Document Effective Date April 2022

Argo AI Supplier Code of Conduct

At Argo AI (“Argo”), we are on a mission to make the world’s streets and roadways safe, accessible, and useful for all. Our purpose is to reimagine the human journey.

Argo was founded on the principles underlying safety-critical systems. Everything we do – from development and testing to road operations and strategic planning – revolves around the safety of our employees and the communities in which we operate.

​​To build self-driving technology you can trust, we are determined to uphold the highest standards of excellence everywhere we do business. We are committed to finding solutions and building a responsible business environment based on honesty and respect – that is the way we treat each other and the way we treat our business partners.

At Argo, we are determined to adhere to all applicable international standards on responsible business conduct. We are committed to fair competition and zero tolerance for corruption.

We acknowledge that our business partners play an important role in our adherence to and upholding of these standards. Only through successful collaboration with our partners in the supply chain can we build self-driving technology that the public can trust.

This Supplier Code of Conduct (“Code”) outlines Argo’s commitments to these standards and our expectations for our suppliers. This Code applies to all of the suppliers, contractors, consultants, agents, and business partners with whom Argo does business (collectively, “Suppliers”). We expect our Suppliers to communicate and apply the Code and relevant policies to employees, agents, and other persons involved in the provision of goods and services to Argo, including those operating throughout our Suppliers’ supply chain. Argo reserves the right to ask any Supplier to complete a risk assessment, the results of which may result in remediation activities. While the Code outlines minimum standards in some areas, we encourage Suppliers to strive to undertake additional relevant actions.

In the event a Supplier knows or suspects a violation of an applicable law, regulation, standard, or this Code relating to the Supplier’s relationship or business interests with Argo, such Supplier must report the issue directly to their Argo business contact, or, if the Supplier wishes to remain anonymous, either online at https://argo.ethicspoint.com or via telephone at 844-418-4427 (US) or
0800 1814348 (Germany).

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Social Responsibility

Compliance with Applicable Laws

• Argo conducts its business in full compliance with all applicable laws and regulations. Suppliers shall conduct business activities in full compliance with all applicable laws, rules, regulations, and directives, including those that apply as a result of providing goods and services to Argo.

Child Labor, Forced Labor, Human Trafficking

• Child Labor: Argo does not tolerate any form of child labor in its supply chain. Suppliers shall comply with the minimum working age in any region in which they operate, while prohibiting employment of anyone below the age of 15, even if permitted under local law, in accordance with the ILO Convention.
• Forced Labor and Human Trafficking: Argo does not tolerate any form of slavery, human trafficking, servitude, bonded, indentured, prison, or forced labor, as defined by the ILO Convention, in Argo’s supply chain. All labor within Argo’s supply chain shall be voluntary and allow freedom of movement. Suppliers must, upon request, be able to provide (a) assurances regarding their non-use of forced labor, and (b) information about what steps, if any, they are taking to combat modern slavery in their respective businesses and supply chains.

