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Axtria Supplier
Code of Conduct

Last Updated on 25th May, 2025
1. SCOPE AND ACCOUNTABILITY

1.1 Definitions, Applicability of the Code and Commitment:

Axtria: means and includes Axtria Inc. and all other Axtria entities globally

Supplier: means any third-party entity, individual, or organization that provides goods or services to Axtria. This includes vendors, subcontractors, and their affiliates, agents, partners and other associated parties involved in delivering products or services to Axtria

This Code is applicable to all Axtria entities globally on all Suppliers to the extent it is relevant to their operations.

This section outlines the expectations Axtria places on its suppliers regarding accountability and the circumstances under whichbusiness relationships may be terminated.

At Axtria, we believe that accountability is the cornerstone of a successful and ethical business relationship. Our Suppliers who serves Axtria are expected to uphold the highest standards of integrity, transparency, and responsibility in all aspects of their operations.

1.2 Commitment to Ethical Conduct:

Suppliers must conduct their business in a manner that aligns with Axtria’s values and ethical standards. This includes compliance with all applicable laws, regulations, and contractual obligations. Suppliers are expected to implement internal policies and procedures that promote ethical behavior, prevent misconduct, and ensure compliance with this Supplier Code of Conduct.

1.3 Responsibility for Subcontractors and Affiliates:

Suppliers are accountable not only for their own actions but also for the actions of their subcontractors, affiliates, and any third parties involved in delivering goods or services to Axtria. It is the Supplier’s responsibility to ensure that all parties in their supply chain understand and comply with the principles outlined in this Code. Failure to do so may result in reputational damage and jeopardize the Supplier’s relationship with Axtria.

1.4 Monitoring and Reporting:

Suppliers are expected to maintain accurate records and provide timely, truthful information to Axtria upon request. This includes documentation related to compliance, labor practices, environmental impact, and financial transactions. Suppliers must also have mechanisms in place to monitor their operations and identify potential risks or violations.

If a supplier becomes aware of any issue that may affect their ability to meet Axtria’s standards, they are required to notify Axtria immediately. This includes any legal proceedings, regulatory investigations, or internal incidents that could impact the supplier’s performance or reputation.

1.5 Corrective Actions and Continuous Improvement:

When non-compliance or misconduct is identified, suppliers are expected to take immediate corrective action. This may involve revising internal policies, retraining staff, or implementing new controls. Axtria encourages a culture of continuous improvement and expects suppliers to proactively address issues and enhance their practices over time.

1.6 Grounds for Termination:

Accountability of Suppliers is not merely a contractual obligation—it represents a shared commitment to ethical business practices and mutual respect. By adhering to these principles, suppliers contribute to a responsible and sustainable supply chain that benefits all stakeholders. Axtria values its partnerships and is dedicated to collaborating with suppliers who exhibit integrity, transparency, and a genuine commitment to ethical conduct.

Axtria reserves the right to terminate its relationship with any supplier that fails to meet the expectations outlined in this Code. These Grounds for termination are in addition to any other grounds mentioned in the agreement with the Supplier and may include, but are not limited to:

  • Repeated or serious violations of legal or regulatory requirements
  • Breach of contract or failure to deliver agreed-upon goods or services
  • Evidence of corruption, fraud, or unethical behavior
  • Failure to implement corrective actions after a compliance issue is identified
  • Inability or unwillingness to cooperate with Axtria’s monitoring or audit processes
2. ANTI-CORRUPTION

Axtria maintains a zero-tolerance policy toward corruption in all its forms, including bribery, extortion, and facilitation payments. We expect our suppliers to uphold the same standard and to conduct their business with integrity, transparency, and accountability.

Suppliers must comply with all applicable anti-corruption laws and regulations, including but not limited to the U.S. Foreign Corrupt Practices Act (FCPA), the UK Bribery Act, and the OECD Convention on Combating Bribery of Foreign Public Officials. These laws prohibit offering, promising, giving, or receiving anything of value to influence a business decision or gain an unfair advantage.

Suppliers must not offer or accept bribes, kickbacks, or other improper payments in any form, whether directly or indirectly through third parties while conducting its business activities. This includes gifts, entertainment, travel, charitable donations, or political contributions intended to influence a decision-maker at Axtria or elsewhere. Any such activity is strictly prohibited and may result in immediate termination of the business relationship with Axtria.

