Supplier Code of Conduct (“Supplier Code”)

Accelonix Limited

Policy Statement

This Supplier Code is relevant to all suppliers of Accelonix and its subsidiaries and affiliates. For the avoidance of doubt, suppliers include contractors, subcontractors, agents, distributors, reps, consultants and advisors and any other similar relationships.

The overarching document between both parties is the contractual agreement but this Supplier Code should serve as a supplementary document. The Accelonix Supplier Code serves as a guide for compliance by the Accelonix supply chain with a set of established principles of actions and values. These principles and policies define who we are, how we work, and what we stand for. They also tell us what we expect of ourselves and all who work with us in our supply chain. In summary, at Accelonix we believe in doing the right thing above all else and we expect our suppliers to do the same.

Our Supplier Code

We expect our suppliers to work to a standard which is equivalent to, and at least as high as, the standard that we, ourselves, operate to. Suppliers must comply with all applicable laws and regulations and require all its employees to conduct business in accordance with the law.

We, at Accelonix, are dedicated to strengthening our strong reputation as a trustworthy and dependable partner to our customers and suppliers. Through the establishment of a Supplier Code of Conduct, we seek to embody the conscientious, honest, and considered approach that defines our business dealings. Our commitment extends to remaining attentive to the evolving commercial environment, ensuring our policies are responsive and thoughtfully crafted to address emerging challenges whether they be regulatory, legal, environmental or ethical. We expect our suppliers, wherever they operate, to uphold these same high standards.

The objective of this document is to provide an overview of the areas suppliers must be compliant with and to:

  1. Establish guidelines for action and behaviours;
  2. Define a reference framework of mandatory compliance; and,
  3. Create rules of conduct for stakeholders that are related in any way to Accelonix.

Any supplier who does not comply with these standards, laws and regulations will have appropriate action taken against them and/or the employing company. Should any proven breach of the Supplier Code be criminal, we will support the appropriate authorities in their prosecutions of those involved. Customs or local practices never take precedence over legal requirements. If you find that our Supplier Code is in conflict with applicable legal requirements, you should inform your Accelonix representative immediately.

Our mission

Our mission is to keep our customers one step ahead of their competitors, positioning them to meet the ever-increasing demands placed on them by the industry in which they operate.

With over 30 years working within the electronics industry, we achieve this though:

  • Continuously searching for more effective solutions for our customers and new market opportunities for our suppliers;
  • Maintaining a strong in-house technical capability to understand and support our customer’s needs throughout the lifetime of a project;
  • Delivering tailored, innovative, fully integrated product and service solutions;
  • Using group synergies to deliver the most effective breadth and depth of resource to all our customers; and,
  • Being a professional, reliable, responsible partner on whom our customers can depend.

Our vision

Our vision is to build a dynamic brand, strong enough to:

  • Attract and retain the leading suppliers in our chosen markets within every territory we choose to operate; and,
  • Establish long term relationships with the most discerning of customers in our target markets, wherever they are located around the globe.

Keynote message

To our employees, Accelonix will

  • Give you the ability to grow and develop
  • Enable you to take ownership
  • Support you so you can effectively deliver the Accelonix Brand

To our customers, Accelonix will

  • Have your interests at heart
  • Do all in our power to support you correctly
  • Be a continuing presence

To our suppliers, Accelonix will

  • Work together to enhance your market position
  • Support your products professionally
  • Be your long-term partner

Procurement – selecting the right supplier

Remaining alert and attentive to emerging and evolving technologies is central to the approach we take to selecting the right supplier and technology for our business. By actively networking and forging strong relationships within the industry, we deepen our understanding of the business landscape and identify developing trends. This enables us to recognise gaps in our product portfolio and ensures we are strategically positioned to collaborate with market-leading manufacturers as new opportunities present themselves. Such vigilance and adaptability are key to maintaining Accelonix’s reputation for proactive, forward-thinking procurement and partnership development.

We work with prospective suppliers to assess the needs of the business and the requirements for selection – always a two way process – ensuring technology and company compatibility. In this process we strive to be impartial, fair, and transparent to all involved.

Audit

Accelonix reserves the right to monitor and audit each supplier’s compliance with our Supplier Code. Accordingly, you must cooperate by providing relevant information that we request, and by making individuals accessible so Accelonix can conduct a meaningful audit. Similarly, you are required to evaluate your supply chain to ensure compliance with our Supplier Code. Any non-compliance by you or your supply chain must be effectively remedied both in a timely manner and at no additional cost to us or our customers. Breaches of the Supplier Code may negatively impact your business relationship with Accelonix. Potential consequences may include but are not limited to contract termination.

