Supplier Code of Conduct

Toloka AI BV (the “Company”) is committed to conducting business fairly and with integrity.  We expect the same of our business partners. We seek to award business to partners who share similar corporate values to the Company, who have adopted and promote the implementation of our or equivalent business principles as set out in this Supplier Code of Conduct, and who observe the applicable legislation and other regulations of the countries in which they operate.

It is the responsibility of our business partners to maintain and enforce compliance within their supply chains. Failure to comply with internationally recognized standards and the standards set out in this Code of Conduct may result in the termination of the partner’s contract and relationship with the Company.

1. Conduct Business with Integrity

Laws and regulations: comply with applicable laws and regulations.

  • Antitrust and competition: adhere to the principle of free enterprise and comply with antitrust and competition law in the countries in which they operate.

  • Bribery and corruption: conduct their business free from any form of bribery, corruption, fraud, extortion, payment facilitation, gifts, entertainment, or other tangible or intangible methods of bribery.

  • Conflicts of interest: disclose and address any potential or confirmed conflict of interest.

  • Confidential information & insider trading: maintain the confidentiality of information entrusted to them and not disclose this information for use on any insider deals.

  • Intellectual property: not to use Company intellectual property (including software products, databases, patented solutions, trademarks, and logos) without prior written permission. While doing business with the Company, business partners must avoid the unauthorized use of the intellectual property of third parties.

  • Data Privacy: protect the privacy of individuals and the security of confidential assets and information in compliance with all applicable local laws; and use, access and disclose personal information only for the purpose for which it was provided.

  • Sanctions & export controls: comply with applicable sanctions laws and not provide the Company with goods or services subject to national or international export control regulations.

  • Money laundering: fully and accurately document all business and commercial operations and reflect this in accounting reports in accordance with applicable laws, and not be involved in money laundering or the facilitation thereof.

* Business Partners include suppliers, distributors, agents, resellers and other third parties in our supply chain.

* Business Partners include suppliers, distributors, agents, resellers and other third parties in our supply chain.

2. Respect Human Rights

Discrimination and anti-harassment: treat all people with respect and provide a workplace free of harassment or abuse of any kind, unlawful practices or discrimination. Employees should be hired based only on their ability to do their job.

  • Diversity and inclusion: foster an inclusive culture and ensure that employees and other stakeholders are treated with dignity and respect.

  • Forced or child labour: Not use illegal child labour and employ only people above the legal age for employment. Not tolerate any forms of forced labor or slavery as defined in national legislation and/or applicable international documents such as the International Labour Organization’s Forced Labor Convention.

  • Freedom of association: respect freedom of association and collective bargaining rights in accordance with applicable laws and regulations.

  • Health and safety: provide a safe and healthy working environment in compliance with local, national and international standards.

  • Fair working conditions: ensure fair working conditions in accordance with local wage and labour laws, and ensure compensation at the living wage level according to local living conditions.

3. Be Environmentally Responsible

Comply with environmental laws: comply with all applicable environmental laws and regulations and promote sustainable best business practices.

  • Responsible handling of resources: have processes and policies in place to optimize resource usage, covering energy, water, and other materials, and prevent the accidental release of hazardous materials into the environment and adverse environmental impacts on the local community.

  • Sustainable business operations: operate ethically and consider the environment when making business decisions. The Company encourages business partners to develop and use environmentally friendly technologies, products, and services. 

3. Categories of personal data processed by Toloka

The table below sets out the categories of personal data Toloka collects and processes. Toloka collects personal data primarily from the data subjects themselves (e.g., Your contact requests through the Toloka Platform). In addition, personal data may also be obtained from third parties as listed in the table below. Please use a horizontal scroll to navigate across the table.

Contact Information

Toloka AI BV 

Ethics & Compliance, Gustav Mahlerlaan 300, 1082MA Amsterdam, The Netherlands

Content Owner

Ethics & Compliance

Effective Date

23 May 2024

Version

V1.0

Replaces

This Supplier Code of Conduct supersedes any previous Supplier Code of Conduct within the Company.

Review and amendment

This Policy is periodically reviewed and approved by the Board as revisions may be required due to changes in law or regulations or changes in our business/environment.

What is the foundation for the Supplier Code of Conduct?

The Supplier Code of Conduct is based on the Company Code of Conduct. We expect our business partners and their employees to demonstrate the same level of commitment as we do. This Code and the Company Code of Conduct are based on the principles set out in applicable laws and the following international documents:

Universal Declaration of Human Rights,
United Nations GuidingPrinciples on Business and Human Rights,
ILO Conventions,
Principles of the UN Global Compact

What if local law differs from the Code?

The Code is leading, but where local laws or regulations are stricter than the Code, then those local laws or regulations prevail.

Will we confirm compliance with this Code?

We trust the assurance provided by our business partners that they share the principles of business conduct set out in this Code. While public company information may provide some information,   Toloka AI BV reserves the right to implement audit procedures. The audit, its scope, and other details shall be agreed with the business partner in advance.

How do I report a suspect violation of the Code?

Any breach or concern relating to this Code should be reported to your Company relationship manager immediately.

Should you wish to remain anonymous, you may also contact our independent Speak Up service operated by Ethicspoint and available 24/7.

we-speakup.ethicspoint.com