Last update: January 12, 2026
1. Policy Statement and Scope
At Ingeniarts Technologies Inc., dba UgoWork (together with its wholly owned subsidiaries, “UgoWork“, “we“, “us“, “our”), we provide an advanced, cost-efficient, and proven energy management program in the material handling industry. We are future-driven and envision a sustainable world driven by intelligent resource management and efficiency.
As such, business integrity, responsible product sourcing, the protection of the environment and the safety and well-being of workers across our global supply chain are of paramount importance to UgoWork. These principles apply to all aspects of our business, and encompass all manufacturers, distributors, vendors, contractors and sub-contractors of goods and services, including their employees and representatives (collectively, the “Suppliers“).
These principles are reflected in this Supplier Code of Conduct (the “Code“), which highlights what we stand for and sets clear expectations for our Suppliers. Suppliers must not only comply with this Code, but also ensure that any subcontractors or other suppliers they use throughout the value chain complies with a set of standards compatible with this Code.
This Code is based on the principles of the International Labour Organization (ILO)’s Declaration on Fundamental Principles and Rights at Work; the ILO’s Basic Terms and Conditions of Employment; the United Nations Guiding Principles on Business and Human Rights; the International Bill of Human Rights; the Voluntary Principles on Security and Human Rights (VPSHR); the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (together with other standards mentioned in this Code, the “Standards“).
2. Compliance with Laws
Suppliers shall comply with all applicable laws, including federal, provincial, territorial and local laws and regulations, including laws and regulations relating to or giving effect to the Standards. Where this Code requires Suppliers to meet a higher standard than set out by law or regulation, Suppliers shall meet such higher standards.
3. Business Integrity and Ethics
- Anti-Bribery and Anti-Corruption
Suppliers must comply with applicable laws related to anti-bribery and anti-corruption in the jurisdictions in which they operate. Under any circumstance, it is not acceptable for any Supplier to offer any bribe, kickback or other unlawful payment or benefit to secure a concession, contract or other favorable treatment or outcome, including from our employees. - International Trade
Suppliers must comply with all applicable international trade, export control, economic sanctions or embargo laws, and customs laws and regulations. - Fair Competition
Suppliers must observe applicable laws related to fair business, fair advertising and fair competition, as well as the relevant antitrust and competition laws, which particularly prohibit price fixing, market or customer allocation, market sharing or bid rigging with competitors. - Gifts, Hospitality and Other Benefits
The nature of any gifts, hospitality or other benefits must not, by their quality, quantity or timing, be used by Suppliers to gain improper advantage or preferential treatment from UgoWork employees. UgoWork employees are restricted from accepting external hospitality from current or prospective Suppliers other than onsite working meals in a customary business setting. - Conflicts of Interest
Suppliers must always avoid situations of real or perceived conflicts of interest and must exercise reasonable care and diligence to prevent any such situation. - Disclosure of Information
Information regarding Suppliers’ labor, health and safety, environmental practices, business activities, structure, financial situation and performance is to be disclosed in accordance with applicable regulations and prevailing industry practices. Falsification of records or misrepresentation of conditions or practices in the supply chain are strictly prohibited. - Protection of identity and non-retaliation
Suppliers must operate and maintain an anonymous confidential reporting channel and whistleblower protection program, unless prohibited by law. Suppliers must have a clear and known process for their employees to be able to raise any concerns or report any violations without fear of retaliation.
4. Information and Data Management
- Privacy & Data Protection
Suppliers shall comply with data protection and information security laws and regulatory requirements, including those regarding privacy and personal information protection when personal information is collected, stored, processed, transmitted or shared. - Confidentiality
Suppliers must safeguard and not improperly disclose any confidential, sensitive, and nonpublicly available business information pertaining to UgoWork, including but not limited to its employees, customers and suppliers, financial information, and intellectual property. - Intellectual Property
Suppliers must avoid misappropriating or infringing upon third-party intellectual property. Suppliers will protect UgoWork’s intellectual property such as copyrighted information, trademarks and logos, patents, and trade secrets against loss or infringement, and use them only in accordance with UgoWork’s instructions.
5. Labor and Human Rights
- Slavery and Human Trafficking
All labour must be voluntary. Suppliers shall not support or engage in slavery or human trafficking in any part of its supply chain. Suppliers shall not support or engage in, or require any compelled, involuntary, or forced labour; bonded labour; indentured labour; or prison labour. - Child Labor
Child labor is not tolerated in any form. Suppliers shall not directly or indirectly employ children below the minimum age of 15, unless exceptions under applicable Standards and other laws and regulations apply. - Hazardous Work
Suppliers shall not support or engage in, or require any hazardous labour to be performed by any person under the age of 18. Hazardous labour involves any work that, by its nature or the circumstances in which the work is undertaken, involves the substantial risk of harm to the safety or health of the worker or coworkers if adequate protections are not taken. - Freedom of Movement
Suppliers shall ensure that workers have the right to freedom of movement (including the right to terminate their employment or work arrangement) without delay or hindrance or the threat or imposition of any discipline, penalty, retaliation, or fine or other monetary obligation. Suppliers may not require any worker to surrender control over identification papers and shall not, whether or not as a condition to the right to work, require any worker to incur financial obligations. - Freedom of Association and Collective Bargaining
Suppliers shall respect, and shall not interfere with, the right of workers to decide whether to lawfully associate with groups of their choice, including the right to form or join trade unions and to engage in collective bargaining.