Axtria expects suppliers to implement robust anti-corruption compliance programs. These programs should include written policies, employee training, internal controls, and procedures for reporting and investigating suspected violations. Suppliers must conduct due diligence on third parties acting on their behalf and ensure that they also adhere to anti-corruption standards.

Suppliers must maintain accurate books and records that reflect all transactions transparently and in reasonable detail. False or misleading entries, off-the-books accounts, or undisclosed payments are strictly prohibited. Financial records must be available for review by Axtria upon request.

If a supplier becomes aware of any actual or suspected corruption involving Axtria or its representatives, they are required to report it immediately through Axtria’s confidential reporting channel i.e. compliance@axtria.com. Axtria will investigate all reports thoroughly and take appropriate action.

In high-risk areas or industries, suppliers are expected to conduct enhanced due diligence and implement additional safeguards. This may include third-party audits, background checks, and regular compliance reviews.

Axtria encourages suppliers to foster a culture of integrity and ethical behavior throughout their organizations. Senior leadership must set the tone from the top and ensure that anti-corruption principles are embedded in daily operations.

By adhering to these standards, suppliers help protect Axtria’s reputation, ensure compliance with global regulations, and contribute to a fair and transparent business environment.

3. ANTI MONEY LAUNDERING

Axtria is committed to maintaining the highest standards of integrity and transparency in all business dealings. As part of this commitment, we expect our suppliers to implement robust anti-money laundering (AML) practices to prevent the misuse of financial systems for illicit purposes. Money laundering involves disguising the origins of illegally obtained funds to make them appear legitimate. It is a serious offense that undermines the integrity of financial institutions and global markets.

Suppliers must comply with all applicable AML laws and regulations in the jurisdictions where they operate. This includes, but is not limited to, the U.S. Bank Secrecy Act, the USA PATRIOT Act, the European Union’s AML Directives, and the Financial Action Task Force (FATF) recommendations. Suppliers must also be aware of and comply with any local AML requirements that may be more stringent than international standards.

To meet these obligations, suppliers are expected to establish and maintain a comprehensive AML compliance program. This program should include written policies and procedures that clearly define the organization’s approach to identifying, preventing, and reporting suspicious activities. The program must be tailored to the supplier’s specific risk profile, taking into account the nature of its business, customer base, geographic location, and transaction types.

Key components of an effective AML program include:

  • Customer Due Diligence (CDD): Suppliers must verify the identity of their customers and beneficial owners before establishing a business relationship. Enhanced due diligence should be applied to high-risk customers, such as politically exposed persons (PEPs) or entities operating in high-risk jurisdictions.
  • Transaction Monitoring: Suppliers must implement systems to monitor transactions for unusual or suspicious activity. This includes identifying patterns that may indicate money laundering, such as large cash transactions, rapid movement of funds, or transactions that lack a clear business purpose.
  • Recordkeeping: Suppliers must maintain accurate and complete records of customer identification, transactions, and internal investigations for a minimum period as required by law. These records must be readily available for review by regulatory authorities or Axtria upon request.
  • Training and Awareness: Employees must receive regular training on AML laws, internal policies, and procedures. Training should be tailored to the employee’s role and responsibilities and updated to reflect changes in regulations or emerging risks.
  • Reporting: Suppliers must have procedures in place to report suspicious activities to the appropriate authorities. Employees should be encouraged to report concerns without fear of retaliation, and all reports must be handled confidentially and investigated promptly.

Axtria reserves the right to audit suppliers’ AML programs and request documentation to verify compliance. Failure to maintain an effective AML program or to report suspicious activity may result in termination of the business relationship and potential legal consequences.

By implementing strong AML controls, suppliers help protect the global financial system, support law enforcement efforts, and uphold Axtria’s commitment to ethical business practices.

