendly product designs

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    Implement climate risk management strategies and take measures to enhance water efficiency in their operations through conservation efforts

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    Promote ethical mineral sourcing by minimising the use of resources, such as energy, water, and natural materials in their operations and ensure that sourcing practices reduce environmental damage

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    Comply with all relevant legislation and ensure the identification, labelling, and management of chemical or hazardous substances in products that may pose a risk to human health and the environment

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    Implement practices in their operations that minimise or eliminate the use of hazardous or toxic substances

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    Conduct product assessments and consider design and manufacturing aspects to minimise environmental impact

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    Maintain transparency of the supply chain and on request, provide information on the countries of origin for the rare earth elements (RRE), in case they are used in - products, materials and components supplied to the Company

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    Maintain transparency of the supply chain and on request provide information on equipment/product manufacturing details including certifications (such as ENERGY STAR, BEE Certified, Electronic Product Environmental Assessment Tool (EPEA), TCO Development Certified, Blue Angel), use of reused materials (plastic and metal) and recyclable part percentages

• • b)

    Waste Management: It is expected that vendors -

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    Comply with all applicable local, national, and international regulations regarding the management, transportation, storage, and disposal of hazardous wastes, pervasive organic pollutants, and hazardous chemicals

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    Use minimal and environmentally friendly or recyclable packaging

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    Implement operational practices that minimise post-consumer waste and reduce environmental impact

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    Implement measures to reduce, reuse, and recycle waste, enhancing resource efficiency and promoting circularity

• • c)

    Energy Efficiency: It is expected that vendors -

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    Continuously seek to re-engineer both existing and new products supplied to the Company, aiming to reduce energy consumption and improve the energy efficiency of the equipment and products while ensuring compliance with Bureau of Energy Efficiency (BEE) standards for certification

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    Adopt energy efficiency measures in operations and work towards increasing the use of renewable and clean energy sources to lower greenhouse gas emissions

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    Maintain transparency and, upon request, share a plan for reducing energy consumption of the provided equipment and products

• 2.2

  Socially Responsible: We recognise that procurement decisions can have significant social impacts, and the Company intends to contribute proactively to the realisation of a sustainable society. We are committed to making a positive social impact through our supply chain by upholding the highest standards of social responsibility. This involves advocating for fair labour practices, encouraging diversity and inclusion, respecting human rights and promoting opportunities for persons with disabilities or those who are specially-abled. By choosing vendors who align with our values of social equity and ethical behaviour, we aim to support community well-being and promote a more just and inclusive society.

• • a)

    Human Rights & Labour: It is expected that vendors -

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    Ensure adherence to all relevant local, national, and international laws regarding human rights and labour rights, including measures to combat modern slavery

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    Promote respect for human rights in alignment with international standards, such as the United Nations Universal Declaration of Human Rights and the International Labour Organisation's Declaration on Fundamental Principles and Rights at Work

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    Prohibit forced labour resulting from coercion, detention, inhumane prison conditions, slavery, or human trafficking

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    Promote the inclusion of persons with disabilities or those who are specially-abled by offering equal opportunities, ensuring accessible workplaces, and actively working to prevent discrimination in hiring, employment, and career progression

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    Adhere to all relevant legal obligations concerning wages, health insurance, provident fund (PF) contributions, employee state insurance (ESI), gratuity, retirement benefits, and other essential human resource responsibilities to protect the rights and well-being of workers/employees

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    Prohibit the transport, concealment, recruitment, transfer, or hiring of individuals through intimidation, coercion, abduction, or fraud

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    Prohibit any actions that compromise the dignity of individuals. Vendors must respect the human rights of workers/employees and ensure they are not subjected to inhumane treatment, such as mental or physical abuse, coercion, harassment, or any other acts that could be considered inhumane

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    Implement due diligence processes in the supply chain to ensure that there are no human rights violations

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    Promote the use of technology in the supply chain that adheres to high ethical standards and complies with applicable laws and regulations. Ensure responsibility in protecting and managing data with respect for human rights, and avoid any unfair discrimination resulting from algorithmic or data biases

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    Comply with the Company’s commitment to a workforce free of harassment, sexual harassment, abuse and unlawful discrimination in hiring, compensation, access to training, employment practices, promotion, termination or retirement based on race, skin colour, sex, sexual orientation, ethnicity or nationality, religion, age, disability, pregnancy, gender identity or expression, marital status or veteran status

• • b)

    Child Labour: It is expected that vendors -

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    Comply with all applicable local, national, and international laws on child labour

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    Prohibit employment of individuals below the legal minimum working age

