Supplier's Code of Conduct

1. INTRODUCTION

This Supplier’s Code of Conduct (“the Code”) sets out the minimum standards expected of all suppliers and subcontractors engaged to provide goods or services to Mogo Auto Limited (“Mogo”). The Code is issued in support of, and should be read together with, Mogo’s procurement policies, and reflects Mogo’s commitment to fair, ethical, safe, and sustainable business practices.

 

 2. REQUIREMENTS FOR ALL SUPPLIERS

These requirements apply to every supplier, and their employees (be they temporary, casual, or permanent), agents and sub-contractors, regardless of size or service type.

 

2.1. Legal and regulatory compliance

Suppliers must comply with all applicable laws and regulations, including but not limited to:

  • labor and employment regulations
  • workplace health and safety regulations
  • environmental management requirements
  • licensing and tax obligations
  • anti-corruption and financial crime legislation
  • data protection and privacy regulations

Suppliers must hold all necessary permits and approvals relevant to their operations.

 

2.2. Ethical business conduct

Suppliers must uphold high standards of integrity by:

·       upholding honesty in all interactions

·       avoiding conflicts of interest

·       maintaining accurate, transparent business and financial records

·       ensuring fair, professional business conduct

2.2.1. Anti-money laundering and sanctions compliance  

Suppliers must not engage in money laundering, terrorism financing, or transactions involving sanctioned individuals or entities, and must comply with applicable anti-money laundering and sanctions regulations.

 2.2.2. Conflict of interest disclosure

Suppliers must avoid situations that may create a conflict of interest in their dealings with Mogo and must disclose any actual or potential conflict of interest that could influence their ability to perform work impartially.

 2.2.3. Accuracy of information and documentation

Suppliers must ensure that all information, certifications, and documents submitted to Mogo are complete, accurate, and not misleading. Misrepresentation or falsification of information is prohibited.

 2.2.4. Business continuity

Suppliers must take reasonable steps to maintain continuity of operations and must inform Mogo promptly of any disruptions that could materially affect service delivery.

2.2.5. Anti-Bribery & Corruption

Suppliers must not offer, give, solicit, or accept bribes, facilitation payments, or any form of improper advantage in connection with work for Mogo. Suppliers must comply with all applicable anti-corruption laws, including Kenya’s Anti-Corruption and Economic Crimes Act.

 

2.3. Human rights and fair treatment of workers

Suppliers must respect human rights and ensure fair treatment of workers. This includes:

  • no child labor
  • no forced, bonded, or trafficked labor
  • no harassment, discrimination, or abuse
  • lawful wages, working hours, and benefits
  • respect for workers’ freedom of association

2.4. Occupational health and safety

Suppliers must provide safe and healthy working conditions by:

  • identifying and preventing workplace hazards
  • maintaining safe tools, equipment, and infrastructure
  • providing basic safety training
  • supplying appropriate personal protective equipment where required

2.5.  Environmental responsibility

Suppliers must conduct operations in a manner that protects the environment and nearby communities. Expectations include:

  • complying with environmental laws and permit requirements
  • preventing pollution and environmental harm
  • handling oils, chemicals, batteries, tires, and other hazardous materials safely and legally
  • ensuring proper waste management and disposal

2.6. Protection of confidential information and personal data

Suppliers must protect all confidential information obtained through work with Mogo and prevent unauthorized access, disclosure, or misuse. Any personal data processed during the cooperation with Mogo must be done in line with the applicable agreement or Data Processing Agreement, Mogo’s instructions, and applicable data protection legislation.

Suppliers must not collect or process personal data on behalf of Mogo unless such processing is authorized under the applicable agreement.

 

2.7. Subcontractor responsibility

Where a supplier uses subcontractors, the supplier remains fully responsible for ensuring that subcontractors adhere to the standards set out in this Code.

 

 3. GRIEVANCE MECHANISM, REPORTING, AND ISSUE RESOLUTION

Mogo maintains a grievance mechanism, including a whistleblowing system, through which concerns related to ethics, labor practices, safety, environmental matters, or other issues connected to work performed for Mogo may be raised.

Suppliers, contractors and employees who become aware of any unethical conduct (dishonesty, corruption, fraud, labour and human rights violations, environmental harm etc.) should report concerns through the following official reporting channels:

  1. Email: info@mogo.co.ke
  2. Phone / WhatsApp: +254 768 469 112
  3. Whistleblowing mechanism (including anonymous reporting): www.app.faceup.com/en-us/c/elevinggroup

All channels are available to suppliers, supplier employees, subcontractors, and affected community members. All reports will be handled confidentially. Mogo will acknowledge and review concerns in accordance with its internal procedures.

Suppliers must maintain their own internal reporting and grievance mechanisms, which remain the primary channels for workplace, employment, or operational concerns within their organization. If a matter relates to activities performed for Mogo or could affect Mogo’s obligations, reputation, or stakeholder relationships, it may also be reported through Mogo’s grievance mechanism.

Suppliers remain fully responsible for investigating and resolving issues within their operations and for implementing corrective or preventive actions where necessary. Suppliers must ensure that workers and subcontractors can raise concerns - either internally or through Mogo’s channels - without fear of retaliation.

Repeated, serious, or unresolved concerns may result in limitations, suspension, or termination of cooperation.

 

4. RESPONSIBILITY AND OVERSIGHT

Suppliers are solely responsible for ensuring compliance with this Code and with all applicable legal requirements within their operations and supply chains. Mogo does not supervise, audit, or investigate supplier operations.

Where a concern related to work performed for Mogo is brought to Mogo’s attention - whether through the grievance or whistleblowing channels or any other credible source - Mogo may request that the supplier review the matter internally and take appropriate corrective action within a reasonable timeframe. Failure to remediate serious or repeated breaches may result in Mogo limiting, suspending, or terminating the business relationship.

Responsibility for identifying, managing, and correcting non-compliance remains at all times with the supplier.

Acceptance of this Code is confirmed through the Supplier Code of Conduct Compliance and Checklist, completed during onboarding or contract signature.

 

5. MONITORING AND REVIEW

The Code is reviewed periodically to ensure its continued relevance, effectiveness, and alignment with applicable laws, regulatory requirements, and operational needs.

 

EFFECTIVE FROM: January 2026