4. BUSINESS CONTINUITY DISASTAR RECOVERY

At Axtria, we understand that ensuring resilience and reliability within the supply chain is critical for maintaining client trust and guaranteeing seamless service delivery. Business continuity is not merely a precaution; it is a core requirement for all our suppliers. Suppliers must take a proactive approach to anticipate, plan for, and respond to disruptions that could impact their ability to fulfill obligations to Axtria. This includes developing a robust Disaster Recovery Plan to address unforeseen events such as natural disasters, cyberattacks, or major system failures. Suppliers should periodically update their Business Continuity and Disaster Recovery Plans, ensuring they remain relevant and effective.

Key components of a robust Business Continuity and Disaster Recovery Plans include:

  • Risk Assessment and Business Impact Analysis (BIA): Suppliers must identify potential threats to their operations and evaluate the impact of various disruption scenarios. This analysis should prioritize functions based on their criticality to Axtria’s supply chain.
  • Recovery Strategies: Suppliers must define clear recovery strategies for each critical function. This may include alternate suppliers, backup facilities, remote work capabilities, and redundant systems. Recovery Time Objectives (RTOs) and Recovery Point Objectives (RPOs) should be established and aligned with Axtria’s expectations.
  • Emergency Response and Crisis Management: Suppliers must have procedures in place for responding to emergencies, including communication protocols, roles and responsibilities, and escalation paths. A designated crisis management team should be trained and empowered to make decisions during a disruption.
  • IT Disaster Recovery: For suppliers providing technology services or relying on IT infrastructure, a separate IT Disaster Recovery Plan (DRP) must be in place. This plan should address data backup, system restoration, cybersecurity, and cloud service continuity.
  • Testing and Training: Suppliers must conduct regular testing of their Business Continuity and Disaster Recovery Plans through simulations, tabletop exercises, or full-scale drills. Employees must be trained on their roles in the plan, and lessons learned from tests should be used to improve preparedness.
  • Third-Party Dependencies: Suppliers must assess the resilience of their own suppliers and partners. This includes verifying that critical third parties have Business Continuity and Disaster Recovery Plans in place and that their plans are compatible with Axtria’s continuity requirements.

Communication and Transparency

In the event of a disruption, suppliers must notify Axtria immediately and provide timely updates on the situation, expected recovery timelines, and any potential impact on deliverables. Open and honest communication is essential to enable Axtria to manage client expectations and implement contingency measures.

Audits and Reviews

Axtria reserves the right to review suppliers’ Business Continuity and Disaster Recovery Plans and request evidence of testing and updates. Suppliers may be required to participate in joint continuity planning sessions or provide documentation demonstrating their preparedness.

5. BUSINESS INTEGRITY

Axtria operates in a highly regulated and ethically sensitive industry. As a company that supports various clients, including pharmaceutical and life sciences clients, we hold ourselves and our suppliers to the highest standards of business integrity. Suppliers operating in or supporting the pharmaceutical sector must demonstrate a deep commitment to ethical conduct, regulatory compliance, and patient safety. This section outlines the expectations Axtria places on its suppliers to uphold integrity in all aspects of pharmaceutical operations.

Regulatory Compliance and Ethical Standards

Suppliers must comply with all applicable laws, regulations, and industry codes governing the pharmaceutical sector. This includes, but is not limited to, Good Manufacturing Practices (GMP), Good Distribution Practices (GDP), Good Laboratory Practices (GLP), and Good Clinical Practices (GCP). Suppliers must also adhere to ethical standards set by organizations such as the International Council for Harmonisation of Technical Requirements for Pharmaceuticals for Human Use (ICH), the U.S. Food and Drug Administration (FDA), the European Medicines Agency (EMA), and other relevant regulatory bodies.
Compliance is not limited to technical standards. Suppliers must also ensure that their business practices reflect honesty, transparency, and fairness. This includes accurate labeling, truthful marketing, and responsible communication with healthcare professionals and patients.

Product Quality and Safety

Suppliers must implement robust quality management systems to ensure the safety, efficacy, and consistency of pharmaceutical products. This includes rigorous testing, validation, and documentation of all processes. Any deviation from established procedures must be investigated, documented, and corrected promptly.

Suppliers must also have systems in place to manage product recalls, adverse event reporting, and pharmacovigilance. These systems must be capable of identifying and responding to safety concerns in a timely and effective manner.

