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OLX Supplier Code of Business Ethics and Conduct

The Code explained October 2022

What do we expect from our Suppliers?

We all need to comply with the law, but this Code is about more than following legal requirements. It sets out our expectations for the ways  we should behave. Specifically, we expect all our Suppliers to:

  • Do business in an honest, sincere and trustworthy way.
  • Act ethically and in line with accepted standards of behavior.
  • Report incidents of non-compliance with the Code or any other wrongdoing  in good faith.

This document is based upon both the Prosus and OLX Code of Business Ethics & Conduct.  These define the way in which Prosus and all subsidiaries, including all OLX controlled entities, conduct business and treat all their stakeholders.  The full Prosus code along with other key ethics and compliance documents can be found here: https://www.prosus.com/about/policies

PEOPLE

We take our responsibility to build a sustainable world for everyone seriously.

OLX expects that our Suppliers promote mutual respect in the working environment and reflect the diversity of the communities where we all work.

We expect you to follow all applicable laws relating to human rights and employment practices and strive to ensure that your workplace is welcoming and inclusive for everyone.  Like OLX you should be committed to the United Nations (UN) guiding principles on Business and Human Rights as well as the International Labour Organisation (ILO) Declaration on Fundamental Principles and Rights at Work, the UN Declaration of Human Rights,  the UN Global Compact, and the principles as set out in the Organisation for Economic Co-operation and  Development (OECD) guidelines for Multinational Enterprises.

 

Health and Safety

You should provide your employees with a safe and healthy work  environment. Your employees must follow environmental, safety and health rules and practices, and promptly report accidents and injuries, and unsafe equipment,  practices or conditions.

It’s an OLX policy to uphold high standards and maintain a work  environment that’s safe for employees, suppliers, contractors and visitors.  As a Supplier you should do the same.

 

Human Rights

Key business conduct requirements

  • Operate within the framework of locally applicable labour laws, regulations and employment practices.
  • Respect the freedom of our employees to establish or join organisations of their choice, and don’t make employment subject to the condition that an employee should accept or relinquish trade union membership.
  • Regularly engage with your employees to understand their priorities and concerns and address their feedback.
  • Never condone labour below the relevant legal minimum age requirements and don’t tolerate child labour (ie work that deprives children of their childhood, their potential and their dignity and that is harmful to their physical or mental development, including by interfering with their education).
  • Recognise the fundamental human rights of freely chosen employment  and don’t condone any form of forced labour (ie work or service that’s carried out under the threat of a penalty or where the person has not offered voluntarily).
  • All work directly or indirectly undertaken should be voluntary.
  • All employees should be provided with a written agreement describing the employee’s terms of employment in a language the employee understands. No person starting employment will be deprived of identity papers.
  • Don’t allow deductions from wages as a disciplinary measure unless  serious grounds require otherwise. In addition, any disciplinary measure  must be in accordance with applicable laws.
  • Comply with human rights legislation and you are not exposed to, or complicit in, human rights violations.
  • Pay fair and balanced compensation and benefits consistent with the provisions of all applicable wage laws, including those relating to minimum wage, overtime hours and legally mandated benefits. Employees are informed of pay and benefits in a detailed and clear manner before and during employment.
  • Support employees in achieving a work-life balance.

 

Diversity, equality, & inclusion

Like at OLX, we expect our Suppliers to be committed to an inclusive work environment where all individuals are treated with dignity and respect. Everyone has the right to work in a professional atmosphere that promotes equal employment opportunities and prohibits discriminatory practices. Commitment to inclusion means that we create an environment where our differences aren’t just respected but are valued and celebrated.

You must not tolerate any form of discrimination, harassment or offensive behaviour that makes anyone feel unwelcome or excluded.

You must not tolerate harassment or any mistreatment in the workplace or situations directly related to work. This includes harassment related to gender, gender identity, gender expression, transgender status, sexual stereotypes, sexual orientation, class, race, religion, creed, colour, marital or family status, age, nationality, political association or disability. The right to equality without discrimination doesn’t make all differences of treatment discriminatory.  Differentiation is possible if based on reasonable and objective criteria.

Key business conduct requirements

  • Identify and remove barriers to inclusion and make this a part of daily practice and culture.
  • Provide equal opportunities for everyone in recruiting, hiring, training, promotion and pay.
  • Value and respect differences of opinion, experiences, characteristics,  backgrounds and cultural identities. Promote employability and help people reach their potential through professional development.
  • Treat all applicants and employees equally, without any form of discrimination.
  • To achieve equality of opportunity, recognise that to be treated fairly, sometimes people need to be treated differently. For example, a person  with a disability may require adjustments in their work environment.
  • Follow all applicable laws relating  to discrimination in employment practices and strive to ensure that your workplace is welcoming and inclusive of all.

