New Era Technology and its subsidiaries (“New Era” or “the Company”) are committed to conducting business with integrity, ethical behavior, and compliance with all applicable laws and regulations. We expect the same high standards from our suppliers and subcontractors.

This Supplier Code of Conduct (“Code”) sets out the minimum principles and requirements that all suppliers and subcontractors must follow in their provision of products and services to New Era Technology and any of its affiliates.

For the purposes of this Code, “You”, “Your”, “Supplier”, or “Subcontractor” means you as a company, including your officers, directors, employees, agents, and contractors. Each member of your organization engaged in providing products or services to New Era is expected to read, understand, and act in accordance with this Code.

We recognize that customs, practices, regulations, and laws vary across regions. This Code is intended to apply globally. Where local laws or regulations impose higher standards, those standards shall prevail. Certain regional variations (including EMEA, APAC, and LATAM) may apply where required.

This Code aligns with New Era’s compliance principles and the United Nations Global Compact Initiative.

Contents

Global Supplier Code of Conduct

1. Professional Conduct

2. Human Rights.

3. Labor Standards.

4. Environmental Responsibility.

5. Anti‑Corruption and Anti‑Bribery.

6. Confidentiality and Use of Information.

7. Information Security and Data Protection.

8. Performance Monitoring and Audits.

9. Compliance with New Era Policies.

10. Reporting Concerns.

11. Consequences of Non‑Compliance.

12. Conflict Resolution.

13. Updates.

14. Acknowledgement

1. Professional Conduct

Suppliers and subcontractors must uphold the highest levels of professionalism, integrity, and ethical behavior when performing services on behalf of New Era Technology.

This includes:

• Acting in a manner consistent with New Era’s values and ethical principles.
• Complying with any New Era Technology customer Code of Conduct applicable at the site(s) where services are performed.
• Ensuring all personnel are appropriately and professionally attired when delivering services for New Era and its customers.

2. Human Rights

Suppliers and subcontractors must:

• Support and respect internationally recognized human rights.
• Ensure they are not complicit in any form of human rights abuse.

3. Labor Standards

Suppliers and subcontractors must:

• Uphold freedom of association and the right to collective bargaining, consistent with applicable law.
• Prohibit all forms of forced, compulsory, and child labor.
• Eliminate discrimination in employment and occupation.
• Provide a safe and healthy working environment.
• Treat all employees with dignity, respect, fairness, and without discrimination.
• Employ and remunerate workers under fair, legally compliant, and transparent employment arrangements.
• Maintain internationally recognized minimum labor standards.

4. Environmental Responsibility

Suppliers and subcontractors must:

• Comply with all applicable environmental laws and regulations.
• Minimize environmental impact and pollution associated with their operations.
• Promote sustainable practices and initiatives that support environmental responsibility.
  

5. Anti‑Corruption and Anti‑Bribery

Suppliers and subcontractors must:

• Actively work against corruption in all forms, including extortion and bribery.
• Conduct business ethically and transparently, in compliance with applicable anti‑corruption laws and regulations.

6. Confidentiality and Use of Information

All information learned or accessed in connection with services provided to New Era Technology or its customers must be treated as confidential and proprietary.

Suppliers and subcontractors must:

• Protect all confidential information, data, and knowledge from unauthorized use or disclosure.
• Use such information solely for the purpose of performing contracted services.
• Not make public announcements or disclose information relating to services performed for New Era or its customers without prior authorization.
• This confidentiality obligation applies to all forms of communication, including but not limited to social media platforms such as:

• YouTube
• Facebook
• LinkedIn
• Job boards of any type
• Twitter/X
• Any other current or future social media or online platforms

7. Information Security and Data Protection

Suppliers and subcontractors are expected to maintain appropriate physical, technical, and organizational security safeguards.

At a minimum:

• Facilities must be secured to prevent unauthorized access.
• Any New Era or customer data accessed, processed, or stored must be protected and encrypted on PCs, servers, laptops, and other devices used in the performance of services.
• Devices used to access New Era or customer networks must:
• Be password‑ or PIN‑protected,
• Automatically lock after a period of inactivity,
• Use secure data transmission methods, such as approved wireless networks or VPN solutions.
• Confidential information must never be left unattended and must be securely stored when not in use.
• Computer screens must be locked whenever left unattended.
• Paper records containing confidential information should be securely stored, digitized where appropriate, and shredded when no longer required.

Where permitted by a specific New Era customer, supplier‑owned equipment connecting to customer networks or systems may be subject to audit as part of customer security requirements. Suppliers shall have no expectation of privacy in personal hardware used for business purposes in such circumstances.

Suppliers are prohibited from accessing New Era or customer systems using “guest” or shared login credentials.

8. Performance Monitoring and Audits

New Era Technology may utilize Customer Satisfaction Surveys (CSS) and other mechanisms to assess service performance, including the performance of suppliers and subcontractors.

Where service deficiencies are identified:

• Suppliers may be required to agree to and implement a service improvement plan.
• Failure to implement required corrective actions may result in removal from New Era’s approved partner or supplier list.

9. Compliance with New Era Policies

Suppliers and subcontractors are expected to familiarize themselves with and comply with relevant New Era policies, which are available at: https://www.neweratech.com.

10. Reporting Concerns

Any concerns, suspected violations, or non‑compliance with this Code should be reported promptly to: privacy@neweratech.com.

Reports may be made in good faith and without fear of retaliation.

11. Consequences of Non‑Compliance

If New Era determines that a supplier or subcontractor has violated this Code, New Era reserves the right to:

• Take appropriate remedial action, including termination of the business relationship.
• Pursue legal remedies where warranted, including claims for damages.

Suppliers may also be required to complete periodic (including annual) questionnaires relating to policies, certifications, and compliance practices.

12. Conflict Resolution

In the event of any conflict between:

1. Applicable laws and regulatory requirements,
2. Contractual agreements with New Era, and
3. Supplier Code of Conduct,

the order of precedence shall be as listed above, with applicable law taking highest priority.

13. Updates

New Era Technology may update this Supplier Code of Conduct from time to time. The most current and authoritative version will be published on the New Era Technology website.

14. Acknowledgement

By engaging in business with New Era Technology, suppliers and subcontractors confirm that they have received, understood, and agree to comply with this Supplier Code of Conduct, in addition to all applicable contractual obligations.