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Business Partner Code of Conduct

This document was last updated September 2026.

Corporate integrity, responsible sourcing and the safety and wellbeing of workers in the countries where we do business are of paramount importance to 4most. These core principles are reflected in this Code of Conduct for our Business Partners (Code), which establishes the minimum standards that must be met by any entity that we work with.

The requirements of this Code apply to Business Partners to the extent relevant to the nature of their activities and their relationship with 4most.

In this Code:

Business Partner means a company, partnership or individual that provides goods or services to one or more members of the 4most group, receives goods or services from one of more members of the 4most group or otherwise has a business relationship with a member of the 4most group.

Representative means a Business Partner’s suppliers, agents, subcontractors or other third party engaged by a Business Partner in connection with its relationship with 4most.

BUSINESS PARTNER’S COMMITMENT

The Business Partner agrees that:

  • It will comply with the requirements in this Code.
  • It has appropriate systems in place to ensure continuous compliance and to demonstrate such compliance.
  • Any breach of this Code will allow 4most to terminate its relationship with the Business Partner with immediate effect.

1. Compliance with laws and regulations and priority of standards
 
In carrying out its agreement(s) with 4most, the Business Partner shall, in addition to complying with the standards set out in this Code, conduct its activities responsibly, ethically and with integrity, and comply with all applicable laws relevant to its operations and supply chain, including those applicable in any jurisdiction in which it or its Representatives operate.
 

2. Updating this Code
 
4most reviews and updates this Code periodically, typically on an annual basis. Business Partners are responsible for ensuring that they are familiar with the current version of the Code, which is available on 4most’s website. Continued engagement with 4most following publication of an updated version of the Code constitutes acknowledgement of the updated Code.
 

3. Workforce issues
 
3.1 Slavery, human trafficking and child labour.
The Business Partner shall take appropriate steps to prevent slavery, servitude, forced labour, human trafficking, child labour and any other form of exploitation within its operations and supply chain. The Business Partner shall not directly or indirectly support, engage in or benefit from the use of forced labour, child labour or prison labour and shall maintain policies and procedures appropriate to the nature and size of its business to identify, assess and address such risks
 
3.2 Human rights.
The Business Partner shall respect internationally recognised human rights and fundamental labour rights across its operations and supply chain and shall take reasonable steps to identify, prevent and address any adverse human rights impacts connected with its activities.
 
3.3 Equal opportunities.
4most is an equal opportunities employer. The Business Partners shall not discriminate in hiring, compensation, training, advancement or promotion, termination, retirement or any employment practice based on race, caste, colour, national origin, gender, gender identity, sexual orientation, religion, age, marital or pregnancy status, disability, union membership or political affiliation or any other characteristic other than the worker’s ability to perform the job subject to any accommodations required or permitted by law.
 
3.4 Accessibility.
The Business Partner shall support accessibility and inclusion by taking reasonable steps to ensure that its services, communications and working arrangements are accessible and inclusive, and by making reasonable adjustments where appropriate to enable workers, customers and other stakeholders to participate fairly and safely.
 
3.5 Diversity & Inclusion.
The Business Partner shall promote an inclusive working environment in which workers are treated fairly and with dignity and respect. The Business Partner shall take reasonable steps to foster a culture of inclusion and equal opportunity.
 
3.6 Dignity at work.
The Business Partner shall not permit its workers or Representatives to harass, bully, victimise or otherwise engage in inappropriate or abusive conduct towards any person, including 4most personnel. Harassment includes unwanted conduct, including conduct of a sexual nature, whether in person, in writing or by electronic means, and whether at the Business Partner’s premises, at 4most’s premises, at any location where services are performed, or at business or social events connected with the relationship. The Business Partner shall take reasonable steps to prevent such conduct, provide appropriate reporting channels, investigate concerns fairly and promptly, take appropriate corrective action and protect individuals who raise concerns in good faith from retaliation.
 
