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Acala (“us”) is dedicated to conducting business and relationships in a lawful, ethical, environmentally friendly and socially responsible manner. A part of this dedication is requiring that our suppliers of goods and services (“you”) conduct business for and on behalf of Acala are in full compliance of all applicable laws and ethics so that Acala can ensure to its customers that the goods they receive from us have been sourced responsibly. This is of utmost important to us not only for our business model but to our core principles and values, so for this reason Acala will not work with suppliers who hinder us from being able to make such declarations at all times. It is therefore critical not only that you understand the requirements and expectations that Acala has for our suppliers, but that your own supply chain who provides you with goods and services in relation to your commercial dealings with Acala (“your business”) complies with this Code because their compliance is a part of yours.

Anti-Bribery and Anti-Corruption:

  • As our supplier, your business will be entirely free of bribery and will at all times be conducted in accordance with all bribery laws as well as the UK Bribery Act 2010.

Child Labour:

  • You will not employ on a full time basis any person under the statutory minimum age for the completion of compulsory education, or employ on any basis any person under the minimum age of employment.
  • Your business will at all times comply with the UN Convention of the Rights of the Child.

Forced Labour and Human Trafficking:

In addition to always meeting the requirements of the UN Abolition of Forced Labour Convention, you will ensure that in regards to your business:

  • forced or involuntary labour will not be tolerated in any form. This includes the prohibition of prison, indentured and bonded labour and the transportation, harbouring, recruitment, transfer, receipt or employment of persons by means of threat, force coercion, abduction, fraud or payments to any person having control over another person’s by such means;
  • workers’ original government issued identification will not be withheld. You will not impose unreasonable restrictions on movement upon entering or leaving the country or place(s) of work; and
  • workers’ conditions of employment are clearly conveyed to them in writing in a language they comprehend.

Working Conditions:

In addition to complying with local labour laws:

  • you will ensure the timely payment of wages and benefits, including overtime wages at timelines that meet local statutory requirements;
  • you will ensure that you will not require workers to work more than the maximum hours of daily labour as set by applicable labour laws;
  • all workers in your business will be provided with a working environment that complies with all health and safety regulations;
  • your business will not interfere with your workers in their freedom of association or right to collective bargaining;
  • you will ensure that all of your workers are treated fairly in accordance with their abilities and qualifications and that you will not discriminate against your workers or potential workers on the basis of race, religion, gender, sexual orientation, physical disability or any other basis prohibited by law; and
  • your business will treat its workers with dignity and respect and will never in any circumstance subject its workers to threats of or actual violence, physical punishment, confinement or any form of physical, sexual, psychological or verbal harassment or abuse.

For the avoidance of doubt, “worker(s)” includes full time employees, part time employees and consultants.


  • You will promote transparency in supply chain and understand that you may be required by Acala to provide certain factory audit findings when requested.
  • If Acala identifies a breach, or risk of a breach of the points mentioned here, you confirm (a) that Acala may audit your business/factory to ensure its compliance with this Code (Acala will endeavour to cause the least business disruption to your organisation as possible within its control) and (b) that your cooperation by allowing Acala or its representatives access to your organisation’s facilities, records and employees in such an audit is a condition of your commercial relationship with Acala. Acala will treat the findings as highly confidential. 


  • Your business will comply with all applicable environmental laws and regulations and is committed to running in the most environmentally responsible manner possible.
  • Your business will not use palm oil from unsustainable source.
  • Your business will not use any chemicals or manufacturing processes that are harmful to the environment. As a minimum, if you are using, making, selling or importing chemicals from the EU, you will follow REACH (Registration, Evaluation, Authorisation and restriction of Chemicals) regulations.
  • The OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas provides detailed recommendations to help companies respect human rights and avoid contributing to conflict through their mineral purchasing decisions and practices. When your organisation uses any minerals or metals in its supply of goods or services to Acala, you will conduct a country of origin inquiry to determine whether any of the conflicts minerals originate from conflict-affected and high-risk areas such as the Democratic Republic of the Congo and surrounding countries including Angola, Burundi, Central African Republic, Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda and Zambia and issue a declaration of conflicts minerals for each product.


By signing this Code, you:

  • warrant that the dealings that you have with us or on behalf of us will comply with this Code;
  • understand that wilful or reckless non-compliance with this Code on the part of your organisation and your relevant supply chain will constitute a breach of warranty of your services and Acala may terminate all commercial transactions without penalty;
  • understand that non-compliance of this Code may cause Acala to incur liability for which you would be under an obligation to fully remedy. You hereby confirm your understanding that such damage to business and reputation that your non-compliance can cause to Acala is often immeasurable until the same has manifested;
  • understand that you are under an obligation to report any instances of non-compliance to Acala.

Signed for and on behalf of: 

Company name:


Name of Signatory:


Signatory’s Title:


Date of Signature:

Month:                           Day:                           Year:




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