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Ethical Standards and Compliance

ETHICAL STANDARDS AND COMPLIANCE

At K2, we are deeply committed to the principles of environmental stewardship, social responsibility, and sound governance, which are central to our operations and business philosophy. These principles include adherence to ethical conduct, fair labor practices, anti-bribery and anti-corruption laws, sustainability, and minimizing environmental impact. We also prioritize maintaining a respectful workplace, ensuring all interactions are conducted with integrity and professionalism. These principles form a fundamental part of every agreement and contract K2 enters into with clients, suppliers, and partners. By agreeing to cooperate with K2, all parties are expected to uphold these values and integrate them into their practices. Any violation of these principles could be treated as a breach of the agreement. This may result in disciplinary actions, including the termination of the contract, as K2 is committed to ensuring the highest standards of integrity and responsibility in all business relationships.

1. Anti-Facilitation of Tax Evasion. Throughout the cooperation, clients and suppliers agree to fully comply with all applicable laws and regulations related to tax obligations, specifically those aimed at preventing tax evasion and its facilitation. Neither party shall, directly or indirectly, engage in or enable any activity that could be seen as facilitating local or international tax evasion, including actions to conceal taxable income or assets unlawfully.

Both parties must implement strict internal policies and procedures to prevent any tax evasion facilitation by employees, subcontractors, consultants, or other third parties. These measures should include clear guidelines, training, and monitoring to ensure compliance and awareness of legal consequences. The client and supplier must regularly review and update these policies to remain in compliance with evolving regulations.

If a third party requests or suggests involvement in tax evasion facilitation, the party must immediately report it to the other party, providing details of the request and the identity of the requesting party. Upon request, the parties must provide evidence of compliance, including a signed declaration within 14 days confirming adherence to these obligations.

Both parties must ensure that all third-party consultants or providers are bound by these anti-tax evasion requirements and monitor their compliance. Any breach of these obligations by consultants or third parties will be considered a violation of the contract.

2. Anti-Slavery. In fulfilling its obligations, both the client and the supplier agree to comply with all applicable laws and regulations intended to combat modern slavery and human trafficking, and to adhere to K2’s Anti-Slavery and Human Trafficking Policy. Each party warrants that neither it nor any associated individuals or entities have been convicted of or investigated for slavery or human trafficking offenses. To mitigate risks, each party agrees to conduct due diligence on its own supply chains, including measures to identify, prevent, and address potential instances of modern slavery or human trafficking. Both the client and the supplier are required to notify K2 immediately upon becoming aware of any actual or potential breaches of anti-slavery or human trafficking laws.

Additionally, each party shall maintain thorough records of their supply chain verification processes and provide K2 with a detailed report on the preventive measures in place against modern slavery and human trafficking whenever requested. This includes regular documentation and monitoring procedures that demonstrate compliance and transparency in preventing and mitigating such risks. Both the client and the supplier must also ensure that any subcontractors or third-party providers adhere to these anti-slavery standards, taking responsibility for their compliance and accepting liability for any violations. Failure to comply with these requirements will be considered a serious breach of contract.

3. Anti-Bribery.  Both clients and suppliers agree to fully comply with all applicable anti-bribery and anti-corruption laws, as well as with K2’s Code of Conduct and Ethics. Each party is required to establish, implement, and maintain comprehensive internal controls, policies, and procedures to ensure compliance with these standards throughout the term of this Agreement. These measures must include regular training for employees, subcontractors, and representatives on anti-bribery and anti-corruption practices, as well as procedures to detect, report, and address any violations or potential violations. 

Each party is responsible for keeping accurate and transparent financial records that clearly document all transactions to prevent any potential concealment of bribery or corrupt activities. If any party becomes aware of an actual or suspected violation of anti-bribery or anti-corruption laws, they must promptly notify K2, detailing the nature of the violation and the actions taken in response. Both parties shall, upon request, provide K2 with evidence of compliance, including access to relevant records, policies, and documentation of internal audits related to anti-bribery efforts.

If K2 reasonably determines that either party has breached, or is alleged to have breached, these anti-bribery provisions, K2 reserves the right to terminate the Agreement immediately, without prior notice. In such cases, the non-compliant party waives any claims against K2 and its affiliates and agrees to indemnify, defend, and hold them harmless from any resulting damages, losses, fees, or costs, including legal fees and expenses, arising from the breach. Furthermore, each party agrees to take responsibility for any breaches by third parties they engage in and shall implement contractual safeguards with subcontractors and consultants to enforce adherence to these anti-bribery standards.