Suppliers shall not take any action to prevent or suppress the workers’ exercise of freedom of association or collective bargaining rights; discriminate or retaliate against, or discipline or punish, any worker who supports or exercises freedom of association or collective bargaining rights. - Working Hours
Suppliers shall ensure that a regular working week is in accordance with the Standards and other laws and regulations. Suppliers must give breaks, annual paid leave and one day off every week unless collective agreement defines exceptions. - Wages and Benefits
Suppliers shall pay wages and benefits at a minimum according applicable laws, industry standards and relevant collective agreements, whichever is highest. The level of wages shall reflect the level of skills and qualifications of regular working time regardless of gender.
Overtime should be paid according to local regulation. Suppliers shall pay accurate wages in a timely manner, and wage deductions shall not be used as a disciplinary measure. - No Discrimination, Abuse, or Harassment
Suppliers shall not discriminate in hiring, compensation, training, advancement or promotion, termination, retirement, or any other employment practice based on race, colour, ethnic or national origin, gender, gender identity, sexual orientation, military status, political convictions, religion, age, language, civil, marital, or pregnancy status, social condition, disability, handicap or the use of any means to palliate a handicap, or any other characteristic other than the worker’s ability to perform the job.
Suppliers shall treat workers with respect and dignity.
Suppliers shall not subject workers to corporal punishment, or physical, verbal, sexual, or psychological abuse or harassment. Suppliers must not condone or tolerate such behaviour.
6. Health and Safety
Suppliers shall provide a safe, healthy, and sanitary working environment. Suppliers shall implement procedures and safeguards to prevent workplace hazards, and work-related accidents and injuries, including procedures and safeguards to prevent industry-specific workplace hazards, and work-related accidents and injuries, that are not specifically addressed in the Standards.
General and industry-specific procedures and safeguards include those relating to health and safety inspections; equipment maintenance; maintenance of facilities; worker training covering the hazards typically encountered in their scope of work; fire prevention; and reporting and record-keeping.
Suppliers shall provide workers adequate and appropriate personal protective equipment to protect workers against hazards typically encountered in the scope of work.
Suppliers shall obtain, keep current and comply with all required health and safery permits.
7. Environment
- Environmental Permits and Reporting
All required environmental permits, approvals and registrations are to be obtained, maintained and kept current and their operational and reporting requirements are to be followed by Suppliers. - Pollution Prevention and Waste Reduction
Suppliers shall control and implement actions to reduce the use of resources and generation of waste of all types, including water and energy, at the source or by practices such as modifying production, maintenance and facility processes, materials substitution, conservation, recycling and re-using materials. - Hazardous Substances
Suppliers shall identify and manage chemicals and other materials posing a hazard if released to the environment and ensure their safe handling, movement, storage, use, recycling or reuse and disposal. - Energy Consumption
Suppliers should aim to track and document energy consumption and greenhouse gas emissions at the facility or corporate level. Suppliers shall always strive to implement methods and processes to improve energy efficiency and to minimize their energy consumption and greenhouse gas emissions. - Circularity
Suppliers shall assist UgoWork in assessing and calculating its carbon footprint, including with respect to the circularity of its products, parts and components. Upon request, Suppliers shall provide all relevant information to this effect, including information regarding recycling, reuse and other end-of-life scenarios. Suppliers shall reduce the impacts of their operations from a circularity perspective.
8. Sourcing of Minerals
UgoWork acknowledges potential and real risks of serious human rights abuses and environmental threats related to the sourcing of certain minerals. UgoWork undertakes not to purchase, use or include in its products minerals which directly or indirectly finance or benefit armed groups in Conflict-affected or high-risk areas (“CAHRAs”) (as defined in the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (the “Guidance”).
Suppliers shall exercise due diligence, and develop and maintain a compliance program consistent with the Guidance, to detect the presence of any minerals of concern from CAHRAs in the value chain. Suppliers must keep records on any identified risks and the actions taken to address them. Suppliers shall immediately notify UgoWork if they become aware of any minerals of concern from CAHRAs being used in the value chain and shall provide any information reasonably requested by UgoWork to ensure compliance with the foregoing.
9. Administration of the Code
UgoWork may update this Code from time to time. While UgoWork will make reasonable commercial efforts to communicate any update to the Code to the Suppliers, it is the Suppliers’ responsibility to review the published version of this Code from time to time to monitor any changes or updates that may be made.
UgoWork may at any time demand that Suppliers complete self-assessments and reserves the right to conduct audits on Suppliers and their own subcontractors and suppliers regarding compliance with this Code and any agreed upon corrective action plan.
Suppliers shall self-report any actual or suspected violations of the Code. Supplier shall not retaliate or take disciplinary action against any worker who has, in good faith, reported violations or questionable behaviour, or who has sought advice regarding this Code.
In addition to UgoWork’s other rights and remedies, which it fully reserves, UgoWork may immediately terminate its business relationship (including any purchase order(s) and purchase contracts) with Suppliers who fail to meet the Standards or otherwise comply with the provisions of this Code.
| Rafael Martines Address: 1065 Lescarbot, Suite 200 Quebec, QC, Canada, G1N 1X6E Email: rafael.martines@ugowork.com |
