Supplier & Vendor Code of Conduct

NAWINZA (OPC) Private Limited
Effective Date: 21 August 2026

1. Purpose and Commitment

NAWINZA (OPC) Private Limited is committed to conducting business with suppliers, manufacturers, vendors, service providers, contractors, sourcing partners, distributors and other business partners who share our principles of integrity, ethical business conduct, product quality, regulatory compliance, transparency, responsible sourcing and respect for people and the environment.

This Supplier & Vendor Code of Conduct (“Code”) establishes the minimum standards expected from all suppliers and vendors who supply products, materials, services or other business support to NAWINZA.

Compliance with this Code forms an important part of our supplier and vendor relationship and may be considered during supplier selection, onboarding, evaluation, purchasing, quality review and continuation of business relationships.

2. Scope

This Code applies to all suppliers and vendors of NAWINZA, including, where applicable:

• Manufacturers and contract manufacturers
• OEM/ODM and private-label partners
• Product suppliers and distributors
• Importers and exporters
• Raw-material and packaging suppliers
• Logistics and warehousing partners
• Agents, brokers and sourcing intermediaries
• Service providers and contractors
• International suppliers and business partners
• Subcontractors and other parties engaged in fulfilling NAWINZA requirements

Suppliers are expected to communicate applicable requirements of this Code to their own relevant employees, subcontractors and business partners.

3. Compliance with Applicable Laws

Suppliers and vendors must conduct their business in compliance with all applicable laws, regulations, standards, licences, permits and governmental requirements in the jurisdictions in which they operate or supply products or services.

Depending on the nature of the product or service, this may include requirements relating to:

• Product safety
• Manufacturing and quality standards
• Labelling and packaging
• Consumer protection
• Import and export controls
• Customs and trade documentation
• Intellectual property
• Environmental requirements
• Labour and employment
• Taxation
• Anti-bribery and anti-corruption
• Data protection and confidentiality
• Product-specific regulatory requirements

Where local law and this Code address the same subject, suppliers are expected to comply with the higher applicable standard to the extent legally permissible.

4. Ethical Business Conduct

Suppliers must conduct all commercial activities honestly, professionally and transparently.

Suppliers must not engage in:

• Fraud or fraudulent documentation
• Misrepresentation of products or services
• Concealment of material information
• Unlawful commissions or kickbacks
• Bribery or corruption
• Manipulation of quotations, invoices or commercial records
• Collusion or other anti-competitive conduct
• Any other unlawful or unethical business practice

All business records and commercial information provided to NAWINZA must be accurate, complete and not misleading.

5. Anti-Bribery and Anti-Corruption

NAWINZA maintains a zero-tolerance approach to bribery and corruption.

Suppliers and vendors must not directly or indirectly offer, promise, authorize, request or provide improper payments, benefits, gifts, commissions or advantages to obtain or retain business or influence a business decision.

This requirement applies to dealings with:

• NAWINZA employees or representatives
• Government officials
• Customs authorities
• Regulatory authorities
• Customers
• Business partners
• Agents and intermediaries

Legitimate and properly documented commercial expenses must not be used as a means of providing an improper benefit.

6. Conflicts of Interest

Suppliers must disclose any actual, potential or perceived conflict of interest that could improperly influence their relationship with NAWINZA.

Any personal, financial or business relationship involving a supplier and a NAWINZA employee, director, representative or decision-maker that could affect objective business judgment should be disclosed promptly.

7. Product Quality and Safety

Suppliers are responsible for ensuring that products supplied to NAWINZA meet agreed specifications, quality standards and applicable legal and regulatory requirements.

Products must be:

• Authentic and accurately described
• Fit for their intended purpose
• Manufactured under appropriate quality controls
• Properly packaged and labelled
• Free from unauthorized substitution or adulteration
• Supported by required documentation
• Compliant with agreed specifications and contractual requirements

Where applicable, suppliers must maintain appropriate systems for quality control, traceability, batch/lot identification, testing and product release.

8. Regulatory Documentation

Where applicable to a product or transaction, suppliers must provide accurate and current documentation, which may include:

• Product specifications
• Certificates of analysis
• Test reports
• Safety documentation
• Manufacturing information
• Ingredient or material declarations
• Licences and registrations
• Certifications
• Country-of-origin documentation
• Batch/lot information
• Packaging and labelling information
• Export/import documentation
• Product photographs or technical information
• Regulatory approvals required for the relevant market

Documents must be genuine, valid and issued or maintained by appropriate authorities or competent organizations where required.