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    Prohibit young workers under 18 from performing hazardous tasks that could jeopardise their health or safety, including night shifts and overtime

• • c)

    Occupational Health and Safety: It is expected that vendors -

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    Comply with local, national, international and country-specific laws and regulations for the occupational health and safety of their workers/employees

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    Identify safety risks and implement appropriate measures including design, technology and management practices

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    Provide workers/ employees with training on health and safety in the workplace

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    Assess the machinery and equipment used by workers/employees for safety risks and introduce suitable safety measures as needed

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    Identify and assess the risks that workers/employees may face from harmful biological, chemical, or physical effects in their workplace, and manage these risks effectively

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    Implement suitable measures to address occupational injuries and illnesses, and take appropriate corrective and preventive actions

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    Provide Personal Protective Equipment (PPE) to workers/employees, making certain that it is suitable for their specific tasks, and ensuring they receive training on its correct usage, maintenance, and limitations to improve workplace safety

• 2.3

  Good Governance Practices: We are committed to upholding rigorous governance practices and maintaining the highest standards to ensure transparency, accountability, and ethical conduct throughout our operations and supply chain.

• • a)

    Ethical Business Conduct: It is expected that vendors -

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    Comply with established anti-bribery and anti-corruption policies and practices prohibiting bribery, acceptance of gifts and entertainment services, illegal political donations, extortion and embezzlement

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    Must not offer or accept bribes, promises or any other forms of inducements to obtain undue or improper advantages

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    Implement measures to prevent money laundering and provide workers/employees with appropriate education and training to ensure ongoing compliance

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    Do not disadvantage other suppliers by exploiting a dominant bargaining position

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    Conduct thorough due diligence to ensure that the minerals used in their products do not lead to or contribute to serious human rights violations, environmental damage, corruption, conflict, or other issues in conflict zones and high-risk areas

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    Offer comprehensive consumer service, support, and complaint-handling mechanisms, under the terms and agreements specified in the contract

• • b)

    Product Quality and Safety: It is expected that vendors -

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    Adhere to the safety standards established by the laws and regulations mandated regionally, nationally and internationally for their products. They are also responsible for designing, manufacturing, and selling products in a way that guarantees adequate product safety

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    Provide accurate information about products and services, and strictly prohibit the dissemination of falsified or manipulated information

• • c)

    Information Security: It is expected that vendors -

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    Comply with relevant regional and country-specific legislation to appropriately manage and protect all personal information of consumers and third parties

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    Develop and enforce security policies that adhere to international standards

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    Design products and services to ensure the confidentiality, authenticity, integrity, and availability of data

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    Establish and enforce policies and procedures to prevent the inclusion of backdoors, malware, or malicious code when developing products or services

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    Establish mechanisms and management systems—including defining information management levels and providing workers/employee education and training—to effectively manage and protect confidential information which is received from customers and third parties

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    In the event of a security incident, promptly notify stakeholders, determine the cause of the incident, contain the damage, and implement measures to prevent recurrence

• • d)

    Business Continuity: It is expected that vendors -

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    Prepare adequately to resume operations as quickly as possible and work to minimise the impact on the supply chain in the event of major disruptions, such as large-scale natural disasters

• 3

  Accreditations: We encourage our vendors to obtain accreditation for their business operations in line with international standards and best practices, including ISO 9000, ISO 14001, ISO 20000, ISO 27001, ISO 45001, SA 8000, Capability Maturity Model Integration (CMMI) and others.

• 4

  Vendor Registration Questionnaire: Vendors are expected to maintain transparency when responding to the Company’s Vendor Registration Questionnaire on the registration portal.

• 5

  Vendor Code of Conduct: Vendors are responsible for ensuring compliance with the Sustainable Procurement Policy and the Vendor Code of Conduct. They must promptly notify the designated Company contact or a member of our management if any situation arises that could lead to a breach of these policies.

• By submitting your information as part of the vendor registration process, you acknowledge and consent that Velocis Systems Private Limited ("Company") may collect, receive, store, process, and use your personal data in accordance with applicable Indian data protection laws, including the Digital Personal Data Protection Act, 2023, the Information Technology Act, 2000, and relevant rules thereunder. Company is committed to protecting your personal data and will use it solely for legitimate business purposes such as registration, due diligence, and ongoing compliance. Company implement reasonable security measures to safeguard your information and will retain it only for as long as necessary to fulfil these purposes or as required by law. Your information will not be shared with third parties without your consent, unless mandated by law.

• By proceeding with the registration, you confirm that you have read and understood this disclaimer and agree to the processing of your personal data accordingly.