Axiom Supplier Code of Conduct
1. Objective
Axiom is committed to the highest standard of business ethics and integrity around the world and our continued success depends on our employees, suppliers and business partners acting with honesty and integrity while conducting business with or on behalf of Axiom.
Although our business is primarily service-based, we recognise that our procurement decisions can have environmental and social impacts. Axiom seeks to partner with suppliers who share its commitment to responsible business practices, ethical conduct, and continuous improvement. This Supplier Code of Conduct (“Code”) outlines the basic requirements a third-party providing goods or services to Axiom (“Supplier”) must comply with to do business with Axiom Global Inc., and its subsidiaries (collectively referred to as, “Axiom”). It sets out the minimum standards we expect our suppliers to follow and has been developed to complement Axiom’s own Code of Conduct as well as applicable laws, regulations, and contractual obligations in the jurisdictions in which Axiom operates.
2. Owner
Axiom’s board of directors has overall ownership for ensuring that this Code complies with Axiom’s legal and ethical obligations. Axiom’s Legal & Compliance function is responsible for ensuring that all Suppliers that Axiom engages with are aware of its contents and comply. Axiom’s Legal & Compliance function can be contacted on compliance@axiomlaw.com.
3. Revisions and Updates
Revisions to this Code are made by Axiom’s Legal & Compliance function as and when necessary and the latest version shall be published on Axiom’s website. The Supplier is advised to regularly check Axiom’s website to ensure that it is complying with the latest version of the Code.
4. Definitions
“Representative” means any individual or organisation who is the Supplier's suppliers, agents, and sub-contractors who are involved in Axiom's supply chain.
“Supplier” means companies, partnerships, distributors, agents, representatives, and other business partners and their employees, directors, officers, agents, representatives, and sub-contractors providing a product and/or services to Axiom.
“Worker” means any individual whom the Supplier employs, hires, or engages, or otherwise uses to conduct its business.
5. Supplier Commitment
Supplier agrees that:
- it will comply with the requirements in this Code and any subsequent revisions;
- it has appropriate systems in place to ensure continuous compliance and to demonstrate such compliance;
- any breach of this Code will allow Axiom to terminate its relationship with the Supplier with immediate effect; and
- this Code forms a part of the contractual documentation between Axiom and the Supplier (irrespective of whether it is explicitly referred to in any other contractual documentation which has been entered into between the parties).
6. Compliance with Laws and Regulations
In addition to the responsibilities outlined in the Code, Suppliers must comply with all applicable laws and regulations, including, but not limited to, immigration and labour laws, environmental, health and safety laws, data protection laws, modern slavery and human rights laws, discrimination laws, and trade and sanctions regulations.
If there is a conflict between any applicable laws or regulations, the provision of an agreement with Axiom and/or the provisions of this Code, the Supplier shall meet the most stringent standard.
Supplier must promptly report any activity that appears to violate applicable laws and regulations, contract obligations, or Axiom policies and procedures.
7. Workforce Issues
Slavery, human trafficking and child labor.
The Supplier shall comply with all applicable anti-slavery and human trafficking laws, statutes, regulations, and codes from time to time in force. This includes, but is not limited to, not supporting or engaging or requiring any forced labor, the use of child labor, bonded labor, indentured labor and prison labor.
Human rights.
The Supplier shall comply with all internationally recognized human rights, at a minimum, as those expressed in the International Bill of Human Rights and the principles concerning fundamental rights set out in the International Labor Organization’s Declaration on Fundamental Principles and Rights at Work from time to time in force.
Compensation.
The Supplier shall fairly compensate their Workers by providing wages and benefits which are in compliance with applicable laws and regulations of the jurisdictions in which the Supplier operates, or which are consistent with the prevailing local standards in the jurisdictions, if the prevailing local standards are higher.
Hours of Labor.
The Supplier must ensure that working hours are consistent with applicable laws and regulations and are not excessive. The Supplier must provide Workers rest days and leave privileges.
Discrimination/Equal Opportunities.
