1. INTRODUCTION AND PURPOSE

Creative Clicks B.V. and all of its subsidiaries (hereinafter collectively referred to as "Creative Clicks", "we", "us") places great value on integrity and social responsibility, principles that we uphold within our own organisation. We expect all Suppliers who provide products and services to Creative Clicks ("Suppliers", "you") to share in this commitment. The Creative Clicks Supplier Code of Conduct ("Code") outlines our expectations for how Suppliers conduct business globally. At Creative Clicks, we expect Suppliers to adhere to the Code and comply with all international trade obligations as well as any applicable laws and regulations in the regions where they operate, while also striving for continuous improvement within the environmental and social domains. Additionally, Suppliers must extend similar obligations to their own Suppliers, subcontractors, and agents.

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2. SCOPE

• Creative Clicks is committed to conducting its business in an ethical, legal, and responsible manner. 
• This Code of Conduct sets out basic requirements on human rights, labour, environment, and business integrity. Creative Clicks, its employees, and shareholders have a duty to comply with the applicable laws and regulations and are expected to behave responsibly and ethically.
• This Code has cross-border application, and sets the baseline for compliance, however, any national, local or municipal legislation in the country of operation detailing stricter guidelines, must be adhered to. 
• Creative Clicks expects its Suppliers to work on their corporate social responsibility and comply with the requirements set out in this Code. We expect our Suppliers to promote these basic requirements actively throughout their supply chain.
• This Code is made in accordance with; International Labour Organisation (ILO), UN Universal Declaration of Human Rights (UDHR), UN Global Compact, UN Conventions on children’s rights and the elimination of all forms of discrimination, EU Forced Labour Regulation and the OECD Guidelines for Multinational Enterprises. 
• By acknowledging this Code, you agree that you are committed to acknowledging the social and environmental standards laid down in this Code and to take appropriate measures by securing relevant corporate policies and management systems to ensure that the requirements of the Code can be met. 

3. BUSINESS INTEGRITY AND ETHICAL PRACTICES

1. Compliance With Applicable Laws
   
   • Supplier must ensure that any and all of its activities are in compliance with applicable international, national, municipal and local laws, rules, and regulations of relevant the jurisdictions they operate in.
   • This includes laws and regulations relating to environmental, health and safety, ethics, and labour practices. Additionally, to Suppliers based in the following countries, we expect compliance with the following Regulations; including but not limited to:
     1. The Netherlands: EU competition law, GDPR, Dutch Civil Code, EU Whistleblower Directive, 
     2. United States of America (California): Federal Antitrust Law, California Antitrust Law, CCPA/CPRA privacy, SOX whistleblower protections
     3. Canada: Competition Act, PIPEDA, applicable provincial privacy laws, federal and provincial whistleblower protections
     4. China: Anti-Unfair Competition Law, PRC Criminal Law (commercial bribery), Personal Information Protection Law (PIPL), Cybersecurity Law, Data Security Law.
   • Suppliers must require their sub-Suppliers to follow the same beha
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2. Competition – Common Forms of Prohibited Content
   • Unlawful Exchange of Confidential Information. Certain competitive information can be used fully and freely, such as information that is available in trade and other publications, obtainable by analysis of a competitor’s marketed products, or disclosed in formal presentations at public meetings. However, it is prohibited to use privately shared information. Prohibited exchange of confidential information occurs where parties who compete with one another, even if contemplating a transaction or the exchange of information in another context, engage in discussions or information exchanges that adversely impact competition between them.
   • Price Fixing and Market Sharing. Price fixing is an agreement among competitors that raises, lowers, or stabilises prices or competitive terms. Competitors are not allowed to enter into an agreement on raising prices, offering no discount/more discount, apply minimum prices and pass on surcharges. Even talking about prices with competitors is forbidden. Market sharing is when competitors agree to divide or allocate customers, Suppliers, or geographic areas among themselves rather than making independent decisions as to where to operate, who to source from and which customers to pursue. Competitors are not allowed to divide the market by not supplying each other’s customers, not supplying in each other’s area, not selling the same product (due to an agreement) and arrange different periods for discounts.
   • Abuse of Dominance. Abuse of dominance (or abuse of market power) occurs when a dominant firm, or group of firms, substantially prevents or lessens competition, by engaging in acts that aim to eliminate or discipline competitors, or simply to stop potential competitors from entering a market. Abusing a dominant position may include predatory pricing, tying, unreasonably high prices and exclusive purchasing. These practices are strictly prohibited.
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3. Corruption and Bribery 
   • Corruption. An umbrella term that includes every form of the abuse of power for personal gain. Besides bribery this also includes nepotism, trading in influence and extortion. It makes no difference if the recipient or instigator is a public official or a private individual. Corruption can also go together with laundering proceeds of the corrupt practices, forgery, and accounting fraud. The following laws are applicable, but the scope is not solely limited to them, and Supplier should take appropriate measures for compliance: 
     