We expect our Suppliers to ensure and promote equal employment opportunity without discrimination or harassment on the basis of gender, gender identity,  gender expression, transgender status, sexual stereotypes, sexual orientation,  class, race, religion, creed, colour, marital or family status, age, nationality,  political association or disability.

 

Dignity, anti-bullying & anti-harassment

Key business conduct requirements

  • You and your employees should behave in a considerate and professional manner at all times. This includes:
    • Engaging respectfully with others. Any form of harassment (sexual or otherwise), aggression or bullying isn’t tolerated.
    • Avoiding offensive or rude comments, behaviours or jokes that  could offend, humiliate or intimidate others and being aware of possible personal or cultural sensitivities.
    • Challenging anyone who exhibits disrespectful, hostile or  intimidating behaviour.

RESPONSIBLE & SUSTAINABLE BUSINESS

Environment & social responsibility

Key business conduct requirements

Environmental:

  • You should be committed to minimizing your impact on the environment and address critical issues, including climate change and the responsible use of natural resources.
  • Recognize the urgency of climate change and commit to tackling its impact by embedding environmental considerations in our operations  and investment decisions. Limit your own environmental footprint by setting targets and focusing on reducing emissions across various parts of  your operation, such as responsible business travel, energy-efficient offices,  improved waste management and procurement of renewable energy.

Social:

  • Demonstrate responsible leadership by deploying technology that addresses big societal needs, improves people’s lives, and enriches the communities in which you live and work.
  • Commit to increasing the positive impact you have on society by growing your businesses in a sustainable way that helps to improve  people’s lives and strengthen communities.
  • Continue to be a responsible corporate citizen by aiming to solve  social challenges through partnerships and philanthropy, and, during times  of crisis, by supporting the communities where you operate.
  • Encourage and support businesses across your core segments to  implement corporate social responsibility initiatives that have the biggest positive impact locally.

 

Anti-bribery & anti-corruption

Key business conduct requirements

  • Your employees and third parties (including agents or representatives) acting on your behalf are prohibited from offering, promising, giving, demanding or accepting any illegal payment or advantage to or from  anyone in government and/or the private sector to gain, retain or direct  business, or to secure any other improper or undue advantage in the conduct of business.
  • Consider any charitable donations, political contributions or sponsorships  carefully. Such payments may never illegally influence a business outcome  and must be made to a legitimate organisation that has undergone an  appropriate level of due diligence.

 

Anti-money laundering & counter financing of terrorism

Key business conduct requirements

  • You should ensure compliance to all laws and regulations to avoid any exposure to situations in which you could inadvertently become involved in money laundering or terrorist financing.
  • Never knowingly deal with any supplier, contractor or third party involved in or suspected of involvement with criminal activity or handling the proceeds of crime.
  • Make sure that any business transactions conducted never involve acquiring or using the proceeds of criminal activity (whether cash or other property).
  • Make sure that any third parties you work with have been appropriately screened, and that screening is periodically updated to include the most  recent sanctions lists.

 

Fair competition & anti-trust

Key business conduct requirements

  • To  compete fairly and ethically within the framework of all applicable  competition laws, you shouldn’t prevent others from competing freely with you.
  • You should never:
    • Communicate with competitors about price and/or terms that affect pricing or production levels.
    • Make any formal or informal agreements with competitors regarding prices, discounts or terms and conditions.
    • Agree to divide or boycott clients or markets with competitors (by, for example, agreeing not to compete for a specific client or within  a specific territory), where the purpose or result of such discussion or agreement could potentially be collusive behavior.
    • Impose minimum resale prices on your customers.

 

Sanctions & export controls

Key business conduct requirements

  • You are aware of sanctions risks and of the consequences of your actions and business activities from a sanctions perspective.
  • When you are assessing new business activities or expansion, sanctions and export control risks are always considered.
  • You understand (and classify) any goods that you export which are restricted  by sanctions (including looking at their end use). You are aware of any  applicable export restrictions and license requirements.
  • You make sure that the third parties you do business with have been  screened against sanctions lists.

 

Speak Up

If you believe an OLX Employee or Supplier has breached our Code then we encourage you to Speak Up and, where possible, discuss your dilemma or concern with the person involved, your Contract Manager or, if you don’t feel comfortable doing this, want to remain anonymous or you’re not sure who to speak to, you can contact our Group Ethics & Compliance team directly by emailing [email protected]

Our Ethics & Compliance Officers are our trusted representatives and act as a local first point of contact for any employee or Supplier with questions or concerns related  to ethics and compliance.

Alternatively, you can visit the Speak Up Service website https://speakup.olxgroup.com which is operated by an external company. This service allows you to make a report via telephone or through the online portal (and then receive feedback from the Group Ethics & Compliance team within the system). You can choose to do this anonymously if preferred and permitted in your jurisdiction.