Global Partner Code of Conduct

Geotab Inc. is committed to transparency, treating all people with respect and dignity, ensuring safe working conditions and conducting environmentally responsible and ethical operations. We expect Partners in our operations and supply chain, and their Partners at all tiers, to embrace the following social, environmental and ethical responsibilities with equal enthusiasm for transparency. Geotab reserves the right to require its Partners to provide proof of their compliance with the requirements set out in this document.

This Global Partner Code of Conduct applies to any Partner doing business with Geotab Inc. or any of its affiliates or subsidiaries worldwide. For this purpose of this policy, “Partner” refers to any person or entity with a business relationship with Geotab, including those that provide goods or services to Geotab, regardless of the type or absence of compensation for such goods or services, those who act as resellers of Geotab products and services, and those who otherwise participate in the Geotab products and services ecosystem (e.g. Geotab Marketplace Partners). “Worker” refers to any person a Partner compensates in any form or manner in exchange for performing labor or any other work.

Partner Compliance with Geotab’s Global Partner Code of Conduct

All Partners must adhere to the following requirements in order to maintain a partnership with Geotab:

1. At a minimum, Geotab’s Partners must comply with all applicable laws, regulations, legal directives and guidelines, and contract obligations they may have with us. For avoidance of doubt, in the event of a conflict in any contract between a Partner, Geotab and this Code, the contract will prevail.

2. Partners accessing or using Geotab’s property, facilities, information technology (IT) systems or other assets will comply with all of our applicable policies and requirements as communicated by Geotab at the time of onboarding.

3. If Geotab requires certifications by third parties for various reasons to manage health, safety and auditability, such as ISO 50001, 14001 or OHSAS 18001, Partners will promptly obtain such certifications or provide reasonable timelines to compliance.

4. Partners will accurately and completely disclose information regarding their labor, employment, health and safety, environmental practices, business activities, organizational structure, financial situation and contract performance, at least annually and promptly upon Geotab’s request.

5. Partners must be familiar with and follow the rules of global sanctions, and be aware of the sanctions’ impact on their business. In particular, Partners will comply with the geographical and targeted sanctions regimes of the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC). Partners will ensure that they do not do business with any person or entity listed on OFAC’s Specially Designated Nationals (SDN) List or Consolidated Sanctions List, or with any other persons or entities as prohibited by applicable law.

6. Partners will identify, understand and comply with all applicable obligations related to importing and exporting, including customs laws and regulations. Partners must understand and comply with all applicable requirements to obtain licenses to export goods, services or technologies.

7. Partners will cooperate with any information requests or audits that Geotab or our customers may initiate. Though Geotab seeks to work cooperatively with Partners to resolve issues, we may terminate our relationship with any Partner that fails to comply with this Code.

Labor and human rights

Geotab is committed to upholding the human rights of workers and treating persons with dignity and respect. This applies to all workers, including temporary, migrant, student, contract, direct employee and any other type of worker. As a result, Partners must manage their own workforce in a manner which adheres to the following:

Modern Slavery

Geotab is committed to ensuring that no part of our business, including our supply chain, engages in or facilitates modern slavery or human trafficking. Accordingly, our Partners must ensure that they do not participate in or facilitate modern slavery or human trafficking. Read Geotab’s full Modern Slavery Statementhere.

Freely chosen employment

Partners will not use or permit any form of forced, bonded or indentured labor. All work must be voluntary, and all workers must be free to terminate their employment at any time. Partners will not hold workers’ identity, immigration or work permit documents longer than reasonably necessary for administrative processing. Partners will not require workers to pay recruitment fees or other fees for their employment, either directly or through third parties, and will repay any worker who has paid such fees. Partners will not unreasonably restrict workers’ freedom to move into, out of, or within working facilities, except where role-based access and privacy/security controls mandate restricted access. As part of the hiring process, Partners are expected to give each worker a written agreement (or statement) describing the worker’s terms of employment in a language understood by the worker, and, if internationally relocating, the writing will be provided before the worker leaves their country of origin. Partners will integrate the following labor and wage standards into their business processes to provide workers with a law-abiding work environment:

Underage Labor

Partners will not use child labor. “Child” means any person under age 18, under the age for completing required education or under the minimum age for employment in the relevant country, whichever age is lowest. Partners may use legitimate, properly managed apprenticeship programs, such as student internships. Unless otherwise addressed by local law, Partners are expected to pay student workers, interns and apprentices at least the same wage rates as other entry-level workers performing the same or similar tasks.

Wages

Partners will pay workers at least the legally mandated wages and benefits. Partners must comply with applicable laws regarding paid vacation, personal time off and wage deductions. Partners will provide workers with all details on which workers are compensated via pay stubs or similar documentation that lists all deductions. Partners will not deduct from wages as a disciplinary measure.