     • Netherlands/EU: EU Anti-Corruption rules, Dutch Penal Code.
     • USA: Foreign Corrupt Practices Act (FCPA) – prohibits bribing foreign officials.
     • Canada: Corruption of Foreign Public Officials Act (CFPOA).
     • China: Strict anti-bribery under PRC Criminal Law, Anti-Unfair Competition Law (ban on commercial bribery and “facilitation payments”).
   • Bribery. A common manifestation of corruption. Bribery is prompting someone to act refrain from acting by offering gifts, services or hospitality or making promises with a view to gaining an unfair business advantage. Facilitation payments are a familiar manifestation of bribery. These are small sums paid to low-level public officials for routine actions such as arranging customs clearance. Suppliers shall not engage in or tolerate any form of corruption, bribery, extortion, or embezzlement. Suppliers shall not offer or accept any benefits or other means to obtain any undue or improper advantage. Such improper benefits may comprise cash, non-monetary gifts, pleasure trips or services and amenities of any other nature. 
   It may be allowed to give gifts with the permission of Creative Clicks if the following requirements are met:
   • It is not made with the intention of influencing the party to whom the gift is being given;
   • It is in compliance with applicable European Law;
   • It is not given in the name of an individual;
   • It does not include cash or cash equivalent;
   • It is given/received openly;
   • It is not offered to a government official, a representative or a politician; and
   • It is not above a certain amount.
   All purchases, sales and other contractual commitments must be based solely on consideration of quality, service, price, and efficiency. Only business reasons should determine whether to enter into a contract and with whom. In their dealings with Creative Clicks, if Suppliers become aware of inside information about us or our clients, we expect Suppliers to have policies and procedures in place for the proper handling and use of that information in line with applicable laws and regulations.All business dealings should be transparently performed and accurately reflected in Supplier’s business books and records. Requests for false invoices or payment of expenses that are unusual, excessive, or inadequately described must be rejected and reported. Falsification of records or misrepresentation of conditions or practices in the supply chain are unacceptable.Creative Clicks will not make donations (in cash or any other means) to a political party or a candidate as this may be perceived as an improper business advantage. We also urge our Suppliers to adopt similar practices. Creative Clicks accepts the act of donating to charities – whether through services, knowledge, time, or direct financial contributions and agrees to disclose all charitable contributions it makes. Suppliers are required to be careful in ensuring that charitable contributions are not used to facilitate and conceal acts of bribery.
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4. Intellectual Property & Confidentiality. Suppliers, and sub-suppliers shall respect all Intellectual Property, trade secrets and confidential information of Creative Clicks and its customers, Supplier may become aware of. Supplier shall manage technology and know-how in a manner that protects intellectual property rights.
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5. Privacy and Data Security 
   
   • Creative Clicks commits to the proper application of the GDPR and other data protection legislation and takes its responsibility with respect to the fair and transparent processing of data, the legitimate interests pursued by controllers in specific contexts, the information provided to the public and to data subjects, the exercise of the rights of data subjects, the information provided to, and the protection of, children, and the manner in which the consent of the holders of parental responsibility over children is to be obtained.
   • Supplier is expected to follow the same approach when dealing with personal data including but not limited to data transfer to third countries. Compliance with GDPR is of utmost importance for Creative Clicks.
   • Supplier shall treat any information received from us, including any reported data, internal policies, and training documents, as confidential. Confidentiality obligations do not apply where disclosure may be required by law or by governmental authorities, or if information has already been made public elsewhere.
   • Supplier is obligated to notify us in case of an actual or suspected privacy or security breach. 
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6. Whistleblower PolicySuppliers must promote an environment supportive of open communication, encouraging employees and external stakeholders to come forward with any concerns or observations of possible or actual misconduct.Suppliers shall ensure accessible, effective reporting channels are available to all employees, contractors, and other internal or external stakeholders, enabling them to confidentially report any concerns or incidents of misconduct. Where legally permitted or required, Suppliers must also allow anonymous reporting.Suppliers are encouraged to establish:
   • policies and procedures that protect the confidentiality of both the reporter and the details of the reported issue, and
   • a structured process for reviewing, investigating, and addressing reported concerns or violations appropriately.
   • Suppliers must have safeguards in place to protect individuals who report misconduct in good faith from retaliation, unfair treatment, harassment, or any negative repercussions as a result of their report.
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7. Supplier Obligations
   
   • Suppliers must not take or appear to take any action that could unfairly exclude or reduce competition in any market.
   • Suppliers must not misrepresent, manipulate, conceal, misuse confidential information, and must not engage in disparaging discourse against competitors, or unfair practices with shareholders, clients, business partners, competitors, and other Employees and Partners.
   • Suppliers must only obtain information about competitors, their products, services, technologies, pricing, marketing campaigns, etc. only through legal and ethical means.
   • Suppliers must also not enter Creative Clicks into any business arrangement or cartel conduct to eliminate or discourage competition or confer an inappropriate competitive advantage. Prohibited activities may include, but are not limited to, price fixing agreements, illegal boycotting of Suppliers or clients, bid rigging, cartel conduct, predatory practices, exclusive dealing, misuse of market power, controlling the output or limiting the supply of goods and services, unconscionable conduct, concerted practices, price signalling, price fixing to eliminate a competitor, entering into an agreement or arrangement with competitors to divide a market, exchanging confidential information.
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8. Non-Compliance. Creative Clicks has a zero-tolerance approach on all forms of unfair practices or anti-competitive conduct committed by Employees or Partners acting on its behalf. Engaging in anti-competitive behaviour will result in a breach of this policy and the law, and consequences will apply up to and including termination of employment and penalties can be severe. Violating competition law can have legal and regulatory consequences, including civil and criminal liability, possible imprisonment, monetary fines and penalties on Creative Clicks, Partners and Employees, and reputational damage.

