Supplier Code of Conduct

Part 1: Introduction

Our Commitment

Montage (“Montage”, “we”, “us” or “our”) operates as an international trading company specialising in fertilizers and related commodities. Our business spans multiple continents, connecting producers with end-users through complex global supply chains.

We recognise that with this reach comes responsibility. Our reputation depends not only on the quality of our products and services but equally on how we—and those we work with—conduct business. We are committed to operating with integrity, transparency, and respect for human dignity throughout our supply chain.

Purpose and Scope

This Supplier Code of Conduct (“Code”) establishes the minimum standards we require from every organisation that provides goods or services to Montage. This includes manufacturers, producers, logistics providers, agents, distributors, contractors, consultants, and any other third party engaged in our supply chain (collectively, “Suppliers”).

The Code extends to all individuals performing work for or on behalf of a Supplier in connection with Montage’s business, whether employed directly, through agencies, or as independent contractors (“Personnel”).

By entering into any commercial arrangement with Montage, Suppliers agree to comply with this Code and to ensure that their own subcontractors and agents do the same.

Part 2: Labour Standards and Human Rights

Fundamental Principles

Montage upholds the dignity and rights of all workers. We expect Suppliers to respect internationally recognised human rights frameworks, including the principles embodied in the United Nations Guiding Principles on Business and Human Rights, the International Labour Organization’s core conventions, and the UN Global Compact.

Prohibition of Forced Labour and Human Trafficking

Suppliers shall not use any form of forced, compulsory, bonded, or trafficked labour. All work must be undertaken voluntarily, and Personnel must be free to terminate their employment with reasonable notice as provided by applicable law.

In particular, Suppliers must:

Never require Personnel to surrender identity documents, travel papers, or work permits as a condition of employment
Ensure Personnel are not required to pay recruitment fees or deposits to obtain or retain employment
Permit Personnel to leave their place of work at the end of their shift and freely exit employer-provided accommodation
Never use threats, coercion, or deception to compel work performance

Prevention of Child Labour

Suppliers shall not employ anyone below the minimum legal working age in the relevant jurisdiction, or below age 15, whichever is higher. Where young workers between 15 and 18 are lawfully employed, Suppliers must ensure they are protected from hazardous work and that their employment does not interfere with compulsory education.

Fair Wages and Working Hours

Suppliers shall pay Personnel at least the applicable legal minimum wage and provide all legally mandated benefits. Wages must be paid regularly and in full, with clear documentation provided to Personnel explaining the basis of their compensation.

Working hours, including overtime, shall comply with applicable laws and industry standards. Overtime must be voluntary and compensated at legally required rates. Personnel must receive adequate rest periods and annual leave.

Equal Treatment and Non-Discrimination

Suppliers shall foster workplaces where all Personnel are treated with dignity and respect. Employment decisions—including hiring, compensation, promotion, discipline, and termination—must be based on merit and legitimate business requirements.

Discrimination or harassment based on race, ethnicity, national origin, religion, gender, age, disability, marital status, sexual orientation, political opinion, or any other protected characteristic is strictly prohibited.

Freedom of Association

Suppliers shall respect the right of Personnel to form, join, or refrain from joining trade unions or other representative organisations of their choosing, in accordance with applicable law. Where collective bargaining is legally recognised, Suppliers shall engage constructively with worker representatives.

Workplace Conduct and Discipline

Suppliers shall maintain disciplinary procedures that are fair, transparent, and clearly communicated to all Personnel. Physical punishment, threats of violence, psychological abuse, and any form of intimidation or harassment are strictly prohibited.

Part 3: Health, Safety and Environment

Occupational Health and Safety

Suppliers shall provide a safe and healthy working environment that meets or exceeds applicable legal requirements. This includes identifying workplace hazards, implementing appropriate controls, and taking proactive measures to prevent accidents, injuries, and occupational illness.

Suppliers must:

Conduct regular risk assessments and implement effective hazard controls
Provide appropriate personal protective equipment at no cost to Personnel
Ensure Personnel receive adequate health and safety training
Maintain emergency preparedness and response procedures
Record, investigate, and address all workplace incidents

Environmental Responsibility

Suppliers shall conduct their operations in compliance with all applicable environmental laws and regulations. Beyond mere compliance, we encourage Suppliers to adopt practices that minimise environmental impact, conserve natural resources, and support sustainable development.