Supply Chain Integrity

The integrity of the pharmaceutical supply chain is critical to patient safety. Suppliers must take steps to prevent counterfeiting, contamination, and diversion of pharmaceutical products. This includes secure packaging, serialization, and tracking systems that comply with regulations such as the U.S. Drug Supply Chain Security Act (DSCSA) and the EU Falsified Medicines Directive.
Suppliers must also vet their own suppliers and subcontractors to ensure that they meet the same standards of integrity and compliance. Axtria reserves the right to audit the entire supply chain to verify adherence to these standards.

6. SUSTAINABILITY COMPALINACE & CARBON FOOTPRINT MANAGEMENT

Axtria is committed to environmental sustainability and expects its suppliers to actively monitor, manage, and reduce their carbon footprint. Suppliers must identify and quantify their greenhouse gas (GHG) emissions across all scopes—direct emissions, indirect emissions from purchased energy, and other indirect emissions across the value chain. This requires implementing robust emissions tracking systems, assigning accountability at various operational levels, and establishing protocols for consistent reporting and review.

Suppliers are encouraged to set science-based targets aligned with global climate goals such as the Paris Agreement, aiming for measurable reductions in emissions across short- and long-term timelines. For example, suppliers could adopt renewable energy sources like solar or wind for manufacturing facilities, replace traditional fleet vehicles with electric or hybrid options, and promote energy-efficient practices, such as LED lighting and smart building technologies, within their operations. Other initiatives might include waste reduction programs, sustainable water usage, and the use of biodegradable or recyclable materials for packaging.

To foster accountability, suppliers should actively engage in international environmental disclosure platforms such as the Carbon Disclosure Project or the Global Reporting Initiative, sharing detailed progress reports and benchmarks on sustainability efforts. Collaborations with industry partners for shared infrastructure solutions—like using eco-friendly logistics hubs—can also drive impactful results.

Axtria expects suppliers to participate in cross-functional workshops or training sessions focused on sustainable practices, equipping their teams with the latest skills and innovations in mitigating environmental impact. Action items may include:

  • Conducting annual audits of emissions data and presenting the findings to Axtria upon request.
  • Developing an emissions reduction roadmap with clear milestones and assigning dedicated resources for execution.
  • Integrating sustainability clauses into contracts with subcontractors and partners to ensure alignment across the supply chain.
  • Experimenting with and adopting circular economy principles, such as reusing waste materials in production cycles.

Axtria values transparency and innovation in climate action and expects suppliers to collaborate on initiatives that support a low-carbon economy. This collaboration could involve joint projects to develop new sustainable technologies or sharing best practices across the supplier network. Furthermore, Axtria emphasizes the importance of embedding environmental responsibility into the corporate culture of suppliers, ensuring that sustainability is a core priority at every level of the organization.

7. CONTINUOUS IMPROVEMENT AND MANAGEMENT SYSTEMS 

Axtria expects its suppliers to demonstrate a proactive commitment to continuous improvement in ethical, environmental, and operational performance. Suppliers must establish and maintain effective management systems that support compliance with this Code, including policies, procedures, and performance monitoring tools. These systems should be regularly reviewed and updated to reflect evolving best practices and regulatory requirements. Axtria encourages suppliers to set measurable goals, track progress, and engage in benchmarking and third-party audits to drive accountability and transparency across their operations.

8. CONFLICT OF INTERESTS

Suppliers are required to proactively avoid Conflict of Interest circumstances where personal, financial, or other interests might interfere with their obligations to Axtria. For instance, situations such as having a close familial relationship with an Axtria employee who is involved in procurement decisions or holding ownership stakes in a competing enterprise could create conflicts of interest. Any actual or potential conflicts, whether related to business relationships, financial arrangements, or personal interests, must be disclosed promptly to Axtria to ensure transparency.

To address these challenges, suppliers should institute robust internal policies and procedures aimed at identifying, managing, and mitigating such conflicts. For example, implementing a structured internal review process for business transactions can help ensure that decisions are made objectively. Another example could include engaging third-party audits to verify the impartiality of their operations. Transparency and adherence to ethical standards in all business interactions are indispensable for fostering trust and maintaining the highest level of collaboration across the supply chain.