Axiom is an equal opportunity employer and requires Supplier to base all conditions of employment on the ability to do the job, not on the basis of personal characteristics or beliefs. Suppliers must follow all applicable employment laws, must not engage in acts of verbal or physical harassment and must not discriminate on the basis of race, color, national origin, gender, sexual orientation, religion, disability, or any other characteristic prohibited by applicable laws and regulations.
Diversity, Equity & Inclusion (“DE&I”).
The Supplier should consider DE&I in their decision making and supplier selections, including actively supporting supplier programs that look to ensure a diverse employee base. The Supplier must not discriminate unfairly in hiring or during the employment lifecycle on the grounds of race, color, national origin, gender, sexual orientation, religion, disability, or any other characteristic prohibited by applicable laws and regulations. The Supplier must protect employees from any discrimination or monetary inequality irrespective of gender.
Axiom encourages Suppliers to review the extent of equality, diversity and inclusion within their own supply chain and sourcing decisions. Suppliers should work with diverse businesses and enact inclusive sourcing within their own organisations.
Immigration Law and Compliance.
The Supplier must only employ Workers with a legal right to work. The Supplier is obligated to validate all Workers’ legal status by reviewing relevant documentation before they are allowed to commence work.
8. Business Integrity
Axiom expects the Supplier to conduct its overall business with integrity and specifically address the following areas:
Conflicts of Interest.
The Supplier must avoid the appearance or actual improprieties of conflicts of interests. The Supplier must not deal directly with any Axiom employee or the spouse, domestic partner, or other family member or relative of an Axiom employee who holds a significant financial interest in the Supplier. If a Worker or Worker’s spouse, domestic partner, or other family member or relative is employed by Axiom, then such individual may not participate in any contract negotiations involving the Supplier nor provide services to Axiom on behalf of the Supplier.
Fair Dealing and Fair Competition.
Axiom does not tolerate improperly taking advantage of anyone through manipulation, concealment, abuse of privileged information, intentional misrepresentation of facts or any other unfair practice. The Supplier is expected to comply with applicable anti-competition laws and regulations. Unfair competition practices such as price fixing or bid rigging are not acceptable.
Business Continuity and Crisis Management.
Subject to the terms of any specific contractual provisions that apply, the Supplier must have adequate business continuity plans in place to continue to provide its services to a reasonable degree in the aftermath of any kind of operational crisis, whether caused by a natural disaster, equipment malfunction, power failure, terrorist act or so forth. Upon request by Axiom, the Supplier must disclose and discuss in detail the elements of its business continuity plan.
9. Bribery and Corruption
Axiom is committed to conducting business free from bribery, corruption and unethical activities. The Supplier must comply with all applicable laws and regulations that govern the jurisdictions in which they operate, that relate to the prevention of bribery and corruption as well as those that apply to Axiom including the Foreign Corrupt Practices Act 1977 in the United States of America and the Bribery Act 2010 in England & Wales. To that end, the Supplier shall not accept, offer, promise, pay, permit or authorize:
- bribes, facilitation payments, kickbacks or illegal political contributions;
- money, goods, services, entertainment, employment, contracts, or other things of value, in order to obtain or retain improper advantage; and
- any other unlawful or improper payments or benefits.
Gifts and hospitality.
Any gifts, meals, or entertainment provided by Supplier to Axiom must comply with applicable laws and regulations and must be consistent with local custom and practice. Gifts and hospitality must always be proportionate and adequate for the occasion concerned.
The Supplier has an affirmative obligation to promptly report to Axiom’s Legal & Compliance function any concerns about, or indications of, possible violations of law in respect of anti-bribery and corruption.
10. Health and Safety
Suppliers must maintain healthy, safe and secure work environments and comply with relevant health and safety laws.
Suppliers should have appropriate procedures, controls, and safeguards in place for preparing for and responding to emergencies, including but not limited to natural disasters, epidemics, pandemics, workplace incidents, and other potential business interruptions.
Preparations should include, where appropriate, notification and evacuation procedures, emergency response drills, first-aid supplies, fire detection and suppression equipment, employee training sessions, and adequate exit facilities where required.
