Version 1.0
Effective Date: Janurary 21, 2026
1. Introduction
Apkudo is committed to powering the circular device economy with the highest standards of integrity, ethics, and social responsibility. Our success is built on a foundation of trust with our customers, employees, and partners. We expect our suppliers, vendors, contractors, partners, and any other third-party entities doing business with Apkudo (collectively, "Third Parties") to share this commitment.
This Third-Party Code of Conduct ("Code") outlines the minimum standards of behavior and practice we require from our partners. Compliance with this Code is a condition of doing business with Apkudo. We expect our Third Parties to communicate and apply these standards to their own employees, suppliers, and subcontractors who are involved in providing goods or services to or on behalf of Apkudo.
Third Parties shall conduct their business in full compliance with all applicable laws, rules, and regulations of the jurisdictions in which they operate. This includes, but is not limited to, laws related to anti-bribery, anti-corruption, competition, data privacy, environmental protection, labor, and human rights.
2. Labor and Human Rights
Apkudo is committed to upholding the human rights of workers and treating them with dignity and respect. We expect our Third Parties to adhere to the following standards:
- Freely Chosen Employment: All work must be voluntary. Third Parties shall not use forced, bonded, indentured, or involuntary prison labor.
- Prohibition of Child Labor: Third Parties shall not employ children in any stage of their operations in violation of applicable laws.
- Working Hours and Compensation: Third Parties must comply with all applicable laws regarding working hours, overtime, and compensation. Wages and benefits must meet, at a minimum, the legal standards of the country of operation.
- Humane Treatment and Non-Discrimination: No harsh or inhumane treatment, including harassment, abuse, or corporal punishment, is permitted. Third Parties shall not engage in discrimination based on race, color, age, gender, sexual orientation, ethnicity, disability, religion, political affiliation, union membership, or marital status.
- Freedom of Association: Third Parties shall respect the right of workers to associate freely, join or not join labor unions, seek representation, and join workers' councils in accordance with local laws.
3. Health and Safety
Third Parties must provide a safe and healthy work environment to prevent accidents and injuries. This includes implementing procedures and training to manage occupational safety, handle emergencies, control exposure to physical, chemical, and biological hazards, and ensure the safety of company-provided facilities.
4. Environmental Responsibility
As a leader in the circular economy, Apkudo places a high value on environmental stewardship. We require our Third Parties to share this commitment.
- Compliance and Permits: Third Parties must comply with all applicable environmental laws and regulations and obtain all necessary environmental permits and licenses.
- Waste Management and E-Waste: Third Parties must have systems in place to ensure the safe handling, movement, storage, recycling, reuse, and disposal of waste, including electronic waste (e-waste). All disposal of e-waste must be conducted in an environmentally responsible manner, complying with standards such as R2 or e-Stewards where applicable.
- Pollution Prevention: Third Parties shall work to reduce or eliminate pollution from their operations, including air emissions, water discharges, and waste generation.
- Hazardous Substances: Third Parties must identify and manage hazardous substances to ensure their safe handling, use, and disposal.
5. Business Integrity and Ethics
- Anti-Bribery and Anti-Corruption: Third Parties shall not engage in any form of corruption, extortion, or embezzlement. Offering, paying, soliciting, or accepting bribes or other improper advantages to obtain or retain business is strictly prohibited. This applies to dealings with government officials and private sector partners.
- Gifts and Hospitality: Any business courtesies, such as gifts or entertainment, must be reasonable, infrequent, and transparent. They must not be intended to improperly influence, or appear to influence, any business decision.
- Conflicts of Interest: Third Parties must avoid all conflicts of interest or situations giving the appearance of a conflict of interest in their dealings with Apkudo. Any potential conflict must be disclosed to Apkudo immediately.
- Fair Competition: Third Parties shall conduct their business consistent with fair and vigorous competition and in compliance with all applicable antitrust laws.
- Fraud: Third Parties must not engage in any fraudulent activities, including misrepresentation, forgery, or deceptive practices, to gain any unfair or unlawful advantage.
6. Data Privacy and Information Security
Protecting data is paramount to Apkudo's business. Third Parties that access, process, store, or transmit confidential information or personal data to or from Apkudo, its clients, or their end-users must maintain robust security and privacy controls.
- Confidentiality: Third Parties must protect all of Apkudo's non-public information and use it only for the purposes authorized by Apkudo.
- Personal Data Protection: All personal data must be handled in compliance with applicable data protection laws (GDPR, PIPEDA, CCPA/CPRA, all other U.S. state and applicable international privacy laws). Third Parties must implement appropriate technical and organizational measures to protect personal data against unauthorized access, use, or disclosure.
- Information Security: Third Parties must maintain a comprehensive information security program that protects the confidentiality, integrity, and availability of Apkudo's and its customers' data. Any security incidents or data breaches affecting Apkudo must be reported immediately.
7. Intellectual Property
Third Parties must respect Apkudo's intellectual property rights, including patents, copyrights, trademarks, and trade secrets. The use of Apkudo’s intellectual property must be in accordance with the terms of the governing business agreement.
8. Supply Chain Responsibility
Third Parties are expected to apply the principles of this Code to their own suppliers and subcontractors. This includes implementing due diligence procedures to ensure that their supply chain is free from counterfeit parts and ethically sourced materials (e.g., conflict minerals).
9. Reporting, Audits, and Corrective Action
- Reporting Concerns: Third Parties are encouraged to report any concerns or suspected violations of this Code to their primary Apkudo contact or to Apkudo’s Compliance management team at compliance@apkudo.com. Apkudo prohibits retaliation against any party for making a good-faith report.
- Audits and Assessments: Apkudo reserves the right to verify compliance with this Code through audits, assessments, and facility inspections conducted by Apkudo or its designated representatives.
- Consequences of Violations: Any violation of this Code may jeopardize the Third Party's business relationship with Apkudo, up to and including termination of all agreements. Apkudo may require a Third Party to implement a corrective action plan to remedy any non-compliance.
10. Acknowledgment and Agreement
The Third Party acknowledges that they have read, understood, and agreed to comply with the principles and requirements outlined in the Apkudo Third-Party Code of Conduct.
The Third Party further agrees to communicate these standards to its relevant employees, agents, and subcontractors and to take reasonable steps to ensure their compliance.