3.7 Freedom of association and collective bargaining.
The Business Partner 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.
 
3.8 Working environment.
The Business Partner shall provide a safe, healthy, and sanitary working environment and comply with all health and safety requirements where it operates. This includes, but is not limited to, implementing general and relevant industry-specific procedures and safeguards to prevent workplace hazards and work-related accidents and injuries. Where such hazards cannot be adequately prevented or controlled, the Business Partner shall provide workers with appropriate personal protective equipment to protect against hazards typically encountered in that scope of work.
 
3.9 Wages and remuneration.
The Business Partner must compensate all workers with wages, including overtime premiums, and benefits that at a minimum meet the higher of: (a) the minimum wage and benefits established by applicable law (b) collective agreements (c) industry standards and (d) an amount sufficient to cover basic living requirements.
 
3.10 Whistleblowing.
The Business Partner shall encourage workers and other stakeholders to raise concerns in good faith about misconduct, unethical behaviour or legal or other breaches of this Code. The Business Partner shall provide safe and accessible reporting channels, investigate concerns appropriately and protect anyone who raises a concern in good faith from victimisation, retaliation or other detrimental treatment.
 
3.11 Complaints Handling.
The Business Partner shall maintain effective procedures for the fair and timely resolution of complaints relating to its operations, services and supply chain.
 

4. Protection of Information
 
4.1 Data Protection:
The Business Partner shall handle personal data lawfully, fairly, securely and comply with all data protection requirements when processing any personal data on 4most’s behalf.
 
4.2 Information Security:
The Business Partner shall have in place appropriate measures to:

(a) protect the integrity of information (including information belonging to or supplied by 4most) held on its systems (which include physical and online or electronic systems); and
 
(b) ensure that there is no unauthorised access of the information by third parties, including its Representatives.

 
4.3 Confidentiality.
The Business Partner shall treat all information obtained through its relationship with 4most as strictly confidential. This includes but is not limited to business, financial, technical, personal and proprietary information relating to 4most, its clients, or its affiliates. The Business Partner shall:

(a) use such information solely for the purpose of fulfilling its obligations to 4most and not for any other purpose, whether commercial or otherwise;
 
(b) not disclose any confidential information to any third party without the prior written of 4most, except where required by law or regulation;
 
(c) ensure that all employees, agents, and Representatives who have access to confidential information are bound by confidentiality obligations at least as restrictive as those set out in this Code;
 
(d) implement appropriate technical and organisational measures to safeguard confidential information against unauthorised, use, disclosure, alteration, or destruction;
 
(e) promptly notify 4most of any actual or suspected unauthorised disclosure or misuse of confidential information and cooperate fully with any investigation or remediation efforts; and
 
(f) upon termination of the business relationship, or upon request by 4most, return or securely destroy all confidential information in its possession, including all copies, whether in physical or electronic form, unless retention is required by law.

 
4.4
The obligations of confidentiality set out above shall survive the termination of the business relationship for as long as the information remains confidential.
 
4.5 Use of AI.
The Business Partner shall use artificial intelligence systems responsibly, lawfully, securely and transparently. Where AI systems or tools are used in connection with services provided to 4most, the Business Partner shall:

(a) ensure appropriate governance, security, access controls and human oversight are in place;
 
(b) not input, upload, disclose or otherwise provide any confidential information, personal data or information belonging to 4most or its customers unless expressly authorised in writing by 4most;
 
(c) not permit 4most or client information to be used to train or improve third-party AI models;
 
(d) ensure that the use of AI does not compromise confidentiality, data protection, intellectual property rights, security, fairness or compliance with applicable legal and regulatory obligations; and
 
(e) remain responsible for the accuracy, quality and appropriateness of any services or deliverables produced using AI.