Working hours

For workers who are paid hourly, a Partner’s work week (seven consecutive days) will not exceed 60 hours per week (including overtime) or, if less, the maximum set by local law. Workers will be allowed at least one day off every seven consecutive days. Partners will comply with applicable overtime and other premium compensation rules.

Fair Treatment, non-discrimination, diversity and inclusion

Partners will not permit harassment, bullying, physical, verbal or psychological abuse, corporal punishment, or any other form of excessive, cruel, inhumane or unusual treatment. Partners will not subject workers or potential workers to unlawful medical tests or physical exams or any other unlawful form of testing. Partners will not discriminate in screening, hiring, evaluating, promoting or demoting, terminating or any other employment practices based on race, color, age, sex, gender, gender identity, gender expression, sexual orientation, marital status, ethnicity, national origin, caste, disability, genetic information, medical condition, pregnancy or parental status, religion, political affiliation, union membership, veteran status, body art or any other legally protected characteristic. Partners will reasonably accommodate workers’ religious practices, disabilities, military service requirements, lactating and other parental needs and other requests from workers based on a protected status and in accordance with applicable law. In addition, Partners will demonstrate a commitment to identify, measure and improve a culture of diversity and inclusion through all aspects of workplace management.

Freedom of association and collective bargaining

Partners will permit workers to associate freely, bargain collectively and seek representation in accordance with applicable law. Partners will permit workers to communicate openly amongst themselves and to share grievances with management about working conditions without fear of reprisal or harassment, and will implement anonymous helplines to ensure that workers can report their concerns or violations of law.

No retaliation

Partners will not take an adverse employment action or otherwise retaliate against any worker who exercises their rights in accordance with applicable law or as set out in this Code.

Fair investigation

Partners will investigate and address all inquiries, complaints, concerns or incidents that violate this section of this Code entitled “Labor and Human Rights,” or any other part of this Code, in a fair, respectful and timely manner.

Information

Partners will provide information requested by Geotab about their labor and employment practices and compliance with labor and employment laws and this section of this Code promptly upon request.

Health and safety

Geotab is committed to ensuring a safe and healthy work environment. Partners will integrate the following health and safety management requirements into their business processes to provide workers with a healthy and safe work environment:

Occupational safety and health

Partners will comply with all applicable safety and health laws and regulations and identify, evaluate and control worker exposure to safety and health hazards, including chemical, biological, physical and ergonomic stressors, through proper design, engineering controls, maintenance, safe work procedures and ongoing health and safety guidance. Where these means cannot adequately control hazards, Partners will protect workers with appropriate personal protective equipment and provide them with information about the potential risks of the hazards to which they are exposed. Partners will implement procedures to prevent, manage, track and report occupational injury and illness, including encouraging worker reporting, classifying and recording cases, to provide appropriate and adequate medical treatment, to investigate cases, to implement appropriate and adequate corrective actions and to facilitate workers’ return to work. Partners will report to Geotab, in writing, all factual information about a non-compliance with applicable law or accident within 48 hours after occurrence, and will provide written summaries of compliance with their compliance or accident prevention measures and implemented or intended corrective actions within one week (seven consecutive days) after an accident’s occurrence.

Workplace harassment

Partners will provide a working environment that is free of workplace harassment and workplace sexual harassment, and will investigate and deal with all complaints or incidents of workplace harassment or workplace sexual harassment in a fair, respectful and timely manner.

Emergency preparedness

Partners will identify and develop written plans for addressing and recovering from potential natural and other disasters, pandemics, war and civil unrest, labor disputes or disruptions and other emergencies, and will implement these emergency plans. Partners will provide guidance to their workers on emergency response preparedness and recovery procedures, including emergency reporting, worker notification and evacuation, drills, and fire detection and suppression equipment. Partners will notify Geotab in writing about emergencies that might or will affect their operations and potentially affect Geotab’s operations as soon as possible, but no later than 48 hours after the emergency commences or occurs, including an assessment of how the emergency might affect Geotab’s operations. Partners will provide copies of such plans at least annually and promptly upon request.

Sanitation, food and housing

Partners will provide workers with ready access to adequate and clean toilet facilities, potable water and sanitary food preparation, storage and eating facilities. If Partners provide workers with residential facilities, those facilities will be clean and safe and comply with all applicable laws, including local building codes, have adequate personal space, unrestricted entry and exit, fire detection and suppression equipment and emergency egresses, adequate heat and ventilation, and hot water for cooking and bathing. Partners will provide information requested by Geotab about sanitation, food, housing and related information for their workers, at least annually and promptly upon request.

Information

Partners will provide information requested by Geotab about their health and safety practices and compliance with health and safety laws and this section of the Code at least annually and promptly upon request.

Environmental

Geotab recognizes that environmental responsibility is integral to producing world-class products. In manufacturing operations and construction, Partners will strive to create regenerative processes and work to minimize adverse effects on the community, environment and natural resources while safeguarding the health and safety of the public. Partners will integrate the following green standards into their business processes:

Environmental permits and reporting

Partners will obtain and keep current all environmental permits, approvals and registrations required by applicable law and follow all operational and reporting requirements.