9. No Counterfeit, Adulterated or Unauthorized Products

Suppliers must not supply counterfeit, stolen, adulterated, expired, illegally diverted or otherwise unauthorized products.

Suppliers must immediately notify NAWINZA if they become aware of any suspected counterfeit, adulteration, unauthorized substitution, regulatory issue or other material concern relating to products supplied to NAWINZA.

10. Traceability and Recall Cooperation

Where applicable, suppliers should maintain adequate records to enable reasonable traceability of products, materials and batches supplied to NAWINZA.

If a product presents a safety, quality, regulatory or legal concern, the supplier must cooperate promptly with NAWINZA regarding:

• Investigation
• Product identification
• Batch/lot tracing
• Containment
• Corrective action
• Withdrawal or recall
• Regulatory communication
• Replacement or other appropriate resolution

11. Packaging, Labelling and Product Information

Suppliers must ensure that packaging and labelling supplied or approved for NAWINZA products accurately reflects the agreed product information and applicable requirements.

No material change to formulation, composition, specifications, packaging, labelling, manufacturing location or other significant product characteristic should be made without appropriate prior notification and approval where contractually required.

12. Change Management

Suppliers must promptly communicate material changes that may affect product quality, safety, compliance, availability or commercial suitability.

Such changes may include:

• Manufacturing location
• Manufacturing process
• Raw materials
• Ingredients
• Components
• Formulation
• Packaging materials
• Product specifications
• Product certifications
• Regulatory status
• Ownership or legal entity
• Key subcontractors

NAWINZA may require additional documentation, testing or approval before accepting materially changed products.

13. Labour and Human Rights

Suppliers are expected to respect internationally recognized principles relating to human dignity and responsible employment practices.

Suppliers must not use:

• Forced labour
• Bonded labour
• Human trafficking
• Child labour prohibited by applicable law
• Involuntary prison labour

Suppliers should maintain lawful employment practices, appropriate working conditions and fair treatment of workers.

14. Health and Safety

Suppliers must provide a workplace that is reasonably safe and appropriate for the nature of their operations.

This includes, where applicable:

• Appropriate safety procedures
• Personal protective equipment
• Safe machinery and equipment
• Emergency preparedness
• Appropriate handling of hazardous materials
• Workplace training
• Accident and incident management

15. Environmental Responsibility

NAWINZA encourages suppliers to conduct operations responsibly and to minimize unnecessary environmental impact.

Suppliers should, where reasonably practicable:

• Reduce unnecessary waste
• Use resources efficiently
• Manage water and energy responsibly
• Properly handle waste
• Prevent avoidable pollution
• Follow applicable environmental laws
• Promote responsible packaging and material use

Where environmental certifications or regulatory approvals are required for a product or operation, suppliers should maintain them in valid status.

16. Responsible Sourcing

Suppliers are encouraged to maintain responsible sourcing practices throughout their supply chains.

Where relevant, suppliers should be able to provide reasonable information concerning the origin and sourcing of materials, ingredients, components and products supplied to NAWINZA.

Suppliers must not knowingly provide materials or products sourced through unlawful or prohibited activities.

17. Intellectual Property

Suppliers must respect the intellectual property rights of NAWINZA and third parties.

Suppliers must not:

• Use NAWINZA trademarks without authorization
• Copy proprietary designs or packaging without permission
• Misuse confidential product information
• Supply products infringing third-party intellectual property rights
• Represent themselves as authorized representatives of NAWINZA without written authorization

18. Confidentiality and Data Protection

Suppliers may receive confidential commercial, technical, financial, product, customer or business information from NAWINZA.

Such information must be protected against unauthorized access, disclosure, copying, misuse or distribution.

Suppliers must use confidential information only for legitimate business purposes and in accordance with applicable agreements and laws.

19. Information Security

Where suppliers handle NAWINZA business information electronically, they are expected to maintain reasonable safeguards against unauthorized access, loss, alteration, disclosure, malware, fraud and other security threats.

Any material security incident affecting NAWINZA information should be communicated promptly.

20. Gifts, Hospitality and Business Courtesies

Business gifts, entertainment or hospitality must be reasonable, lawful, transparent and appropriate to legitimate business circumstances.

