Ethical Sourcing, Trading & Sustainable Procurement Policy (Including Supplier Diversity)

In CPi Biotech we conduct business ethically and with integrity. We have a zero-tolerance policy in respect of bribery and corruption, and we are 100% ethically focused. We support all refusals to engage in any such behaviour.

We expect all suppliers and contactors to adhere to business practices that are in accordance with the letter and spirit of applicable laws and ethical principles. CPi endeavours to hold itself and its Suppliers to the highest ethical and compliance standards, including basic human rights, encouraging fair and equal treatment for all persons, the provision of safe and healthy working conditions, respect for the environment, the adoption of appropriate management systems and the conduct of business in an ethical manner.

We value working with a diverse range of suppliers. As a small business enterprise in Ireland (defined as less than 250 persons engaged) with 100% independent ownership, we know firsthand the importance that small and diverse businesses add to both the economy and business in general.

We are committed to Supplier Diversity which involves collaborating with a supplier base which includes small-sized, minority-owned, or local companies. A diverse supplier is a business that is at least 51% owned and operated by an individual or group that is part of a traditionally underrepresented or underserved group. Common classifications are small-business enterprises (SBEs), minority-owned enterprises (MBEs), and woman-owned enterprises (WBEs). Suppliers can self-declare as a Diverse Supplier by completing our online form. Suppliers are encouraged to pursue the appropriate certification where possible.

Key initiatives under this Policy include:

➢ To appoint an Ethical Sourcing, Trading & Sustainable Procurement Champion (including Supplier Diversity) within the company – Q4 2024.

➢ To challenge our suppliers through the onboarding and qualification process regarding their commitment to meeting current sustainability initiatives – Q4 2023.

➢ We commit to doing due diligence to ensure a potential supplier or vendor does not engage in unethical behaviours – Q4 2023.

➢ Suppliers can self-declare as a Diverse Supplier by completing our online form.

➢ We will endeavour to increase our spend with diverse suppliers where possible.

➢ Staff are encouraged to speak up should they observe unethical sourcing and trading practices.

➢ Staff are not permitted to accept gifts in the procurement of goods & services for the company as outlined in our company handbook.

➢ To educate the company on the topic of Ethical Sourcing/Trading – ongoing.

The sustainability team along with management are committed to measuring our performance as part of our management review meeting process, ensuring the initiatives are progressed in line with aims. This policy will be reviewed annually. Please also see our AntiSlavery and Human Trafficking Statement.

Ethical Sourcing, Trading & Sustainable Procurement Policy | CPI Biotech

Adrian Giltinan

Managing Director

Date: 29th September 2023