Code of Conduct
Introduction
BTR is aware of its corporate responsibility towards the people, communities, and environment wherein we and our suppliers conduct our business. We support a sustainable development policy, and the conduct of our people and suppliers is a crucial part of that policy. The conduct of our supplier network is part of our organizational conduct policy and is governed by our business integrity policy as well as our BTR ethics standards.
NOW, THEREFORE, IN CONSIDERATION OF THE MUTUAL COVENANTS AND AGREEMENTS HERETO CONTAINED AND FOR OTHER GOOD AND VALUABLE CONSIDERATION, DULY RECEIVED, THE PARTIES HERETO AGREE AS FOLLOWS:
1. General
1.2 Words importing the singular number include the plural and vice versa and words importing the masculine gender include the feminine and neuter genders.
1.3 The division of this Code of Conduct into articles and insertion of headings is for convenience and reference only and shall not affect the construction or interpretation of this Code of Conduct.
1.4 The preamble hereto forms an integral part of this Code of Conduct.
2. Scope of Code of Conduct
2.1 This Code of Conduct shall apply to all suppliers and service providers of BTR. It is not limited by jurisdiction or region but not superseding any regulations or laws that might be in effect within these regions. BTR expects that its suppliers will apply this Code of Conduct to their businesses and enact similar policies to their own supplier network.
3. Legal and Regulatory Compliance
3.1 Suppliers and service providers of BTR shall conduct their business operations according to the laws and regulations that are in place in their regions, jurisdictions, or countries while they are linked to BTR. These obligations shall include (but not be limited) to the following:
3.1.1 Strict compliance to anti-corruption laws within the countries of operation (including but not limited to applicable EU, U.S., U.K., or Chinese anti-bribery legislation or any other such legislation in the country of your business operations). Under no circumstance should you make illegal payments directly or indirectly to any government or corporate officials to illicit the abuse of his/her position to obtain or retain contractual business from said organizations.
3.1.2 Conduct your business in full compliance with any anti-trust or fair competition regulation in place within your jurisdiction of business operations.
3.1.3 Conduct your business in full compliance with environmental laws and statutes when it comes to the handling of hazardous material, air emissions, waste products, wastewater discharge. This includes the transportation, storage, disposal, and release of these waste products and materials into the environment.
3.1.4 Conduct your business in an honest and transparent manner with any agency or government officials at all times.
4. Monitoring and Review
4.1 BTR has a supplier relationship management process in place that assists with the selection, monitoring, and evaluation of the supply chain network. This system is based on a risk-based methodology to determine compliance with the Code of Conduct as well as the internal policies and procedures of BTR currently in place.
4.2 Each supplier will be evaluated according to this risk-based process before business operations will be entered into between BTR and Supplier. We will also be conducting regular assessments to review the status of each supplier to maintain a high standard of the business relationship between all parties.
4.3 The assessments will be conducted using a self-test questionnaire as well as further evaluations if required. These assessments will be conducted as and when BTR deems it necessary. If any non-compliance is found, we will inform the supplier of the corrective measures that must be taken to ensure compliance with regulations and the continuation of the business relationship.
4.4 If any non-compliance is brought to the attention of BTR through any other means, we reserve the right to conduct independent investigations to determine the validity on a case-by-case basis. This does not limit our statutory or contractual rights in any way.
5. Standard Business Practices
5.1 The suppliers, vendors, and employees of the BTR will at all times conduct their business with integrity and in compliance with any and all agreements with BTR. Furthermore, all suppliers will do the following:
5.1.1 Accurately record all business transactions and information and comply with the relative laws and regulations pertaining to the recording and storage of this information.
5.1.2 Maintain accurate records both created and stored in compliance with the regulation pertaining to financial record keeping in your jurisdiction.
5.1.3 Protect the data and assets of BTR as well as intellectual property when dealing with clients and other suppliers.
5.1.4 Not issue any press releases or other similar statements on behalf of BTR without prior authorization.
5.1.5 At all times use good judgment when entertaining BTR employees. The giving of gifts or entertainment must comply with this Code of Conduct so as not to breach the ethical standards of BTR. At no time will the Supplier offer any bribes, kickbacks, or any type of barter for business or incentive to any employee of BTR.
5.1.6 Maintain clear business relationships that do not appear or are in fact improper or might be seen as improper. The Supplier shall not conduct any business with BTR if their spouse, life partner, or any other family member is employed by BTR. This policy will extend to the negotiating of the supplier's contract prior to a business relationship being initiated.
6. Employment Practices
6.1 BTR maintains a high standard when it comes to human rights and equal opportunity within the workplace. We require our suppliers to comply with this standard in their employment policies as well as keep in line with the current laws and regulations within their jurisdictions. The following aspects will gain special attention but will not be limited to these aspects:
6.1.1 Ensure that the workplace is free of harassment and unlawful discrimination. We will at all times be focused on creating and maintaining a work environment that does not include hiring discrimination, inequality of compensation, access to training and promotion, wrongful termination or retirement based on age, religion, disability, gender, marital status, sexual orientation or union memberships as well as political views or legally protected categories.
6.1.2 Comply with the applicable employment laws and regulations.
6.1.3 Maintain a safe work environment that promotes mental and physical health and complies with all relevant health and safety regulations.
6.1.4 Prevent the use or possession and distribution of illegal drugs on any property.
6.1.5 Prohibit the use of forced labor in any facilities or properties.
6.1.6 Comply with the local minimum working age and at no time be a party to child labor practices or exploitive labor practices.
6.1.7 Maintain proper employee records in accordance with local regulations and legislation.
7. Sustainability
7.1 BTR believes in living up to a high standard of social responsibility and sustainability. We are constantly striving to live up to our stewardship of the environment and we also expect our supplier to do so within their business practices. BTR and Supplier will at all times strive to improve the commitment to the environment and business sustainability.
8. Code of Conduct Compliance / Audit
8.1 It is the responsibility of the Supplier and its officers to ensure that all employees and its representatives comply with the Code of Conduct contained within this document. Any transgression or violation of these policies must be reported to BTR to prevent damage to the business relationship with BTR’s clients and supply chain. In the event of a violation, BTR reserves the right to request the removal of persons or persons that committed the transgression.
8.2 Any breach of conduct must be reported to the BTR immediately.
8.3 If doubts exist as to the compliance of Supplier with this Code of Conduct or if BTR itself is obliged to conduct an audit, BTR has the right to conduct audits to evaluate the compliance at its discretion.
Date
Last revised: October 2025