11. Environment and Sustainability
Axiom expects suppliers to proactively manage environmental impacts associated with their operations and value chains in a responsible and transparent manner, in compliance with applicable laws and regulations. The Supplier must:
- comply with applicable environmental laws and regulations, permitting rules and reporting requirements applicable to their operations;
- stay informed of and mitigate environmental risks; and
- conduct their operations in a manner that makes reasonable efforts to meet industry best practices and standards to minimize the impact on the environment;
Axiom encourages Suppliers to integrate social enterprises into their supply chain and to source goods and services that minimize carbon footprints, uphold ethical labor standards, and support the circular economy, ensuring long-term value while mitigating supply chain risks.
12. Downstream Monitoring and Due Diligence
Suppliers are expected to perform effective due diligence on their own supply chains to ensure that information security, data protection, human rights, diversity and inclusion, society, environmental, product and service responsibility, whistleblowing, monitoring, and values and behaviour standards are monitored. Due diligence should ensure that effective and that appropriate progress plans are in place where relevant, as part of their own supplier management program.
In its dealings with third parties, Supplier shall ensure that:
- agreements with third parties include provisions that require them to comply with applicable laws and regulations as well as the provisions of this Code, or the Suppliers own code of conduct that mirrors the provisions of this Code.; and
- it has measures to monitor that those third parties are complying with those compliance-related provisions and that it has systems in place to address any deficiencies or breaches of those requirements.
13. Responsible Product and Materials Sourcing
We recognise the importance of responsible sourcing throughout our operations and supply chain. We require suppliers to source product materials responsibly, develop more efficient and sustainable packaging for those products, and minimize or eliminate the use of hazardous substances. If product does contain hazardous materials or conflict minerals, Suppliers must adhere to applicable laws and regulations, including regarding labelling.
Suppliers should prohibit the sourcing of materials and services from locations and entities that directly or indirectly finance or benefit perpetrators of serious human rights abuses, contribute to armed conflict or human rights abuses in Conflict Affected and High-Risk Areas (CAHRAs), or are sanctioned by the U.S. Government.
14. Confidentiality, Intellectual Property, and Data Protection
Confidentiality.
The Supplier must not disclose to others and will not use for its own purposes or the purpose of others any trade secrets, confidential information, knowledge, data, skill, or any other information considered by Axiom as “confidential”. The Supplier must require all Workers to sign confidentiality provisions to protect customer information as a condition of employment.
Intellectual Property.
The Supplier shall respect the intellectual property rights of others including that of Axiom. The Supplier must safeguard any intellectual property that it creates for Axiom or is permitted to use on behalf of Axiom. Any authorised transfer of confidential information is to be done in a way that protects all intellectual property rights.
Data Protection.
The Supplier shall comply with all data protection laws, regulations and best practices when processing any personal data on behalf of Axiom. The Supplier must ensure that:
- it does not access or disclose Axiom personal information (also known as “personal data”) except as authorised under its agreement with Axiom;
- it takes appropriate steps to safeguard any information belonging to or supplied by Axiom that could lead to the identification of individuals, including information that identifies individuals in combination with other information;
- it maintains a written information security program that includes administrative, technical, and physical safeguards designed to protect the security, integrity, and confidentiality of personal information;
- there is no unauthorized access of the information by third parties, including its Representatives; and
- it notifies Axiom without undue delay of any unauthorized access or disclosures.
15. Monitoring and Compliance
Suppliers must develop and enforce policies and procedures to ensure compliance with all aspects of this Code.In certain cases, Axiom may require the Supplier to certify its compliance with the Code in writing on an annual basis.
In addition, Suppliers undertake to provide documentary evidence of compliance with the principles laid out in this Code upon written request and where applicable and necessary to welcome audits no more frequently than once a year as commissioned by Axiom to verify compliance, where required.
16. Violations of this Code
Any violations of this Code are taken seriously by Axiom and may result in Axiom terminating its relationship with the Supplier with immediate effect.
Last updated: July 2026