Our Policies

We expect all suppliers to adhere to all of the following legislative and best practice requirements.

a. Anti-bribery and corruption

With reference to Section 7 of the UK Bribery Act 2010, Accelonix is committed to and believes in conducting business to the highest possible standards.

We do not tolerate, permit, or engage in bribery, corruption, or improper payments of any kind in our business dealings, both with public officials and people in the private sector. This applies to our operations anywhere in the world and wherever business is operated on our behalf by an applicable partner or associate.

In support of this statement our Senior Leadership Team has the responsibility for monitoring and reporting all activities covered within this statement.

We are committed to the following principles:

  • We will carry out business fairly, honestly, and openly;
  • We will not give or offer any money, gift, hospitality, or other advantage to any person carrying out a business or public role, or to a third party associated with that person, to induce them to do something improper;
  • We will not give or offer any money, gift, hospitality, or other advantage to any public official or third party connected to a public official with the intention of influencing the public official to our business advantage;
  • We do not allow employees to accept money, gifts, hospitality, and/or other advantages from business associates, actual or potential suppliers, service providers or business partners which are intended to influence a business decision or transaction in some improper way;
  • Any employee found to be in breach of this statement will face disciplinary action;
  • No employee will suffer demotion, penalty, or other adverse consequence for refusing to pay bribes, even if it may result in us losing business;
  • We will avoid doing business with others who do not commit to doing business without bribery; and,
  • We are committed to counter the risk of us being involved in bribery.

All employees are individually accountable to conduct our business with integrity and to recognise and report issues of concern and to undertake our business in an honest, fair, and legally compliant manner at all times.

This statement will be communicated to employees and reinforced through periodic communication, induction, and training where appropriate.

We request of our Suppliers and Customers, where appropriate, to complete an Anti-Bribery Statement and we ask companies to regularly affirm their commitment to Anti-Bribery to ensure we continue to work only with those who share our commitment to lawful business.

This statement highlights our integrity in conducting ethical business interactions that meet – in spirit and letter – of what is right, how we conduct day to day business and what we value as an organisation.

We treat this subject very seriously and to underline this commitment the Senior Leadership Team is the responsible champion for driving all aspects of this compliance.

b. Anti-tax evasion

It is our policy to conduct all of our business in an honest and ethical manner. We have a zero tolerance approach to all forms of tax evasion, whether under UK law or the law of any foreign country and are committed to implementing and enforcing effective systems to counter tax evasion facilitation. We expect our suppliers to comply with all applicable laws, regulations, codes and sanctions relating to the prevention of tax evasion facilitation including the Criminal Finances Act 2017. In performing its obligations under any contractual agreement, the supplier shall:

  • Comply with the legislative and best practice requirements and have and maintain its own procedures to ensure its compliance and to reasonably prevent the facilitation of tax evasion;
  • Not engage in any activity or conduct which would constitute a UK or foreign tax evasion facilitation offence under section 45(1) or 46(1) of the Criminal Finances Act 2017; and,
  • Report any breaches or suspected breaches to Accelonix at the earliest possible opportunity at sales@accelonix.co.uk, or directly to the Managing Director.

c. Anti-money laundering and Counter-Terrorist financing

Accelonix is committed to conducting its business with integrity and in compliance with applicable UK anti-money laundering (AML) and counter-terrorist financing (CTF) legislation.

Accelonix does not knowingly engage in, facilitate, or support money laundering or terrorist financing and by placing, accepting, processing, or fulfilling any order, or otherwise continuing to transact with us, counterparties confirm their acceptance of and agreement to comply with this policy, without the need for signature. Compliance to this policy is a condition of doing business with us.

We apply a proportionate, risk-based approach to AML and CTF that reflects the size, nature, and complexity of our operations and consequently, do not operate continuous or proactive monitoring of counterparties or transactions. Controls are applied in a reasonable and practical manner, consistent with our resources and risk profile.

Accelonix does not routinely conduct formal due diligence checks and does not actively monitor transactions for money laundering or terrorist financing indicators. Suppliers remain responsible for conducting any due diligence required under their own jurisdictional obligations.Where information comes to our attention that gives rise to a reasonable concern or suspicion in relation to money laundering or terrorist financing, we may take appropriate and proportionate steps, which may include requesting clarification or declining to proceed with a transaction.