9. BOOKS AND RECORD KEEPING

Axtria expects its suppliers to maintain accurate, transparent, and comprehensive records to ensure compliance with legal, regulatory, and contractual obligations. Suppliers must ensure all financial, operational, and transactional records are accurate and complete, avoiding any falsification or manipulation. Records should be retained as required by applicable laws or contractual agreements, with clear policies for secure disposal, and stored in a manner that allows timely retrieval for audits or inquiries. Confidential information within records must be protected with measures such as encryption and secure storage, ensuring access is limited to authorized personnel. Suppliers should participate in periodic audits by Axtria or third parties, address discrepancies promptly, and regularly review their record-keeping practices to align with evolving standards, updating policies and procedures accordingly. By adhering to these requirements, suppliers demonstrate their commitment to ethical and transparent operations, fostering trust and collaboration across the supply chain.

10. GIFTS, ENTERTAINMENT, HOSPITALITY, GRATUITIES AND OTHER FAVORS

Suppliers must avoid offering or accepting gifts, entertainment, hospitality, or other favors that could influence—or appear to influence—business decisions involving Axtria. Such exchanges, if permitted, must be modest in value, infrequent, and consistent with customary business practices, applicable laws, and Axtria's policies, particularly the Axtria Gift Policy. For example, symbolic or promotional items such as pens, calendars, or branded merchandise may be acceptable under certain circumstances, provided they do not create a perception of impropriety.

Lavish or inappropriate gifts, cash equivalents, or anything that could be construed as a bribe are strictly prohibited, as these undermine trust and compromise ethical standards. Suppliers must also be vigilant in recognizing the fine line between legitimate professional courtesies and potentially coercive gestures.

To ensure transparency and accountability, suppliers are required to document all instances of gift exchanges or offers and provide these records upon request. Any potential conflicts of interest or questionable offers should be promptly reported to Axtria, allowing for timely resolution and safeguarding the integrity of business relationships. By adhering to these guidelines, suppliers contribute to a fair and ethical partnership model that prioritizes trust and mutual respect.

11. FRAUD PREVENTION

Axtria maintains a zero-tolerance policy toward fraud in any form. Suppliers must not engage in deceptive practices such as falsifying records, misrepresenting facts, inflating invoices, or manipulating financial data. Internal controls must be in place to detect and prevent fraudulent activities, and employees must be trained to recognize and report suspicious behavior. Any instance of fraud must be reported to Axtria immediately, along with a full investigation and corrective action plan. Continued partnership is contingent on the supplier’s commitment to transparency and accountability.

In addition to avoiding fraudulent conduct, suppliers are expected to implement proactive fraud prevention measures. This includes conducting regular audits, segregating duties, enforcing approval hierarchies, and using secure systems for financial transactions. Suppliers should foster a culture of integrity by establishing whistleblower mechanisms and protecting individuals who report misconduct. Axtria values suppliers who demonstrate a strong ethical foundation and who take active steps to safeguard against financial and reputational risks.

12. HEALTH AND SAFETY

Axtria requires all suppliers to provide a safe and healthy working environment for their employees, contractors, and visitors. This includes compliance with all applicable occupational health and safety laws, regulations, and industry standards. Suppliers must identify and mitigate workplace hazards, conduct regular safety training, and maintain emergency preparedness plans. Facilities must be equipped with appropriate safety equipment, signage, and first-aid resources. Axtria encourages a proactive safety culture where incidents are reported, investigated, and used as learning opportunities to prevent recurrence.

Axtria expects suppliers to protect the fundamental rights of workers, including the right to fair wages, safe working conditions, and freedom from discrimination and harassment. Suppliers must comply with all applicable labor laws and international labor standards, including those set by the International Labour Organization (ILO). This includes respecting working hours, providing rest periods, and ensuring that employment terms are clearly communicated and honored. Suppliers should also promote equal opportunity and foster inclusive workplaces that value diversity and employee well-being. Axtria Suppliers must confirm that they comply with their legal obligations, in relation to Human Rights, including Modern Slavery, and are committed to ensuring there is no slavery, forced labour or servitude, child labour or other human rights violations taking place in their business, or any of their supply chains.

