Sustainable Procurement
Policy© 2002—2024 Cactus Communications. All Rights Reserved1Table of Contents
1. Definitions .......................................................................................3
2. Who Does This Policy Apply To? ..................................................3
3. Purpose ...........................................................................................3
4. Our Expectations from the Suppliers ..............................................4
5. Communication and Training ........................................................5
6. Raising a Concern or Complaint ...................................................6
7. Zero Retaliation...............................................................................6
8. Monitoring and Review...................................................................6
9. Disciplinary Action .........................................................................7© 2002—2024 Cactus Communications. All Rights Reserved21. Definitions“Associates” shall mean all directors, officers, managers, employees(whether full-time, temporary, or part- time), trainees, interns, etc. ofCACTUS, wherever located.
“Suppliers” shall mean any individual or organization, who/ which provides
goods, services or materials to CACTUS, including but not limited to all
current and potential consultants, vendors, distributors, sub-contractors,
business contacts, intermediaries, advisors, agents, freelancers,contractors, and any other parties involved in the supply chain whocontribute to the delivery of products or services to CACTUS, including theiremployees, freelancers, and contractors.
“Sustainable Procurement” is defined as “a process whereby
organizations meet their needs for goods, services, works and utilities in away that achieves value for money on a whole life basis in terms ofgenerating benefits not only to the organization, but also to society and theeconomy, whilst minimizing damage to the environment.”

2. Who Does This Policy Apply To?
This Policy is applicable to all the procurement activities, including goods,services, and works, conducted by Cactus Communications Private
Limited, including all its global affiliates and group companies (“CACTUS”/ “Company” / “we” / “our” / “us).

3. Purpose
This Sustainable Procurement Policy (“Policy”) emphasizes CACTUS’integral values such as integrity, trust, transparency and our firm commitment
to our customers, Suppliers and communities. We consider our Suppliers as
strategic partners, who are integral to our business.
The purpose of this Sustainable Procurement Policy is to establish guidelines
and standards for our supply chain operations that promote environmental,social, and economic sustainability. We recognize that our Suppliers belong© 2002—2024 Cactus Communications. All Rights Reserved3

to different categories in terms of their scale, the product/service they
supply, the materials being used by them, their organisation structure andgeographies of operation. Considering these factors, the Policy has been
designed in a manner that it works for the entire supplier base.

4. Our Expectations from the Suppliers
CACTUS selects and continues business relationship with Suppliers byconsidering factors such as the perfect match of product and service
offerings, pricing, ESG considerations, deadlines, and the outcomes of
periodic evaluations of the Suppliers' performance. In assessing businessproposals from potential Suppliers and continue business relationship withexisting Suppliers, we focus on the following factors, which entails our key
expectations.
The key expectations include:• Superior quality at optimum price: CACTUS maintains top-notch
performance levels in meeting our customer's needs. We demand thislevel of dedication from all of our partners.
• Service: CACTUS seeks Suppliers who highly value customer service
excellence• Innovation: CACTUS prefers Suppliers who have a continuous vigor for
product and process improvement mindset.
• Ethics in doing business: It is our expectation that every Supplierconsistently follows our Supplier conduct guidelines, in both form andessence.
• ESG emphasis and adherence: We expect that our Suppliers
incorporate ESG considerations into their business and operations
activities, thereby supporting CACTUS' ESG Vision and objectives.
Some of the key expectations include:o The Supplier shall comply with all applicable regulatory
requirements and take measures to go beyond compliancerequirements by implementing good industry practices.
o The Supplier shall strengthen their focus on managing
environmental pollution and enhancing resource conservation byadopting relevant standards and practices at their operation.

© 2002—2024 Cactus Communications. All Rights Reserved4

o The Supplier shall respect human rights, and no employee of thesupplier shall suffer harassment, physical or mental punishment, orother form of abuse.
o Wages and working hours will, as a minimum, comply with allapplicable wage and hour laws, and rules and regulations, including
minimum wage and maximum hours in the country concerned.
o Suppliers shall subscribe to highest standard of ethics and integrity,transparency in their business operation.
o There shall be no use of forced or compulsory labor and employees
shall be free to leave employment after reasonable notice.
o There shall be no use of child labor, and specifically there will becompliance with relevant International Labor Organization (ILO)standards.
o The working conditions of the employees of the Suppliers will besafe and healthy and shall for Zero harm.
o The Supplier shall educate its workforce on environmental
protection, human rights, health & safety at a regular basis.
o The Supplier shall develop ESG goals and targets, conduct internal
ESG assessments to continually improve their ESG performance.
o The Supplier shall comply with the expectations set in this policy and
our Supplier’s Code of Conduct.
oThe Supplier shall disclose ESG related data to CACTUS andaccommodate CACTUS’s request for ESG assessments as andwhen requested.

5. Communication and Training
It is our commitment to ensure that this Policy is available andunderstood throughout our organization through proper
communication and there are adequate procedures available tomanage procurement practices in sustainable manner. To meet thisobjective, the following will be executed.
a. Dissemination of this Policy for new Associates shall be
carried out at the time of induction.
b. This Policy will be shared with all existing Associates andSuppliers.
© 2002—2024 Cactus Communications. All Rights Reserved5c.

This Policy will be communicated to all Suppliers, whereverpossible, at the outset of CACTUS’ business relationshipwith them or as appropriate thereafter.

6. Raising a Concern or Complaint
Complying with the Policy commitment and contributing towards
meeting the organizational goals and objectives towards
sustainable procurement practices is the responsibility of all thoseworking for or with CACTUS. You are required to avoid any activity
that might lead to or suggest a breach of this Policy.
Any person who has reason to believe that a violation of this Codeof Conduct has occurred, or may occur, must promptly report thisinformation to the Supplier Risk Assessment Committee (SRAC) bywriting to suppliergrievance@cactusglobal.com .

7. Zero Retaliation
CACTUS is committed towards no retaliation provisions towards
persons who file reports or complaints under this Policy. CACTUS
aims to prevent victimization and other retaliatory behavior towards
the person raising the complaint, so they aren’t afraid to speak up
about any issues. To ensure that this Policy is adhered to and toassure that the concerns or grievances will be acted upon seriously,
CACTUS shall ensure that:a. the person reporting under this Policy is not victimized andadequate safeguards against such victimization are provided.
b. complete confidentiality of the person reporting the concern ismaintained.
c. suitable action is taken against any person violating this Policy.

8. Monitoring and Review
CACTUS will establish appropriate measures to ensure compliance with therelevant policies, procedures, and controls. CACTUS will monitor theeffectiveness and review the implementation of this Policy regularly,
considering its suitability, adequacy, and relevance. Any improvements
identified will be made as soon as possible. CACTUS reserves the right toamend, suspend or terminate this Policy at any time, at its sole discretion,© 2002—2024 Cactus Communications. All Rights Reserved6

with or without notice.

9. Disciplinary Action
Non-compliance with this Policy by any Supplier may result in suspension ofpayment and termination of all contracts and association with them. An
Associate acting in contravention of the Code of Conduct will also facedisciplinary action up to and including summary dismissal and criminal orcivil penalties which will vary according to the offence.

© 2002—2024 Cactus Communications. All Rights Reserved© 2002—2024 Cactus Communications. All Rights Reserved

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