Working Environment

• Humane Treatment, Anti-Harassment, Non-Discrimination: Argo does not tolerate inhumane treatment or unlawful discrimination, including harassment, in its supply chain. Suppliers shall not subject workers to verbal, physical, sexual, or psychological harassment or abuse based on religion, race, color, ethnic group identification, age, national origin, ancestry, physical or mental disability, medical condition, genetic information, marital status, military and veteran status, sex, gender, gender identity, gender expression, sexual orientation, height, weight, or any other characteristic protected by applicable law. Additionally, Argo explicitly affirms that we are an anti-racist company. We are committed to recognizing, addressing, and opposing all forms of racism and ethnic oppression within our organization, our supply chain, and the broader community. As such, we expect Suppliers to make similar anti-racism commitments within their own company culture and supply chains.
• Diversity, Inclusion, and Equal Opportunity: Argo is committed to diversity, inclusion, and equal opportunity in the workplace and our supply chain. These shall be fundamental principles of Suppliers’ corporate policies and demonstrated through an inclusive and diverse workforce and supply base.
• Healthy and Safe Working Environment: Argo does not tolerate unhealthy or dangerous working environments in its supply chain and requires working environments to meet local and national safety, occupational health, and fire safety laws and requirements. Suppliers shall provide a clean and safe working environment that meets or exceeds all applicable laws and regulations. Suppliers shall provide an environment where occupational injuries and illnesses are prevented and, when they occur, are accurately reported and addressed without fear of reprisal. Suppliers shall maintain a health and safety management system to limit worker exposure to hazard, promote continuous improvement of working conditions and occupational health and safety, and ensure that workers have access to, and knowledge of, safety procedures in addition to appropriate signage posted throughout the workspace.
• Wages, Working Hours: Suppliers shall comply with all applicable wage and hour laws, including those relating to minimum wages, overtime hours, and other elements of compensation. Suppliers shall not require employees to work more than the maximum number of hours as may be set by local law.
• Freedom of Association and Collective Bargaining: Suppliers shall respect employees’ rights to freedom of association and collective bargaining.
• Responsible and Ethical Recruitment Practices: Argo expects Suppliers to be honest, transparent, fair, and ethical towards all applicants. Suppliers shall not mislead potential employees regarding the nature of the work or ask potential employees to pay recruitment fees or make inquiries prohibited by law. Suppliers shall not confiscate, destroy, conceal, and/or deny access to potential employees’ government-issued identity documents.

Responsible Sourcing and Trade

• Conflict Minerals: Suppliers shall ensure that products supplied to Argo, at any point in the supply chain, do not contain metals derived from minerals or their derivatives originating from conflict regions that directly or indirectly finance or benefit armed groups and cause or foster human rights abuses. Conflict minerals include, but are not limited to, tin, titanium, tungsten, gold, cobalt, and mica. Suppliers shall conduct due diligence to understand the source and origin of raw materials utilized in any Argo products, implement measures aimed at identifying risks, and take appropriate measures to minimize such risks. This includes continuous efforts to enhance transparency along the upstream supply chain extending back to raw material extraction. Suppliers shall provide, upon request, transparent reporting to Argo, including information regarding smelters or refineries used by Suppliers or sub-suppliers. More information and guidance can be found at the Organization for Co-Operation and Economic Development (OECD).
• Counterfeit Parts: Suppliers shall develop, implement, and maintain methods and processes appropriate to their products and services to minimize the risk of introducing counterfeit parts and materials into deliverable products. Effective processes should be in place to detect counterfeit parts and materials and mark parts as obsolete as appropriate.
• Fair Competition: Suppliers shall conduct business in line with fair competition and in accordance with all applicable antitrust laws (which may locally be referred to as “competition law” or other names). Suppliers shall deal honestly and fairly with customers, other Suppliers, partners, service providers, and competitors. Suppliers shall never take unfair advantage of others through manipulation, concealment, abuse of privileged information, misrepresentation of facts, or other unfair dealings.
• Trade Compliance: Argo is committed to conducting business in compliance with all applicable export and import laws and regulations. Suppliers shall strictly comply with all applicable laws, regulations, rules, and directives applicable to the exporting and importing of items, information, and/or software, as well as those that restrict dealings (including without limitation any business affiliation, relation and transaction) with persons, entities, jurisdictions, territories (collectively called “Restricted Parties”), and certain activities. These laws include, but are not limited to, the International Traffic in Arms Regulation (ITAR), the Export Administration Regulations (EAR), sanctions managed by the Office of Foreign Assets Control (OFAC), U.S Customs regulations and other similar laws in the European Union and the countries in which Argo does business. In addition to prohibited dealings with Restricted Parties, Suppliers must immediately disclose any ownership of or acquisition by any Restricted Parties or any other direct or indirect involvements with any Restricted Parties. Suppliers must regularly screen parties within their supply chain to ensure compliance.

Land Acquisitions

• Suppliers shall ensure that all land acquisitions, including leasing and utilization, meet International Finance Corporation (IFC) Performance Standards, including Free, Prior, and Informed Consent.

