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Ergo Technology Group
Responsible Sourcing Policy

Background, Objectives, and Scope of the Policy

At Ergo, we hold ourselves to the highest standards of business conduct, environmental stewardship, and social protection. Despite these efforts, we acknowledge the fact that we operate in a sector that is linked to negative environmental and social impacts throughout our supply chain. Environmental impacts related to climate change, resource use, and waste are frequently related to the activities in our supply chain, and negative social impacts related to conflict, inadequate working conditions, child and forced labour, health and safety are also frequently reported in the sector. Although we do not have visibility over our entire supply chain, we recognise our responsibility in taking action to identify, address, and mitigate against these impacts, through adopting principles of responsible sourcing in our procurement practices.

In accordance with our broader group sustainability strategy, and with respect to global frameworks and standards such as the United Nations Global Compact principles, this Responsible Sourcing Policy (herein referred to as “the policy”) outlines Ergo’s commitments to responsible sourcing. Our Supplier Code of Conduct builds on the commitments outlined in this policy through setting concrete sustainability requirements for our supply chain partners and helps us enforce our responsible sourcing practices.

As per Ergo’s audited accounts from 2024, over 95% of supplier spend was with supply chain partners (i.e. the purchase of goods or services that are to be resold to our customers).  No supplier of goods or services that are for internal Ergo use represents more than 1% of overall purchase.  Given that the areas of primary concern that are outlined above pertain to suppliers in our supply chain only, this policy will focus on Ergo’s twenty largest suppliers (measured by euro value). These Strategic Suppliers account for over 80% of all supply chain purchases.

Ergo’s Commitments to Responsible Sourcing

Our overarching goal with regards to responsible sourcing is to ensure that products and services are obtained ethically and sustainably, prioritising supplier transparency, environmental stewardship, and respect for human rights within our supply chain.

To support the implementation of these responsible sourcing objectives, Ergo commits to ensuring:

  • Compliance: We will ensure that we comply with all applicable regulatory requirements related to the environment, governance, and labour standards, in all sectors and geographies in which we operate.
  • Due Diligence: We will maintain a preferred list of Strategic Suppliers and ensure that we perform due diligence checks regarding ESG performance on these supply chain partners.  All new Strategic Suppliers will be assessed prior to entering a contractual relationship. If any risks or negative impacts are flagged during these checks, we will investigate the issue and reconsider proceeding with the partnership or work with our potential supplier to outline an appropriate corrective action plan.
  • Impact Identification and Action: We have undertaken an exercise to identify social and environmental impacts and risks in our supply chain and have also undergone a Double Materiality Assessment to identify sustainability topics that are material to our business. We will continue to identify and consider these impacts in our procurement decisions, especially when sourcing products containing high impact commodities. As a company that procures computer hardware, of which the components are frequently linked to conflict minerals, we will ensure to align with all regulatory requirements on this issue and closely monitor suppliers of these products for ESG risks.
  • Environmental Stewardship: The manufacturing of computer hardware, and its related value chain activities, contributes to greenhouse gas emissions, the consumption of scarce resources, and waste generation. In light of these negative environmental impacts, Ergo commits to working with its suppliers to ensure awareness of these environmental issues, and to set targets and expectations for our suppliers in this regard. We commit to measuring our Scope 3 carbon emissions, identify emissions hotspots, and collaborate with our suppliers to reduce the emissions in these hotspots.
  • Human Rights Defence: Modern slavery, including forced and child labour, is strictly prohibited in our operations and value chain. We commit to screen suppliers for human rights violations risks and undertake supplier audits if there are risks of modern slavery or human rights violations in their operations. In the case of human rights incidents, corrective action will be undertaken, and contract termination will be considered.
  • Responsible Sourcing: Given that the vast majority of any environmental and social negative impacts occur in our supply chain, we commit to injecting sustainability considerations into all stages of our supplier journey, from pre-qualification, to onboarding and contracting to performance management.

Ergo’s Supplier Expectations for Responsible Sourcing

Ergo expects its suppliers to adhere to the following expectations that we have set as part of our responsible sourcing strategy:

  • Compliance: Comply with all applicable environmental and social legal requirements, in all territories in which they conduct business activities.
  • Sustainability: Embed sustainability in the organisation’s various functions and ensure respect for human rights and the environment is embedded in supporting policies, procedures and governance processes.
  • Carbon Measurement and Data Provision: Upon request, provide Ergo with data and information regarding environmental, social, and governance policies, actions, and targets.  We expect our suppliers to measure their carbon footprint, and to provide us with this data.
  • Modern Slavery Policy: To support our commitment to the prohibition of modern slavery, we expect all suppliers to have a Modern Slavery Policy in place, and to work with their own suppliers to grow awareness on modern slavery, and to take action to prevent any incidences of modern slavery in your own supply chain.
  • Responsible Sourcing Action: To improve the sustainability of our supply chain, we need all suppliers to work with their own suppliers to cascade responsible sourcing principles down throughout their supply chain. As a minimum in this regard, we expect our suppliers to have their own Supplier Code of Conduct in place, outlining the minimum sustainability requirements suppliers need to meet in order to do business with them. Should no policy exist then the principles of this policy will be deemed to apply.
  • Continuous Improvement: Ergo will monitor the progress of its suppliers in response to sustainability through the performance management aspect of its responsible sourcing strategy.  To this end, suppliers should commit to improving their performance regarding sustainability and strive for continuous growth on their ESG journeys.

Process for Monitoring and Enforcement of the Policy

This Responsible Sourcing Policy will be communicated to all Strategic Suppliers during pre-qualification and onboarding, and we will ensure that suppliers are continuously made aware of its key principles throughout our work together, including during reviews.

The policy will be reviewed and updated periodically to ensure its continued relevance and alignment to regulatory requirements and best practice international standards for responsible sourcing. Should any changes occur to our business activities, stakeholder expectations, or industry standards, we will update the policy to ensure that these changes are reflected in our commitments.

We expect employees and suppliers to report any violations of the commitments of this policy through contacting Ergo’s Compliance Officer.

Policy Oversight

Ergo’s Senior Management and Board of Directors are fully committed to the principles, commitments and expectations outlined in this policy. We are committed to engaging with our Strategic Suppliers to promote sustainable procurement and compliance across all our operations. Ergo’s CEO has oversight over this policy, in collaboration with its compliance and procurement teams, and commits to enforcing the responsible sourcing objectives outlined within it.

 

Policy Owner: Sustainability Committee 

Policy Champion: Claudia Ingoldsby 

Version: 1.1

Review Date: 12.12.25

Changes: 0 

Review Date: 12.12.26