13. PRIVACY OF PERSONAL INFORMATION

Suppliers must protect all confidential, proprietary, and personal data entrusted to them by Axtria, its clients, or third parties. This includes implementing robust data privacy policies, secure IT infrastructure, and access controls to prevent unauthorized use, disclosure, or loss of information. Suppliers must comply with applicable data protection laws such as the General Data Protection Regulation (GDPR), and ensure that intellectual property rights are respected and safeguarded. Any data breaches or security incidents must be reported to Axtria immediately, along with a detailed remediation plan.

In addition to protecting Axtria’s proprietary information, suppliers must ensure the lawful and ethical handling of all personal data they collect, process, or store. This includes data related to employees, customers, and business partners. Regular audits, employee training, and privacy impact assessments should be conducted to maintain compliance and build trust with stakeholders.

Supplier must comply with the following safeguards:

  • Collect personal information only for legitimate business purposes and keep it only as long as necessary.
  • Take adequate precautions to safeguard personal information.
  • Share personal information only with individuals who have a legitimate need for it and will protect it properly.
  • Allow individuals whose personal data is held by the Supplier to review and correct the information.
  • Properly destroy records containing personal information according to Company guidelines.
  • Comply with all applicable international data privacy laws, including but not limited to the General Data Protection Regulation (GDPR) (EU), California Consumer Privacy Act (CCPA) (USA), Personal Information Protection and Electronic Documents Act (PIPEDA) (Canada), Personal Data Protection Act (PDPA) (Singapore), Data Protection Act (DPA) (UK), Privacy Act (Australia), Personal Information Protection Law (PIPL) (China), Digital Personal Data Act (India).
  • All Cross-Border Data Transfers shall be compliant with applicable international legislation and shall only be done after executing the required documentation.
14. INSIDE INFORMATION

Axtria prohibits “insider trading”. It is illegal to buy or sell securities (for example, stocks, bonds or options) of a company when you are aware of “inside information”— material, non-public information— relating to the company. Securities laws and Axtria policy prohibit you from using or disclosing any inside information that you may acquire during the course of your engagement at Axtria.

You cannot use information gained through your engagement with Axtria, before this information is known publicly, to buy or sell the securities of any company with which Axtria has or may be considering a relationship (for example, a customer, supplier, alliance partner or potential acquisition candidate).

Nor can you give inside information to anyone else so that they can trade. This applies no matter where you live or where the receiver of the information lives. Securities law violations are taken very seriously. Government agencies and stock exchanges are able to monitor trading activities through computerized records searches. Violations may result in significant civil and criminal penalties against companies and individuals.

15. INFORMATION SECURITY AND CYBER SECURITY

Suppliers must implement robust information security and cybersecurity measures to protect Axtria’s data, systems, and intellectual property from unauthorized access, breaches, and cyber threats. This includes maintaining secure IT infrastructure, using encryption for sensitive data, enforcing strong access controls, and regularly updating software and security protocols. Suppliers should conduct periodic risk assessments, penetration testing, and employee training to ensure preparedness against evolving cyber risks. Any security incidents or breaches must be reported to Axtria immediately, along with a detailed investigation and remediation plan.

16. RAISING CONCERNS

Suppliers must provide safe, accessible, and confidential channels for its employees and stakeholders to raise concerns about unethical behavior, legal violations, or breaches of this Code or any other violations. These mechanisms should allow for anonymous reporting and protect whistleblowers from retaliation. Concerns must be investigated promptly and thoroughly, with appropriate corrective actions taken. Axtria encourages a culture of openness and accountability and reserves the right to conduct its own investigations or audits if necessary.

17. COMPLIANCE WITH ALL APPLICABLE RULES AND REGULATIONS 

Axtria mandates that all its suppliers strictly comply with federal (central), state, and local laws and regulations, including tax laws, as well as adhere to Axtria's internal rules and policies. Suppliers are expected to uphold their responsibility by ensuring that all their corporate activities align not only with legal requirements but also with ethical business practices and social values. Axtria holds its suppliers accountable for demonstrating compliance across all facets of their operations, including but not limited to supply chain management, employee treatment, financial reporting, and environmental stewardship. Suppliers must also remain vigilant in staying updated on any changes to applicable laws and regulations to ensure ongoing compliance. This commitment to meticulous adherence to legal and regulatory standards is not merely encouraged but is an unequivocal requirement for all business partnerships with Axtria.