Legal

Supplier Code of Conduct

Supplier Code of Conduct

Version 1.0

Last updated January 1, 2026

Index

1. Introduction and purpose

1. Introduction and purpose

This Supplier Code of Conduct (“Code”) sets forth the minimum standards that fileAI Pte. Ltd. (“fileAI,” “we,” “us,” or “our”) expects from all suppliers, vendors, contractors, consultants, and other business partners (collectively, “Suppliers”) who provide goods or services to fileAI.

fileAI is committed to conducting business ethically and with integrity. We expect our Suppliers to share this commitment and to uphold the highest standards of business conduct, including respect for human rights, fair labor practices, environmental responsibility, and ethical business practices.

This Code reflects our commitment to preventing modern slavery, forced labor, human trafficking, and other forms of exploitation in our business operations and supply chains. While fileAI operates as a B2B software-as-a-service (SaaS) company with minimal physical supply chains, we recognize our responsibility to ensure that our business relationships align with our values and comply with applicable laws, including the Australian Modern Slavery Act 2018, UK Modern Slavery Act 2015, and similar legislation globally.

2. Applicability and contractual effect

2. Applicability and contractual effect

2.1 Incorporation into Contracts

2.1 Incorporation into Contracts

This Code may be incorporated into supplier contracts, purchase orders, statements of work, and other agreements by reference (e.g., by including a URL link to this Code or stating “Supplier agrees to comply with fileAI’s Supplier Code of Conduct”). When incorporated by reference, compliance with this Code becomes a binding contractual obligation.

Suppliers acknowledge and agree that:

Acceptance of a purchase order, contract, statement of work, or other agreement that references this Code constitutes acceptance of and agreement to comply with this Code

This Code forms part of the binding agreement between the Supplier and fileAI

Material violations of this Code may constitute a material breach of contract, entitling fileAI to remedies including termination

fileAI may update this Code from time to time. Unless otherwise specified in the contract, the version of the Code in effect at the time of contract execution or purchase order acceptance applies to that specific engagement

Suppliers are responsible for accessing, reviewing, and understanding this Code prior to accepting any contract or purchase order that references it

If this Code conflicts with specific terms in a written contract between fileAI and Supplier, the written contract terms shall prevail to the extent of the conflict

2.2 Scope of Application

2.2 Scope of Application

This Code applies to all Suppliers providing goods or services to fileAI, including but not limited to:

Cloud infrastructure and hosting providers

Software and technology vendors

Professional services providers (consultants, contractors, advisors)

Recruitment agencies and staffing firms

Office equipment and supply providers

Any other vendors or service providers engaged by fileAI

2.3 Supply Chain Extension

2.3 Supply Chain Extension

Suppliers are expected to ensure that this Code, or substantially equivalent standards, are communicated to and followed by their own suppliers, subcontractors, and business partners to the extent they are involved in providing goods or services to fileAI.

3. Legal Compliance

3. Legal Compliance

Suppliers must comply with all applicable laws, regulations, and industry standards in the jurisdictions where they operate and where they provide goods or services to fileAI. This includes, but is not limited to, laws relating to:

Labor and employment

Human rights and modern slavery

Health and safety

Environmental protection

Anti-corruption and anti-bribery

Data protection and privacy

Trade compliance and sanctions

Intellectual property

Competition and antitrust

Where this Code sets higher standards than applicable law, Suppliers are expected to meet the higher standard. Where applicable law sets higher standards than this Code, Suppliers must comply with applicable law.

4. Prohibition of modern slavery, forced labor, and human trafficking

4. Prohibition of modern slavery, forced labor, and human trafficking

fileAI has zero tolerance for modern slavery, forced labor, human trafficking, servitude, debt bondage, and all forms of exploitation in our business operations and supply chains.

4.1 Prohibited Practices

4.1 Prohibited Practices

Suppliers must NOT engage in or support:

Forced labor: Any work or service extracted from a person under threat of penalty, including physical punishment, restriction of movement, withholding of wages or identity documents, or deportation threats

Human trafficking: Recruiting, transporting, transferring, harboring, or receiving persons by means of threat, force, coercion, abduction, fraud, deception, or abuse of power for exploitation

Debt bondage: Requiring workers to work to pay off debts or loans, where the terms are unreasonable or the worker has no real opportunity to leave

Servitude: Obligation to provide services imposed by use of coercion

Child labor: Employment of children under the age of 15 (or 14 where local law allows), or under the age for completing compulsory education, or under the minimum age for employment in the country, whichever is greatest

Hazardous child labor: Employment of anyone under age 18 in work that is likely to harm their health, safety, or morals

Slavery or practices similar to slavery

Any other form of exploitation or abuse of workers

4.2 Required Practices

4.2 Required Practices

Suppliers must ensure that:

All work is voluntary - workers have the right to leave employment with reasonable notice and without penalty

Workers are not required to pay recruitment fees or costs to obtain employment

Workers’ identity documents (passports, work permits, identity cards) are not retained by the employer except for brief periods for administrative purposes with the worker’s knowledge and consent

Workers are provided with employment contracts or agreements in a language they understand, clearly stating terms of employment including wages, working hours, and conditions

Wages and benefits meet or exceed legal minimums and industry standards

Working hours comply with applicable laws and do not exceed legal limits

Workers have freedom of movement and are not confined to work premises or company-controlled housing

Workers have freedom of association and the right to collective bargaining where legally permitted

5. Fair Employment Practices

5. Fair Employment Practices

5.1 Non-Discrimination

5.1 Non-Discrimination

Suppliers must provide equal employment opportunities and treat workers with dignity and respect. Discrimination based on race, color, religion, gender, gender identity, sexual orientation, age, disability, national origin, ancestry, marital status, pregnancy, or any other characteristic protected by law is prohibited.