Suppliers must not use transactions with Accelonix to facilitate money laundering, terrorist financing, or the concealment or transfer of criminal property, or provide false or misleading information in connection with business activities. Any such conduct may result in refusal or termination of the business relationship. Where we know or reasonably suspect that money laundering or terrorist financing may be taking place, we will act in accordance with our legal obligations under UK law.

Accelonix maintains such commercial records as are ordinarily kept in the normal course of business. Records are retained in accordance with legal and accounting requirements.

Failure to comply with this policy may result in the refusal, suspension, or termination of business relationships, and any other action required to comply with applicable law.

This policy may be reviewed and updated periodically to reflect changes in legislation, guidance, or Accelonix’s operations.

This policy is governed by and construed in accordance with the laws of England and Wales.

d. Modern slavery and human rights

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slaver, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

Although Accelonix is a company of size and concern lower than that legally obliged to publish an annual statement relating to section 51(1) of the Modern Slavery Act 2015, we have a zero-tolerance approach, and are committed to act ethically and with integrity in all our business dealings and relationships. We are committed to transparency in our business practices, to implement and enforce effective systems and controls to ensure, as best we can, that slavery is not taking place anywhere in our business or supply chain.

By placing, accepting, processing, or fulfilling any order, or otherwise continuing to transact with us, counterparties confirm their acceptance to maintain the same, or higher (for instance, where there is a legal obligation under the Modern Slavery Act 2015 or associated laws and regulations) standards – in spirit and letter – without the need for signature. Compliance to this policy is a condition of doing business with us.

We do not engage in slavery, forced labour, child labour, abusive disciplinary practices, or human trafficking, and we subsequently expect the same standards from our suppliers. Accelonix reserves the right to terminate business relationships with whoever fails to abide by this requirement.

If you believe or suspect that a conflict with this statement has occurred or may occur in the future, then you must report any concern, or any query, to Accelonix at the earliest possible opportunity at sales@accelonix.co.uk, or directly to the Managing Director.

The prevention, detection, and reporting of modern slavery in any part of our business or supply chain is the responsibility of all those working for us. All employees are required to avoid any activity that might lead to, or suggest, a breach of this statement. The Senior Leadership Team are responsible for communicating this policy to our employees and maintaining open communication channels for reporting. Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors, and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

We request of our suppliers to complete a Modern Slavery and Human Trafficking Statement (or similar, as appropriate) and we ask companies to regularly affirm their commitment to ensure we continue to work only with those who share our commitment to lawful business.

This statement highlights our integrity in conducting ethical business interactions that meet with both the spirit and letter of what is right, how we conduct day to day business and what we value as an organisation. 

e. Equal Opportunities and Diversity

Accelonix is committed to promoting equality, dignity, and respect in all working relationships. We expect every supplier in our supply chain to uphold these same high standards.

To ensure a safe, supportive, and inclusive working environment, it is important that:

  • An inclusive culture is actively embraced and promoted, ensuring fairness, respect, and equal treatment for all individuals;
  • Equal opportunities are upheld for all employees and potential employees, irrespective of age, disability, gender reassignment, marriage or civil partnership, pregnancy or maternity, race, religion or belief, sex, sexual orientation, nationality, or social background, in line with the Equality Act 2010;
  • The personal dignity, privacy, and rights of every individual are respected, with working relationships conducted professionally and ethically at all times;
  • No one within our supply chain tolerates unlawful or unacceptable treatment, including discrimination, harassment, bullying, victimisation, mental cruelty, or conduct that creates an intimidating, hostile, degrading, humiliating, or offensive environment. This includes sexual harassment or any unwanted conduct of a sexual nature.

Suppliers must ensure that their own employees, agents, contractors, and representatives behave in a manner consistent with these principles and that appropriate standards, policies, and training are in place to prevent discrimination, harassment, and victimisation.

f. Competition compliance

Accelonix is committed to conducting its business activities in a fair and open manner at all times and in compliance with all applicable competition laws, rules and regulations and expects the same conduct from its supply chain.

Suppliers must not make any formal or informal agreements or formal or informal discussions with competitors regarding prices or pricing policies, allocating customers, supplier or customer selection or classifications, or allocating markets or territories in which competitive products are sold, customer or supplier boycotts, excluding competitors from the marketplace, or unfairly restricting trade or any other similar competitive information.

g. Health & Safety

Accelonix is committed to providing a place of work free from harm, by preventing injury and ill health, where everyone goes home safe every day. The safety of our employees and partners comes first. We do everything safely and responsibly, or not at all. Accelonix implements robust occupational health and safety management systems, adopting best practices and engaging in continuous improvement.