This includes responsible management of:

Emissions to air, water, and land
Hazardous materials and waste disposal
Energy consumption and greenhouse gas emissions
Product stewardship throughout the supply chain

Part 4: Business Ethics and Integrity

Anti-Corruption and Bribery

Suppliers shall conduct business with the highest standards of integrity. Bribery, corruption, extortion, and kickbacks are strictly prohibited, whether involving public officials or private parties.

Suppliers must comply with all applicable anti-corruption laws, including the UAE Federal Decree-Law No. 31 of 2021 on Crimes and Penalties, the UK Bribery Act, the US Foreign Corrupt Practices Act, and equivalent legislation in jurisdictions where they operate.

Gifts, entertainment, or hospitality may only be offered or accepted where they are modest in value, transparent, and consistent with local business customs. They must never be intended to improperly influence business decisions.

Conflicts of Interest

Suppliers must avoid situations where personal interests conflict, or appear to conflict, with their obligations to Montage. Any actual or potential conflict of interest must be promptly disclosed to Montage in writing.

Fair Competition

Suppliers shall compete fairly and comply with all applicable competition and antitrust laws. Price-fixing, market allocation, bid-rigging, and other anti-competitive practices are prohibited. Marketing and advertising must be truthful and not misleading.

Financial Integrity and Anti-Money Laundering

Suppliers shall maintain accurate books and records in accordance with applicable accounting standards and legal requirements. Falsification of records, fraudulent financial reporting, and any form of money laundering are strictly prohibited.

Suppliers must have appropriate controls to detect and prevent money laundering and terrorist financing, in compliance with applicable UAE and international regulations.

Trade Compliance and Sanctions

Suppliers shall comply with all applicable trade laws, export controls, customs regulations, and economic sanctions. This includes maintaining appropriate due diligence procedures to ensure goods and services are not diverted to prohibited end-users, end-uses, or destinations.

Data Protection and Confidentiality

Suppliers shall protect personal data in accordance with applicable data protection laws, including the UAE Federal Decree-Law No. 45 of 2021. Appropriate technical and organisational measures must be implemented to safeguard data against unauthorised access, disclosure, or misuse.

Confidential information shared by Montage must be protected and used only for the purposes for which it was disclosed.

Part 5: Management and Compliance

Implementation and Communication

Suppliers shall implement management systems appropriate to the size and nature of their operations to ensure compliance with this Code. The requirements of this Code should be communicated to all relevant Personnel and integrated into Supplier policies and procedures.

Supply Chain Responsibility

Suppliers are responsible for ensuring that their own suppliers, subcontractors, and agents comply with standards consistent with this Code. We expect Suppliers to conduct appropriate due diligence on their supply chains and to take corrective action where issues are identified.

Business Continuity

Suppliers shall maintain appropriate business continuity plans to ensure resilience against potential disruptions, including natural disasters, supply chain interruptions, and other unforeseen events that could affect their ability to meet obligations to Montage.

Reporting Concerns

We encourage Suppliers and their Personnel to report any concerns about potential violations of this Code or applicable laws. Reports may be made to your primary Montage contact or directly to:

Email: [email protected]

Post: Compliance Officer, Montage, Office 1302, Saba 1, Jumeirah Lake Towers, Dubai, UAE

Montage prohibits retaliation against anyone who raises concerns in good faith. All reports will be treated confidentially to the extent possible and investigated appropriately.

Verification and Audit

Montage reserves the right to verify Supplier compliance with this Code through questionnaires, documentation requests, site visits, or third-party audits. Suppliers agree to cooperate fully with any such verification activities and to provide access to relevant facilities, records, and Personnel.

Non-Compliance and Remediation

Where non-compliance with this Code is identified, Montage will work with Suppliers to understand root causes and develop appropriate corrective action plans. We are committed to supporting continuous improvement and recognise that building ethical supply chains is an ongoing process.

However, serious violations—particularly those involving forced labour, child labour, significant safety hazards, or corruption—may result in immediate termination of our commercial relationship. Montage reserves the right to terminate any arrangement with a Supplier that fails to meet the standards set out in this Code.

Document Information

Version: 1.0

Effective Date: November 2025

Owner: Montage

Review Cycle: Annual

This Code may be amended from time to time. The current version will always be available from Montage upon request.