5.2 Fair Compensation

5.2 Fair Compensation

Suppliers must:

Maximum working hours (typically not to exceed 48 hours per week plus overtime as permitted by law)

Rest days and breaks

Overtime compensation

Annual leave, sick leave, and other legally required leave

Maternity/paternity leave as required by law

Workers must not be compelled to work excessive overtime. Overtime must be voluntary except where permitted by law and collective bargaining agreements.

6. Health, safety, and working conditions

6. Health, safety, and working conditions

Suppliers must provide a safe, healthy, and secure working environment for all workers. This includes:

Compliance with all applicable health and safety laws and regulations

Implementation of appropriate health and safety management systems

Provision of necessary personal protective equipment

Safe handling, storage, and disposal of hazardous materials

Emergency preparedness and response procedures

Access to clean drinking water, sanitary facilities, and (where applicable) safe housing

Regular health and safety training for workers

Mechanisms for workers to report safety concerns without retaliation

Investigation and remediation of safety incidents

7. Ethical Recruitment and Employment Practices

7. Ethical Recruitment and Employment Practices

7.1 Prohibition of Recruitment Fees

7.1 Prohibition of Recruitment Fees

Suppliers must ensure that workers do not pay recruitment fees, costs, or deposits to obtain employment. All recruitment costs must be borne by the employer, not the worker. This prohibition applies whether workers are hired directly or through recruitment agencies.

7.2 Recruitment Agencies

7.2 Recruitment Agencies

If Suppliers use recruitment agencies or labor brokers, they must:

Conduct due diligence to ensure agencies comply with this Code and applicable laws

Use only licensed and reputable agencies

Ensure agencies do not charge fees to workers

Ensure agencies provide workers with clear employment terms in a language they understand

Monitor agency practices on an ongoing basis

Hold agencies accountable for violations of this Code or applicable law

7.3 Employment Contracts

7.3 Employment Contracts

Suppliers must provide all workers with:

Written employment contracts or agreements

Contracts in a language the worker understands

Clear terms regarding wages, working hours, benefits, leave, termination, and other material conditions

Reasonable time to review and understand the contract before signing

Hold agencies accountable for violations of this Code or applicable law

8. Environmental Responsibility

8. Environmental Responsibility

Suppliers are expected to operate in an environmentally responsible manner and to continuously seek to improve environmental performance. This includes:

Compliance with all applicable environmental laws and regulations

Appropriate handling, storage, and disposal of hazardous materials and waste

Efforts to reduce energy consumption, greenhouse gas emissions, and waste generation

Implementation of environmental management systems where appropriate to the nature and scale of operations

Transparency regarding environmental practices and performance

9. Business Ethics and Anti-Corruption

9. Business Ethics and Anti-Corruption

9.1 Anti-Corruption and Anti-Bribery

9.1 Anti-Corruption and Anti-Bribery

Suppliers must comply with all applicable anti-corruption and anti-bribery laws, including the U.S. Foreign Corrupt Practices Act, UK Bribery Act, and local laws. Suppliers must not:

Offer, promise, give, or authorize bribes, kickbacks, or other improper payments to any person (including government officials)

Accept bribes, kickbacks, or improper payments from any person

Engage in any form of corruption, extortion, or embezzlement

Provide gifts, entertainment, or hospitality that could improperly influence business decisions

Make facilitation payments (small payments to expedite routine government actions) unless legally permitted and properly documented

9.2 Conflicts of Interest

9.2 Conflicts of Interest

Suppliers must:

Avoid conflicts of interest in their dealings with fileAI

Disclose any actual or potential conflicts of interest to fileAI

Not employ fileAI employees or their immediate family members without fileAI’s prior written consent

Not offer employment or business opportunities to fileAI employees for the purpose of influencing business decisions

9.3 Confidentiality and Data Protection

9.3 Confidentiality and Data Protection

Suppliers must:

Protect fileAI’s confidential information and intellectual property

Comply with all applicable data protection and privacy laws (GDPR, CCPA, PDPA, etc.)