Suppliers must not provide any gift, payment, hospitality or benefit intended to improperly influence a purchasing, approval, evaluation or commercial decision.

21. Accurate Commercial Documentation

All quotations, purchase documents, invoices, packing lists, certificates, shipping documents, declarations and other records provided to NAWINZA must accurately reflect the underlying transaction.

Suppliers must not intentionally manipulate:

• Product descriptions
• Quantities
• Prices
• Country of origin
• HS classifications
• Shipment information
• Product values
• Certificates
• Invoices
• Regulatory documentation

22. Subcontracting and Third-Party Manufacturing

Suppliers must remain responsible for products and services provided through approved subcontractors, manufacturers or other third parties.

Where prior approval is required under an agreement, suppliers must obtain such approval before transferring material production or service obligations to another party.

Suppliers must ensure that relevant subcontractors operate in accordance with applicable legal, quality, safety and ethical requirements.

23. International Trade and Customs Compliance

Suppliers involved in international transactions must comply with applicable customs, export-control, sanctions, trade and import requirements.

International shipping documentation must be accurate and consistent with the actual transaction.

Suppliers must cooperate with NAWINZA regarding documentation reasonably required for customs clearance, import/export compliance and regulatory purposes.

24. Supplier Assessment and Due Diligence

NAWINZA may conduct reasonable supplier due diligence before or during a business relationship.

Depending on the nature and risk profile of the supplier or product, this may include review of:

• Company registration
• Manufacturing capabilities
• Product specifications
• Licences
• Certifications
• Quality systems
• Regulatory documentation
• Production capacity
• Testing arrangements
• Previous business references
• Ownership or authorized representation
• Relevant compliance information

Submission of information does not automatically guarantee supplier approval.

25. Audits and Verification

Where reasonably necessary and subject to applicable contractual arrangements, NAWINZA may request information, records, certificates, samples or other evidence to verify compliance with agreed requirements.

For higher-risk products or suppliers, additional inspections, testing, audits or third-party verification may be requested.

26. Reporting Concerns

Suppliers are encouraged to promptly raise concerns regarding suspected:

• Fraud
• Bribery or corruption
• Product safety issues
• Counterfeit or adulterated products
• Regulatory violations
• Falsified documentation
• Serious labour concerns
• Unauthorized use of NAWINZA intellectual property
• Material breaches of contractual or ethical requirements

Concerns should be communicated to NAWINZA through the appropriate business contact or official communication channel.

Compliance & Business Enquiries:
Email: nawinza2026@gmail.com

27. Non-Compliance and Corrective Action

Where a supplier fails to meet applicable requirements, NAWINZA may request corrective and preventive action within a reasonable period.

Depending on the seriousness and circumstances of the breach, NAWINZA may:

• Request additional information
• Require corrective action
• Increase monitoring or verification
• Suspend specific products or transactions
• Suspend or restrict purchasing
• Reject non-compliant products
• Require replacement or remediation
• Terminate the business relationship where appropriate
• Take any other action available under applicable agreements or law

Serious violations may result in immediate suspension or termination where legally and contractually permissible.

28. Continuous Improvement

NAWINZA recognizes that responsible supply-chain management is an ongoing process.

Suppliers are encouraged to continuously improve their systems relating to:

• Quality
• Product safety
• Regulatory compliance
• Ethical conduct
• Labour practices
• Environmental responsibility
• Traceability
• Information security
• Responsible sourcing

29. Supplier Acknowledgement

By accepting purchase orders, entering into supply arrangements or otherwise commencing a business relationship with NAWINZA, suppliers are expected to comply with this Code to the extent applicable to their activities and contractual relationship.

Where a written supply agreement contains stricter or more specific requirements, the applicable contractual requirements will continue to apply.

30. Right to Amend

NAWINZA may periodically review and update this Code to reflect changes in applicable laws, international business practices, product categories, regulatory expectations and responsible-sourcing standards.

The latest version published or formally communicated by NAWINZA will apply from its stated effective date.

31. Final Commitment

NAWINZA believes that strong and sustainable business relationships are built on trust, transparency, quality, accountability and mutual respect.

We expect every supplier and vendor to uphold these principles and to work with NAWINZA toward a reliable, responsible, compliant and internationally credible supply chain.

NAWINZA (OPC) Private Limited
Nagpur, Maharashtra, India
Website: www.nawinza.com
Business & Compliance Email: nawinza2026@gmail.com