Resource efficiency and clean energy

Throughout their operations, Partners will work to reduce consumption of resources, including raw materials, energy and water. Partners will track, document and seek to minimize energy consumption and greenhouse gas emissions and seek ways to improve energy efficiency and use cleaner sources of energy.

Hazardous and restricted substances

Partners will identify and manage chemicals and other materials that pose a hazard to workers and the environment to ensure their safe handling, use, storage and disposal. Partners will identify, monitor, control, treat and reduce hazardous air emissions, wastewater and waste generated from their operations. Partners will adhere to Geotab’s requirements restricting use of specific substances, including labeling for hazards, recycling, or disposal.

Waste mitigation: wastewater, solid waste and stormwater management

Partners will work to reduce or eliminate waste of all types. Where waste cannot be eliminated, Partners will manage and control all waste streams in an environmentally responsible and secure way and in accordance with applicable laws and regulations, including without limitation preventing and remediating illegal discharges and spills, and treating, as required, prior to discharge or disposal, all wastewater and solid waste from operations, industrial processes, and sanitation facilities.

Information

Partners will provide information requested by Geotab about their environmental practices and compliance with environmental laws and this section of the Code at least annually and promptly upon request.

Ethics and compliance

Partners will uphold the highest standards of ethics to promote honesty and integrity in their business dealings and operations. Partners will adopt policies and procedures that integrate the following principles of business ethics into their processes:

Business integrity

Partners will avoid even the appearance of conflicts of interest in their work with Geotab, and will immediately disclose any family or other close personal relationships with our employees or representatives who have an influence over their business dealings with Geotab. If you provide Geotab with goods or services in support of Geotab’s commercial sales, you may not extend any business courtesy to our employees or representatives, except infrequently and where the courtesy has a nominal value. If a Geotab employee or representative offers or accepts a business courtesy that has a value of more than US$150.00, you must immediately report this to Geotab. Partners providing goods or services in support of Geotab’s government sales or for government end use may not offer, request or receive any business courtesies on behalf of themselves or on behalf of Geotab, regardless of value. Partners will not offer or accept any form of bribery, kickbacks, corruption, extortion or embezzlement. Partners will not make illegal payments, directly or indirectly. Partners will implement monitoring and enforcement procedures to ensure compliance with anti-corruption laws. Partners must report to Geotab any allegations of corruption or unethical behavior made against them or one of their employees by a government anywhere in the world. Partners will accurately reflect their business dealings and operations in their books and records.

Intellectual property

Partners will respect Geotab’s and others intellectual property rights, and will conduct technology and know-how transfers in a manner protecting intellectual property rights. Partners will not use or transfer any of Geotab’s intellectual property rights without a written agreement with Geotab allowing them to do so.

Responsible materials sourcing and use

Partners will adopt and maintain a policy concerning responsible sourcing and use of components and raw materials, which will address at a minimum counterfeit, substitute, and used or repaired parts, specialty metals and conflict minerals. Partners must comply with applicable laws and regulations and contract terms and conditions regarding materials sourcing and use. Partners will obtain, maintain and will make available to Geotab at least annually or promptly upon request, all such documentation and other information requested by Geotab regarding materials and their sources and use.

Privacy and information/cyber security

Geotab does not sell data that it processes from its customers, Partners or other third parties in such a manner that can identify the subjects of the data. Accordingly, Partners may not sell any third party data received or obtained during their relationship with Geotab and may not use any such third-party data without prior written authorization from Geotab. Partners will comply with all applicable laws and regulations and contract terms and conditions regarding privacy, data protection and information/cybersecurity. Further, Partners must read Geotab’sprivacy policy and will not undertake any actions that cause Geotab to violate said policy.

Accessibility

Partners will embed relevant accessibility standards, innovation, and best practices to deliver an inclusive work environment, products and services for all users.

Information

In addition to the specific information requirements in this section of the Code, Partners will provide information requested by Geotab about their compliance with the various provisions of this section of the Code at least annually and promptly upon request.

Management system

Partners will adopt or establish a management system to carry out the responsibilities set out in this Code. The management system will be designed to ensure that Partners’ operations: (a) comply with Geotab requirements, contract terms and conditions and applicable laws and regulations; (b) conform to these responsibilities; and (c) identify and mitigate operational risks related to these responsibilities. Partners’ management systems should also facilitate continuous improvement. Partners will provide Geotab with information evidencing that their management systems meet the requirements of this Code at least annually and promptly upon request.

The Partner’s quality management system must contain the following minimum elements:

1. Executive level commitment and accountability,

2. Processes to identify, monitor, and comply with all applicable laws, regulations, standards, requirements, and contract terms and conditions,

3. Risk management processes,

4. Communications and training for all workers and lower tier Partners, as determined by Partners,

5. Ongoing assessments, monitoring and continued improvement, including corrective action processes.