NineAxis Facilities Limited (“NineAxis”, “we”, “our”, or “us”) is committed to building strong, ethical, and sustainable relationships with suppliers, contractors, subcontractors, consultants, and business partners who share our values.

This Supplier Code of Conduct sets out the minimum standards expected from every organisation providing goods or services to NineAxis. Compliance with this Code helps ensure that our operations remain safe, lawful, responsible, and aligned with industry best practices across the United Kingdom.

This Code applies to all suppliers regardless of contract value, duration, or service category.

Our Expectations

We expect every supplier to operate with integrity, professionalism, transparency, and accountability while complying with all applicable laws, regulations, and contractual obligations. Suppliers are responsible for ensuring these standards are upheld throughout their own supply chains where relevant.

Legal Compliance

Suppliers must comply with all applicable UK legislation and regulations relevant to their business operations, including but not limited to:

* Employment legislation

* Health and safety regulations

* Environmental legislation

* Equality legislation

* Data protection laws

* Tax obligations

* Anti-corruption legislation

* Immigration and right-to-work requirements

Any breach of applicable law may result in corrective action or termination of the business relationship.

Business Ethics

Suppliers must conduct business honestly, fairly, and ethically.

They must:

* Avoid bribery and corruption in any form.

* Maintain accurate business records.

* Prevent fraud and financial misconduct.

* Avoid conflicts of interest.

* Compete fairly and lawfully.

* Never offer gifts or hospitality intended to improperly influence business decisions.

Human Rights

NineAxis is committed to respecting internationally recognised human rights.

Suppliers are expected to:

* Respect the dignity of every worker.

* Provide fair and lawful working conditions.

* Prevent discrimination.

* Prevent harassment and abuse.

* Respect freedom of association where legally applicable.

* Promote equality and inclusion.

Modern Slavery

Suppliers must maintain a zero-tolerance approach towards:

* Modern slavery

* Human trafficking

* Forced labour

* Debt bondage

* Child labour

* Exploitative employment practices

Suppliers must immediately report any suspected incidents identified within their own organisation or supply chain.

Employment Practices

Suppliers shall:

* Pay workers fairly and lawfully.

* Provide written employment terms where required.

* Comply with working time regulations.

* Respect statutory leave entitlements.

* Prevent unlawful deductions from wages.

* Verify employees’ legal right to work.

Health & Safety

Suppliers are expected to maintain safe and healthy working environments.

They should:

* Operate effective health and safety management systems.

* Conduct appropriate risk assessments.

* Provide suitable training.

* Supply appropriate Personal Protective Equipment (PPE).

* Report serious incidents where they may affect NineAxis operations.

* Continuously improve workplace safety.

Environmental Responsibility

Suppliers should actively minimise their environmental impact by:

* Reducing waste.

* Recycling wherever possible.

* Conserving energy.

* Managing water responsibly.

* Preventing pollution.

* Using environmentally responsible materials where practical.

* Supporting sustainable business practices.

Quality Standards

Suppliers are expected to deliver products and services that consistently meet agreed specifications and quality standards.

They should:

* Maintain appropriate quality assurance procedures.

* Deliver work professionally.

* Meet agreed service levels.

* Promptly address defects.

* Continually improve performance.

Data Protection & Confidentiality

Suppliers may have access to confidential information during the course of providing services.

They must:

* Protect confidential information.

* Comply with applicable data protection legislation, including the UK GDPR and Data Protection Act 2018.

* Prevent unauthorised disclosure.

* Report any data breaches promptly.

* Use information only for authorised purposes.

Information Security

Suppliers are expected to maintain appropriate cybersecurity measures to protect systems, devices, and data.

This includes:

* Secure passwords and access controls.

* Anti-malware protection.

* Secure storage of sensitive information.

* Timely software updates.

* Appropriate staff awareness training.

Equality, Diversity & Inclusion

Suppliers should promote workplaces free from discrimination.

Employment decisions should be based on merit and capability without unlawful discrimination based on:

* Age

* Disability

* Gender

* Gender reassignment

* Marriage or civil partnership

* Pregnancy or maternity

* Race

* Religion or belief

* Sex

* Sexual orientation

Supply Chain Responsibility

Suppliers are responsible for ensuring that subcontractors and key supply chain partners engaged in delivering services to NineAxis operate to standards consistent with this Code.

Where requested, suppliers should provide reasonable evidence of compliance.

Reporting Concerns

Suppliers are encouraged to report any concerns regarding unethical conduct, legal breaches, fraud, corruption, modern slavery, health and safety risks, or any behaviour inconsistent with this Code. Reports will be treated appropriately and investigated where necessary.

Monitoring & Compliance

NineAxis reserves the right to:

* Request evidence of compliance.

* Review supplier policies and procedures.

* Conduct supplier assessments where appropriate.

* Require corrective action plans.

* Suspend or terminate supplier relationships where serious or repeated non-compliance is identified.

Continuous Improvement

We value long-term partnerships with suppliers who demonstrate a commitment to continuous improvement, innovation, sustainability, operational excellence, and responsible business practices. We encourage suppliers to regularly review their policies, strengthen governance, and adopt recognised industry best practices.

Contact

Questions regarding this Supplier Code of Conduct or supplier compliance expectations may be directed to:

NineAxis Facilities Limited

66 Paul Street

London EC2A 4NA

Email: hello@nineaxis.co.uk

Telephone: +44 (0)7881 190082

Review

This Supplier Code of Conduct will be reviewed periodically to ensure continued alignment with applicable legislation, industry standards, and the operational requirements of NineAxis Facilities Limited.

Effective Date: 7 July 2026

Document Owner: NineAxis Facilities Limited

Version: 1.0