 

5. Environmental responsibility
 
5.1
The Business Partner shall ensure that:

(a) its operations comply with all applicable environmental requirements, including international treaties relating to (but not limited to) climate change, waste disposal, emissions, discharges and the handling of hazardous and toxic materials;
 
(b) the goods it manufactures (including the inputs and components that it incorporates into its goods) comply with all applicable environmental laws and treaties; and
 
(c) it will only use packaging materials that comply with all applicable environmental laws and treaties.

 

6. Bribery and corruption
 
6.1
The Business Partner shall conduct business with integrity and maintain appropriate controls to prevent bribery and corruption in its operations and supply chain. To that end, the Business Partner shall not accept, offer, promise, pay, permit or authorise:

(a) bribes, facilitation payments, kickbacks or illegal political contributions;
 
(b) money, goods, services, entertainment, employment, contracts or other things of value, in order to obtain or retain improper advantage; or
 
(c) any other unlawful or improper payments or benefits.

 

7. Sanctions and trade controls
 
7.1
The Business Partner shall not engage in, support or facilitate any activity that would breach applicable sanctions, trade controls, export restrictions or similar requirements, and shall maintain appropriate controls across its operations and supply chain to identify, assess and manage related risks.
 

8. Unfair business practices
 
8.1
The Business Partner shall compete fairly and act with integrity in the market. The Business Partner shall refrain from anti-competitive practices such as collusion with competitors, unlawful information sharing, price fixing and rigging bids, or any other conduct that undermines fair competition.
 
8.2
The Business Partner shall not misuse confidential, non public or privileged information for personal, commercial or market advantage and shall not engage in insider dealing, unlawful disclosure of information, market manipulation or any similar improper conduct.
 

9. Procuring and managing Representatives
 
(a) The Business Partner shall take reasonable steps to select, engage and manage Representatives in a manner consistent with the principles set out in this Code.
 
(b) The Business Partner shall undertake risk-based due diligence on Representatives, having regard to the nature of the services, geography, level of risk and the Representative’s ability to comply with applicable legal, ethical and responsible business standards.
 
(c) The Business Partner shall take reasonable steps to ensure that Representatives acting in connection with its operations comply with standards consistent with the principles set out in this Code and shall address any material concerns or breaches that come to its attention.
 
1.4
The Business Partner shall deal fairly and transparently with its Representatives, including by maintaining appropriate processes for the timely payment of undisputed invoices.
 

10. Training
 
10.1
The Business Partner shall implement and maintain a comprehensive training and awareness programme for its workers to ensure that they understand and are able to comply with the principles of this Code.
 

11. Certification and audit
 
11.1
The Business Partner shall provide written confirmation to 4most upon request that:

(a) it has appropriate systems in place to monitor its compliance with this Code; and
 
(b) it is able to comply with this Code for the duration of its relationship with 4most.

 
11.2
In addition to the written confirmation at 11.1, 4most may conduct audits and inspections to verify the Business Partner’s compliance with this Code. 4most has no obligation to conduct such audits or inspections.
 

12. Breach, remediation and termination
 
12.1
Where 4most becomes aware of a breach of this Code by the Business Partner or its workers, 4most may either:

(a) immediately terminate its business relationship with the Business Partner (including any contracts); or
 
(b) require the Business Partner to produce a remediation plan specifying the actions that the Business Partner will take that will lead to compliance with the Code. If the Business Partner fails to produce the remediation plan within an agreed timeframe or fails to implement it within a reasonable time, 4most may immediately terminate its business relationship with the Business Partner (including any contracts).

 
12.2
Where 4most becomes aware that a Representative has been involved in an incident (or incidents) that would constitute a breach of any of the requirements under this Code, were they bound directly by it, 4most may either:

(a) terminate its business relationship with the Business Partner (including any contracts); or
 
(b) require the Business Partner to remedy that incident (or incidents) with that Representative. If the Business Partner is not able to remedy such incident with that Representative within a reasonable time, 4most may immediately terminate its business relationship with the Business Partner (including any contracts).