Supplier Code Of Conduct

PHILOSOPHI.AI — SUPPLIER CODE OF CONDUCT

PREFACE

From its founding, Philosophi, LLC. (together with its global affiliates, “Philosophi”) has been guided by a mission grounded in responsibility, integrity, and long-term impact. Our Code of Conduct, applicable to our officers, directors, employees, contractors, and consultants, establishes the ethical standards that govern our operations.

This Supplier Code of Conduct (“Supplier Code”) sets forth the values, principles, and conduct expectations applicable to vendors, suppliers, service providers, and contractors from whom Philosophi purchases goods or services, as well as their subcontractors and upstream partners (each, a “Supplier”).

Suppliers are expected to comply with this Supplier Code and to cascade these standards throughout their supply chains. All notices required under this Supplier Code must be submitted by email to policy@philosophi.ai, with “Supplier Code” included in the subject line.

  1. COMPLIANCE WITH LAWS AND REGULATIONS

Suppliers must comply with all applicable laws, rules, regulations, and legal requirements in every jurisdiction in which they operate.

  1. Anti-Corruption and Anti-Bribery

Suppliers must comply with all applicable anti-corruption and anti-bribery laws, including but not limited to the U.S. Foreign Corrupt Practices Act, the U.K. Bribery Act, and equivalent international statutes.

Suppliers must not engage in bribery, corruption, extortion, facilitation payments, kickbacks, or embezzlement of any kind. This includes improper payments or benefits to public officials or private parties.  Any suspected unethical or unlawful conduct must be reported to Philosophi promptly upon discovery.

  1. Trade Controls and Sanctions

Suppliers must comply with all export control, import, trade, and sanctions laws, including restrictions on dealings with sanctioned countries, entities, or individuals. Suppliers must maintain appropriate compliance programs governing controlled products, software, services, or technical data and must notify Philosophi of any applicable export restrictions prior to providing controlled items.

  1. Antitrust and Fair Competition

Suppliers must conduct business in compliance with all antitrust, competition, and fair-dealing laws.

Suppliers must not engage in price fixing, bid rigging, market allocation, or agreements that restrain trade or competition.

  1. ETHICS AND INTEGRITY

Suppliers are expected to operate with honesty, transparency, and ethical integrity.

  1. Conflicts of Interest

Suppliers must avoid actual or perceived conflicts of interest. Any relationship, financial interest, or benefit that could influence—or appear to influence—business decisions involving Philosophi must be disclosed promptly.

  1. Gifts, Hospitality, and Entertainment

Suppliers must not offer or accept gifts, entertainment, or hospitality intended to improperly influence business decisions. Only modest, infrequent, non-cash courtesies consistent with applicable law are permitted. Significant gifts or lavish entertainment are prohibited.

  1. Confidentiality and Data Protection

Suppliers must safeguard all confidential, proprietary, or sensitive information entrusted to them and comply with applicable data protection and privacy laws. Where required, Suppliers must enter into data protection agreements and implement appropriate safeguards. Suppliers are encouraged to anticipate evolving privacy expectations beyond minimum legal requirements.

  1. Intellectual Property Protection

Suppliers must respect intellectual property rights and use technology, know-how, and proprietary materials only in accordance with applicable law and contractual obligations.

Any suspected infringement or misuse of Philosophi intellectual property must be reported immediately.

  1. Insider Trading

Suppliers must not trade securities or disclose material non-public information obtained through business dealings with Philosophi.

  1. Accurate Records

Suppliers must maintain accurate books, records, and financial documentation in compliance with applicable laws and accepted accounting standards.

III. LABOR AND HUMAN RIGHTS

Philosophi is committed to respecting human rights and expects Suppliers to uphold these principles.

  1. Non-Discrimination and Anti-Harassment

Suppliers must provide equal employment opportunity and prohibit discrimination or harassment based on legally protected characteristics.

Reasonable accommodations must be provided to individuals with disabilities where required by law.

  1. Forced Labor and Human Trafficking

Suppliers must not engage in forced labor, bonded labor, involuntary prison labor, or human trafficking.

Employment must be voluntary, with freedom to leave subject to lawful notice. Workers must not pay recruitment fees.

  1. Child Labor

Suppliers must not employ individuals under the legal working age or the ILO minimum age, whichever is higher. Workers under 18 must not perform hazardous work.

  1. Working Hours

Suppliers must comply with laws governing working hours, overtime, rest periods, and days off.

  1. Wages and Benefits

Suppliers must pay legally mandated wages and benefits. Wage deductions as disciplinary measures are prohibited.

  1. Freedom of Association

Suppliers must respect workers’ rights to freedom of association, collective bargaining, and peaceful assembly in accordance with applicable law.

  1. Responsible Mineral Sourcing

Suppliers must exercise due diligence to ensure that tantalum, tin, tungsten, gold, or cobalt do not finance armed groups or human rights abuses.

  1. Whistleblower Protection

Suppliers must provide mechanisms for reporting concerns without fear of retaliation and comply with applicable whistleblower protection laws.

  1. ENVIRONMENTAL RESPONSIBILITY AND SUSTAINABILITY

Philosophi expects Suppliers to operate responsibly and minimize environmental impact.

  1. Environmental Compliance

Suppliers must obtain and maintain required environmental permits and comply with environmental laws.

  1. Hazardous Materials

Suppliers must properly manage, label, store, and dispose of hazardous materials.

  1. Waste Reduction

Suppliers are encouraged to reduce waste through conservation, reuse, and recycling.

  1. Energy Use and Emissions

Suppliers are encouraged to monitor and reduce energy consumption and greenhouse gas emissions where feasible.

  1. HEALTH AND SAFETY

Suppliers must provide safe, healthy, and sanitary working conditions.

  1. Occupational Safety

Suppliers must identify and mitigate workplace hazards, provide training, and allow workers to report unsafe conditions without retaliation.

  1. Emergency Preparedness

Suppliers must maintain emergency response plans and conduct drills as required.

  1. MANAGEMENT, MONITORING, AND ENFORCEMENT

Suppliers must implement processes to ensure compliance with this Supplier Code.

Philosophi may audit compliance upon reasonable notice. Material violations may result in termination or required corrective action.

CONTACT

Philosophi, LLC.
Compliance & Ethics
policy@philosophi.ai
https://www.philosophi.ai