Privacy, Cyber Security, Intellectual Property

• Suppliers shall take all reasonable and necessary precautions to safeguard the data and information of Argo and data and information of any other parties to which Suppliers have access in relation to developing or maintaining a relationship with Argo. Suppliers shall not disclose this data or information to anyone, inside or outside of Argo, unless properly authorized and the recipient is subject to a written confidentiality agreement or is otherwise bound to an appropriate statutory duty of confidentiality. Suppliers shall comply with applicable data privacy laws, regulations, rules, and directives. Suppliers shall implement technical and organizational measures to protect against accidental or unauthorized access, use, disclosure, modification, or destruction of data or information received in relation to an actual or potential relationship with Argo.

Environment

Climate Change

• Argo believes in climate change and the science and data related thereto. Argo is committed to protecting the planet through understanding how to mitigate climate risks and promoting environmentally sound technology. Argo is striving to develop self-driving technology in an environmentally sound manner by implementing its technology on electrified vehicles and helping to enable a reduction in emissions, as self-driving technology helps reduce personal vehicles and associated traffic congestion on the road. Argo expects Suppliers to also be committed to protecting the planet, especially as it relates to any products or services supplied to Argo. Suppliers shall act in an environmentally responsible manner, comply with all applicable environmental laws and regulations regarding hazardous materials, air emissions, waste and wastewater discharge, including the manufacture, transportation, storage, disposal, and release to the environment of such materials.

Sustainability

• Argo is committed to conducting business safely while working to reduce its emissions, increase reliance on renewable energy, and improve its overall environmental impact. Argo conducts business with energy efficiency in mind, and we expect the same from Suppliers. Suppliers who provide products to Argo shall identify targets and implement action plans for reducing environmental impacts in the areas of water usage, wastewater, energy, greenhouse gas emissions, waste and packaging, and establish transparent reporting mechanisms.

Honesty

Business Integrity and Ethics

• Business Ethics: Argo is committed to the highest standard of ethical conduct. Suppliers shall, at all times, uphold the highest level of integrity in all business dealings.
• Anti-Corruption and Anti-Bribery: Argo does not tolerate corruption, misconduct, fraud, bribery, extortion, or illegal conditions in our supply chain and business relationships. Suppliers shall not tolerate, engage in, or endorse any form of bribery or corruption, either directly or indirectly. Caution should be exercised with government officials, ensuring that actions are ethical, sound, and will not raise any bribery or corruption concerns, including the appearance of impropriety.
• Money Laundering & Terrorism Financing: Argo is committed to compliance with all applicable legal requirements relating to the prevention and detection of money laundering and financing terrorism. Accordingly, Argo expects our Suppliers to not participate in any money laundering activities and comply with all applicable laws on AML/Combatting Financing of Terrorism (CFT).
• Accurate and Honest Record Keeping: Suppliers shall maintain accurate, honest, complete, and timely records in full compliance with applicable legal and regulatory requirements and accepted accounting practices.
• Ethics Hotline: Suppliers shall provide an Ethics Hotline or means for employees to anonymously report any concerns or suspected violation of any applicable laws, regulations, or standards.

Governance

• Management Systems: It is expected that Suppliers develop, implement, use, and maintain applicable management systems and controls related to this Code. Documentation necessary to demonstrate conformance with the principles outlined in this Code should also be maintained through applicable policies, procedures, and protocols.
• Risk Management: Suppliers should actively manage risks that could impact the ability to do business with Argo and implement mechanisms to identify, evaluate, and minimize risks to ensure business continuity.

Innovation

Quality, Continuous Improvement

• At Argo, we hold ourselves to incredibly high quality standards and, in turn, expect Suppliers to provide the highest quality products and services. Argo also expects Suppliers to demonstrate their commitment to continuous improvement by providing feedback and input into opportunities for the products or services that they provide to Argo to ensure the highest quality is achieved.

Embracing Change and Technology

• Argo recognizes that technology and business priorities change rapidly. We expect our Suppliers to be responsive and adaptive to these changes as applicable.