4. LABOUR PRACTICES AND HUMAN RIGHTS

1. Forced and Child Labor
   
   • We expect our Suppliers to respect and protect internationally recognised human rights both in the workplace and in general business practices. 
   • All employees working under Supplier whether directly or indirectly should be treated with honest, respect and dignity. 
   • All employment for Supplier shall be freely chosen by the worker. Workers shall be free to leave their employment at any time and shall not be subject to any coercion or restriction.
   • Any forms of exploitation of children and working conditions resembling slavery or harmful to children’s health are forbidden under ILO and UN Conventions. Supplier shall only employ individuals that have reached, at least the applicable minimum legal age for employment. If children are discovered working in conditions that meet the definition of child labour, Supplier must establish and document policies and procedures to ensure their remediation.
   • Supplier may employ juveniles who have reached the applicable national, or local legal minimum age to perform work, provided they do not perform work that might jeopardise their health, safety, or morals, consistent with ILO Minimum Age Convention No. 138. Supplier is obligated to protect the rights of juvenile workers; under no circumstances should Supplier require juvenile workers to work overtime or perform nighttime work.
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2. Working Conditions
   • Working hours must be limited according to national or local law, including breaks. Overtime should be voluntary, should not replace regular employment and must be fairly compensated.
   • Supplier shall comply with applicable laws relating to wages and benefits (including minimum wages, overtime pay, equal remuneration and legally mandated benefits). Suppliers must not use deductions from wages as a disciplinary measure and must pay workers in a timely manner.
   • Supplier must acknowledge the freedom and rights of workers to organise themselves in order to promote their interests.
   • Suppliers shall ensure a safe and healthy workplace or any other location where work is undertaken. It must take adequate precautionary measures to prevent accidents and damage to health that arise from, relate to, or occur during the work. 
   • All work shall be preceded by and be based on documented adequate risk management with implemented controls. This shall include physical, social, and organizational health risks.
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3. Discrimination and Harassment
   • Supplier shall treat all workers with respect and dignity.
   • Supplier is obligated to ensure that employees are protected from harsh or inhumane treatment including violence, gender-based violence, sexual harassment, sexual abuse, corporal punishment, mental or physical coercion, bullying, public shaming, or verbal abuse of workers; nor is there to be the threat of any such treatment. 
   • Supplier shall not engage in, or support harassment or discrimination based on race, colour, age, gender, sexual orientation, gender identity and expression, ethnicity or national origin, disability, pregnancy, religion, political affiliation, union membership, protected genetic information or marital status in hiring and employment practices.

5. ENVIRONMENTAL PRACTICES

• Creative Clicks has ambitious goals on environmental sustainability and expects its Suppliers to contribute to these goals. 
• Supplier shall company with all environmental laws and regulations including the use and handling of hazardous waste, whether international or national. In line with the legislation, you also shall report on the environmental impact of your activities transparently. 
• The Supplier should endeavour to make continuous improvements in environmental performance through practicable measures and employ leading practices where possible.
• Supplier shall take responsibility by using techniques in the production process that have a minimum negative impact on the environment and shall make maximum efforts to limit the negative impact on biodiversity in the chain - including at Suppliers and partners.
• Suppliers shall make continuous effort to optimise their business in accordance with circular economy principles such as reducing the use of virgin raw materials, optimising product duration, increasing recycling and minimising landfill of waste. 
• We expect Suppliers to measure, manage and reduce energy usage and Greenhouse Gas emissions.

6. COMPLIANCE WITH THE CODE 

• Suppliers should have adequate management systems and controls in place to ensure compliance with the Code or equivalent standards.
• Suppliers are required to promptly report to Creative Clicks any legal violations or violations of this Code or any other Creative Clicks policy. Any and all reports should be sent to the following email: legal@creativeclicks.com. 
• Creative Clicks may monitor compliance with this Code and may audit Supplier. When such an audit is requested from Creative Clicks, Supplier should respond and cooperate promptly to help Creative Clicks with their audit. 
• In case of a violation of law, or this Code, Creative Clicks may suspend or terminate the relationship as well as disclosing the matter to relevant authorities.

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7. SUPPLIER’S ACKNOWLEDGEMENT

Supplier confirms that: 

• They have received and taken due note of the Code of Conduct. 
• They are aware of all applicable international and national laws and regulations.
• They agree to report to Creative Clicks in case of violations of the law or this Code of Conduct.
• All the relevant employees will be informed of this Code of Conduct to comply with the standards.

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