Implement appropriate security measures to protect personal data and confidential information

Not use fileAI’s confidential information for any purpose other than performing services for fileAI

Return or destroy confidential information upon request or termination of the business relationship

9.4 Fair Competition

9.4 Fair Competition

Suppliers must:

Comply with all applicable competition and antitrust laws

Compete fairly and ethically

Not engage in price fixing, bid rigging, market allocation, or other anticompetitive conduct

Obtain competitive information through legal and ethical means only

10. Supply Chain Responsibility

10. Supply Chain Responsibility

Suppliers are expected to:

Communicate the requirements of this Code (or substantially equivalent standards) to their own suppliers, subcontractors, and business partners

Conduct appropriate due diligence on their own supply chains to identify and address modern slavery and other ethical risks

Take corrective action if violations are identified in their supply chains

Be transparent with fileAI about their supply chain, including subcontractors involved in providing services to fileAI

Obtain fileAI’s prior written consent before subcontracting work to third parties where required by contract

11. Reporting Concerns and Remediation

11. Reporting Concerns and Remediation

11.1 Reporting Violations

11.1 Reporting Violations

Suppliers must establish mechanisms for workers and others to report concerns about violations of this Code, applicable law, or ethical standards. Such mechanisms must:

Be accessible to all workers

Allow for confidential or anonymous reporting where permitted by law

Protect reporters from retaliation

Ensure prompt investigation of reports

Provide appropriate remediation when violations are confirmed

Suppliers or their workers may also report concerns to fileAI at: legal@fileai.com

11.2 Non-Retaliation

11.2 Non-Retaliation

Suppliers must not retaliate against any person who:

Reports a concern about potential violations in good faith

Participates in an investigation

Refuses to engage in conduct that violates this Code or applicable law

Exercises their legal rights (e.g., freedom of association)

11.3 Remediation

11.3 Remediation

If violations of this Code are identified, Suppliers must:

Cooperate fully with fileAI’s investigation

Promptly implement corrective action plans

Provide remediation to affected workers where appropriate

Take steps to prevent recurrence

Provide fileAI with evidence of corrective actions taken

12. Monitoring, Verification, and Compliance

12. Monitoring, Verification, and Compliance

12.1 Self-Assessment

12.1 Self-Assessment

Suppliers may be required to complete self-assessment questionnaires regarding their compliance with this Code, applicable laws, and modern slavery due diligence.

12.2 Documentation

12.2 Documentation

Suppliers must maintain appropriate documentation to demonstrate compliance with this Code and applicable laws. fileAI may request such documentation during vendor due diligence or in response to customer inquiries.

12.3 Verification and Audits

12.3 Verification and Audits

fileAI reserves the right to verify Supplier compliance with this Code through:

Review of Supplier documentation, policies, and procedures

Questionnaires and self-assessments

Site visits or inspections (with reasonable notice)

Third-party audits

Worker interviews

Review of certifications or compliance reports

Suppliers must cooperate with reasonable verification activities. Verification costs are typically borne by fileAI unless otherwise agreed.

12.4 Consequences of Non-Compliance

12.4 Consequences of Non-Compliance

Failure to comply with this Code may result in:

Requirement to implement corrective action plans

Increased monitoring or auditing

Suspension of new business or purchase orders

Termination of the business relationship

Legal action where appropriate

fileAI will work collaboratively with Suppliers to address non-compliance where possible. However, serious violations (particularly those involving modern slavery, forced labor, child labor, or other human rights abuses) may result in immediate termination of the relationship.

13. Implementation and Continuous Improvement

13. Implementation and Continuous Improvement

fileAI expects Suppliers to:

Acknowledge receipt and understanding of this Code

Implement policies, procedures, and training necessary to ensure compliance

Assign responsibility for compliance to appropriate personnel

Monitor their own compliance on an ongoing basis

Continuously seek to improve their practices beyond minimum compliance

Engage constructively with fileAI on responsible business practices

Be transparent about challenges and work collaboratively to address them

14. Amendments and Updates

14. Amendments and Updates

fileAI may update this Code from time to time to reflect evolving best practices, regulatory requirements, or stakeholder expectations. Material changes will be communicated to Suppliers with reasonable notice.

For existing contracts that incorporate this Code by reference:

fileAI will notify Suppliers of material changes to this Code

Unless otherwise specified in the contract, the version of the Code in effect at the time of contract execution continues to apply to that specific engagement

fileAI and Supplier may mutually agree to adopt updated versions of the Code for existing contracts

For new purchase orders or renewals, the then-current version of the Code applies unless otherwise specified

15. Contact Information

15. Contact Information

Questions about this Code or reports of concerns may be directed to:

Contact

General Counsel

Company

fileAI Pte. Ltd.

By accepting a purchase order, contract, statement of work, or other agreement from fileAI that references this Supplier Code of Conduct (whether by URL link or otherwise), Supplier acknowledges and agrees that:

1.

Supplier has accessed, read, and understood this Code

2.

Supplier agrees to comply with all requirements of this Code

3.

This Code forms part of the binding agreement between Supplier and fileAI

4.

Material violations of this Code may constitute a material breach of contract

No separate signature or acknowledgment form is required unless specifically requested by fileAI. Acceptance of work from fileAI that references this Code constitutes acceptance of this Code.

Optional Formal Acknowledgment

Optional Formal Acknowledgment

For suppliers who wish to provide formal written acknowledgment, the following form may be used:

Supplier Name:

Authorized Representative:

Title:

Signature:

Date:

Company Stamp/Seal (if applicable):

Building the foundation for agentic AI

Building the foundation for agentic AI