4. Respectful Workplace and Client Interaction.  All of K2’s clients and suppliers agree to uphold a professional, respectful, and harassment-free environment throughout the duration of this contract. Both parties commit to maintaining a workplace where all individuals are treated with dignity and respect, and where any form of harassment, including sexual harassment, is strictly prohibited. This policy aligns with the Equality Act 2010 and ensures that both parties conduct themselves with the highest standards of integrity and professionalism in all interactions.

Each party is responsible for ensuring that its employees, subcontractors, representatives, and any third parties engaged in the delivery of services adhere to these standards of conduct. If any party becomes aware of harassment or inappropriate behavior within the workplace or during interactions related to this contract, they are obligated to take immediate and appropriate action. This may include investigating the issue, addressing it promptly, and, where necessary, removing the offending individual(s) from the working environment.

In the event of any harassment by the client, supplier, or their respective representatives, the affected party must notify the other party immediately. The party responsible for the harassment will be required to resolve the matter swiftly, and the other party may require the offending individual to be removed from the working environment, depending on the severity of the incident. Both parties acknowledge the importance of creating a safe and respectful working environment and agree to take all necessary steps to prevent and address any form of harassment.

5. Whistleblowing Commitment.  K2 is dedicated to upholding the highest standards of integrity, transparency, and ethical conduct in all of our operations. As part of this commitment, K2 extends the same principles to our clients and suppliers, ensuring that they also promote an environment where ethical behavior is a priority and where any concerns about misconduct can be raised safely and confidentially. We are committed to providing all parties involved in this agreement—whether employees, subcontractors, agents, or third-party service providers—with a secure and confidential mechanism for reporting any concerns about unethical behavior, violations of the law, or breaches of contractual obligations.

Both clients and suppliers are encouraged to report any such concerns without fear of retaliation, as K2 guarantees that all reports will be treated with the utmost seriousness and confidentiality. Reports will be thoroughly investigated, in line with K2’s strict whistleblowing guidelines, which are designed to ensure accountability and transparency. These guidelines are available here. 

K2 ensures that whistleblowers are protected from retaliation, and we work with our external partner to manage and address reports fairly and thoroughly. By maintaining this commitment, K2 aims to promote a culture of trust, integrity, and accountability across all parties involved in this agreement. Clients and suppliers are also expected to support this initiative, ensuring that their own employees, subcontractors, and third parties are aware of these reporting mechanisms and encouraged to use them when necessary. Any retaliation against a whistleblower by a client, supplier, or any associated party will be treated as a serious violation of this agreement.

6. Environmental, Social and Governance. K2 is deeply committed to integrating Environmental, Social, and Governance (ESG) principles into every aspect of our business operations. We actively drive initiatives that promote sustainability, social justice, and sound governance practices to ensure that our business contributes positively to the environment and society. Our commitment to ESG reflects our dedication to environmental stewardship, social responsibility, and ethical business management, all of which are essential in maintaining the trust of our clients, suppliers, and the wider community.

We expect our clients, suppliers, and all associated partners to share this commitment and align their practices with K2’s values. To support this, we refer to our Code of Conduct, which outlines our standards for ethical behavior, fair labor practices, and our expectations regarding environmental and sustainability goals. This Code is designed to ensure that all parties involved in our projects adhere to the same principles of fairness, integrity, and environmental responsibility.

In addition to the Code of Conduct, K2’s Environmental Policy sets clear expectations for all stakeholders to adopt environmentally friendly practices, minimize environmental impact, and comply with relevant environmental laws and regulations. We require our clients and suppliers to actively implement these practices in their operations and supply chains, ensuring that they meet or exceed the minimum standards established in our policy. 

These ESG commitments form the essential framework for our cooperation, ensuring that all parties uphold responsible, sustainable practices. By working together and fostering a culture of environmental and social responsibility, we aim to build a robust, sustainable supply chain that contributes positively to the planet and society. Compliance with these ESG standards is not only a requirement but a shared goal that drives long-term success for K2, its clients, and suppliers.