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HOSTINGER THIRD PARTY CODE OF CONDUCT 

HOSTINGER, UAB and the companies belonging to the group (Hostinger; the Company) aim to contribute to sustainable development in their operations and conduct their activities responsibly and ethically, in line with the belief that all businesses should do the same.

Therefore, Hostinger has developed this Third Party Code of Conduct (the Code) to align the engagement of its Third Parties in environmental, social, and governance (ESG) practices with Hostinger's values and establish standards of conduct that they are expected to follow.

This Code applies to Hostinger suppliers, vendors, service providers, consultants, partners, and any other third parties that conduct business with or on behalf of Hostinger or provide goods or services to Hostinger (Third Party). 

This Code of Ethics sets out the minimum standards of business conduct that we expect all our Third Parties to adhere to and, where possible, to exceed. To ensure compliance with the Code, the Third Party should have appropriate controls to implement policies and procedures proportionate to the size, complexity, and risk environment.

If the Third Party faces difficulties correcting identified non-compliance with this Code or has questions regarding the provisions, the Third Party shall contact the Hostinger's through a whistleblowing channel to raise concerns regarding Code violations.

Environment

1. The Third Party complies with all mandatory environmental requirements defined in the applicable legislation.
2. The Third Party aims to identify, evaluate, and reduce the negative impact of its activities on the environment regularly and ensure continuous improvement of environmental performance.
3. The Third Party actively seeks to contribute to the goals of promoting the circular economy of the European Union in the cycle of development, production, and supply of goods, as well as in the provision of services or works and recycling aspects.
4. The Third Party seeks to use electricity more efficiently and/or renewable energy sources to produce, supply, and/or use the goods to provide services or perform the works.
5. The Third Party uses less or no dangerous chemicals to produce goods, provide services, perform work, does not pose a risk to human health, and actively strives not to harm the environment.
6. The Third Party develops the competence of its employees and a responsible approach to environmental protection.

Human Rights

1. The Third Party supports and respects the protection of internationally proclaimed human rights outlined in the Universal Declaration of Human Rights and the United Nations Global Compact and ensures it is not complicit in human rights abuses within its business operations.
2. The Third Party eliminates discrimination with respect to hiring and employment. No discrimination is permitted based on nationality, sex, gender identity, age, religion, education, disabilities, sexual orientation, marital or family status, economic/class status, or characteristic unrelated to the individual's merit or the inherent requirements of the position sought.
3. The Third Party ensures that no one is subjected to cruel, inhuman, or degrading treatment or punishment through its business activities and does not tolerate, support, or encourage any form of physical contact that is sexual, coercive, threatening, abusive or exploitative, or any form of psychological or verbal harassment, intimidation, threats or insults.
4. The Third Party respects the employees' freedom of expression and does not take repressive measures against those who use this freedom.
5. The Third Party protects employees who report or witness incidents and their representatives from hostile behavior, retaliation, and other negative consequences.

Labor

1. The Third Party pays its employees a fair wage in the labor market following national legislation and market practice.
2. The Third Party ensures that the employee's maximum working hours during a specific period are not exceeded. The Third Party shall compensate overtime by applying premiums following the rates established in national legislation or collective agreements.
3. The Third Party provides its employees with written individual or collective employment agreements that contain clear terms and conditions detailing (but not limited to) hours of work, overtime pay, job description, notice periods, salary, and frequency of payment of wages.
4. The Third Party upholds the freedom of association and the effective recognition of the right to collective bargaining, including channels for individuals to communicate openly with management without the threat of retaliation, intimidation, or harassment.
5. The Third Party eliminates all forms of forced and compulsory labor, including such practices as the unlawful or illegitimate withholding of wages, identity or immigration documents. Work must be conducted based on freely agreed terms. The Third Party shall not allow any practice that would restrict the free movement of employees.
6. The Third Party prohibits child labor in its direct and indirect activities and actively works towards the effective eradication of child labor. The minimum age of employment is defined in International Labour Organization Minimum Age Convention No. 138.
7. The Third Party ensures that work conducted by young workers aged 15-18 does not prevent them from attending school legally and does not pose any danger or risk to their physical and mental health or development.

Health and safety

1. The Third Party ensures a safe and healthy workplace that complies with all applicable health and safety laws and regulations at all locations where the Third Party's employees conduct their work. All hazardous work is preceded by and is based on documented adequate risk management with implemented controls.
2. The Third Party prepares safety and health instructions considering the specifics and dangers of the work performed by its employees, familiarizes them, and ensures compliance with these instructions.
3. The Third Party provides its employees with the necessary training and appropriate safety and health equipment and work tools.

Anti-corruption and anti-competitive behavior

1. The Third Party works against corruption in all its forms, including extortion and bribery. The Third Party does not offer, ask, give or accept any benefits, including, but not limited to: cash, cash equivalents (including gift cards), loans, gifts, travel or entertainment, business advantages, favors, discounts, rebates, unauthorized payments, political contributions,  job opportunities or other means to obtain any undue or improper advantage. We expect that the Third Party will have a clear anti-corruption policy.
2. The Third Party does not enter into discussions or agreements with competitors concerning pricing, market sharing, or other similar activities.
3. The Third Party immediately informs Hostinger's representative of any circumstances that may result in a conflict of interest to any employee of Hostinger during cooperation with such Third Party (e.g., friendship, relationship, family ties, etc).

Anti-money laundering

1. The Third Party does not provide any service or enter into any arrangement that facilitates or may constitute Hostinger or a Third Party directly or indirectly involved in economic crime, including money laundering activities. The Third Party does not channel funds to or support illegal activities (e.g., terrorism, tax evasion, fraud).
2. The Third Party complies with applicable economic sanctions and export control laws and regulations and avoids doing anything that would position themselves or Hostinger in violation of appropriate economic sanctions and export controls.

Data protection and IP

1. The Third Party handles and discloses personal data and confidential information they obtain during their partnerships with Hostinger only as authorized and directed by Hostinger and as required by applicable laws and regulations. The Third Party protects personal data and confidential information against unauthorized and unlawful use, disclosure, access, loss, alteration, damage, and destruction.
2. The Third Party respects intellectual property rights and does not obtain, distribute, or use unlicensed copyrighted software or information without proper authorization. 

Complaints and grievances

1. The Third Party makes grievance and/or whistleblowing mechanisms available to personnel and interested parties to make comments, recommendations, reports, or complaints concerning the workplace, the environment, the Third Party's business practices, or the conduct of the Third Party's employees.

Hostinger reserves the right to verify compliance with this Code through dialogue, internal or external assessment mechanisms, and due diligence to assess its relationship with the Third Party. Hostinger expects the Third Party to provide complete, timely, and accurate information when requested.

Hostinger may require the Third Party to implement a remediation plan, or, in certain circumstances at its discretion, it may suspend or terminate the relationship with the Third Party by written notice effective immediately. In any case, Hostinger will terminate connections with the Third Party if the Third Party fails to fully cooperate with Hostinger in an investigation of possible infringement of this Code by the Third Party.