We expect our suppliers to follow suit and provide a safe, healthy and secure working environment for their employees, contractors, customers and anyone who may be affected by their activities.

h. Environmental

Accelonix is committed to minimising its environmental impact and promoting an environmentally responsible culture across all areas of our business. We expect every supplier in our supply chain to uphold these same high standards.

To support this commitment, it is important that:

  • Environmental responsibility is actively embraced and promoted, ensuring that operations are conducted in a way that protects the environment, prevents pollution, and minimises adverse impacts on people, communities, and natural resources.
  • Suppliers comply with all applicable environmental laws, regulations, standards, and statutory obligations, and ensure that appropriate processes, controls, and records are maintained to demonstrate such compliance where required. This includes compliance ‘in letter and spirit’ with relevant legislation.
  • Waste is minimised wherever possible, with suppliers taking reasonable and practical steps to reduce, reuse, and recycle materials, and to avoid unnecessary consumption or waste generation.
  • Products and services supplied to Accelonix are fit for purpose, supporting resource efficiency and avoiding unnecessary manufacturing or environmental burden.
  • Suppliers promote environmental awareness within their own workforce, ensuring employees, contractors, and representatives understand their responsibilities for protecting the environment and contributing to sustainable operations.

Suppliers must ensure that their activities, and those of any subcontractors or representatives, are conducted in a manner that reflects Accelonix’s environmental values and supports our shared commitment to responsible, sustainable business practices.

i. Data Protection and Information Security

It is essential to Accelonix that all suppliers protect any sensitive or personal data to which they have access in the course of providing goods or services. This includes safeguarding any Accelonix information, as well as the systems, equipment, and assets used to process or store such data.

All suppliers, contractors, and service providers — including cloud service providers — that process data on behalf of Accelonix act as Data Processors and must comply with the UK General Data Protection Regulation (“UK GDPR”), the Data Protection Act 2018, and any other applicable data protection or privacy laws.

Suppliers must have information security and data protection policies that are equivalent to, or more comprehensive than, those implemented by Accelonix. These policies must ensure that any personal or sensitive data handled on our behalf is protected at all times.

All personal data and sensitive information must:

  • Be processed lawfully, fairly, and transparently, and only for the specific, legitimate purpose for which it was shared.
  • Be accurate and kept up to date, with appropriate measures to correct inaccuracies without delay.
  • Not be altered, manipulated, or used for any secondary purpose without explicit written authorisation from Accelonix.
  • Not be disclosed to any employee, representative, third party, or subcontractor unless they are directly involved in the contracted work and have been authorised by Accelonix.
  • Be handled in accordance with individuals’ data protection rights, including rights of access, rectification, restriction, and erasure where applicable.
  • Be protected through appropriate technical and organisational measures, including recognised standards of information security, to prevent unauthorised access, loss, destruction, or damage.
  • Be processed in compliance with UK GDPR requirements, including obligations relating to breach notifications, data protection impact assessments, and, where applicable, consultation with supervisory authorities.

If a supplier becomes aware of, suspects, or has reason to believe that a Personal Data Breach has occurred — whether actual or potential — they must notify Accelonix immediately at sales@accelonix.co.uk, and must also inform the Managing Director without delay. Suppliers must cooperate fully with Accelonix in investigating, containing, and remedying any such incident.

If suppliers require further information or clarification on their data protection responsibilities, they should contact Accelonix at sales@accelonix.co.uk. Our full policy can be found at:  www.accelonix.co.uk/privacy-policy/

j. Declaration of Interest

Refers to any personal connection to a person or group within the supply chain that could potentially lead to accusations of unfair practice. Our suppliers should avoid any relationship, influence or activity that might impair their ability to make fair and objective decisions when performing their job. If a supplier believes there is, or may be, an actual or perceived conflict of interest, we expect them to disclose it to Accelonix and all other affected parties, as soon as possible.

It is recommended that our Managing Director is regarded as the first point of contact should a declaration need to be made.

k. Export and trade compliance

Our suppliers must comply with all applicable laws and regulations concerning export licences and consents including imports in connection with any goods and services transactions for military, dual or commercial use. Suppliers are expected to understand any sanctions, import and export control requirements relating to their work, and ensure decisions and activities comply with those requirements.

l. Counterfeit parts

Our suppliers should use the best quality goods, materials, standards and techniques, and ensure that all goods and materials supplied, used or transferred to Accelonix will be free from defects in workmanship, installation and design, as well as free of second hand, counterfeit and/or replica parts.

Approved by: Scott Wood, Managing Director, on 10 February 2026

Effective date: February 2026