Code of Conduct

Last modified: December 16, 2025

  • Introduction
  • Overview
  • 1. Ethical Business Conduct
  • 2. Data Privacy and Security
  • 3. Labor and Human Rights
  • 4. Health, Safety, and Well-being
  • 5. Environmental Stewardship
  • 6. Governance and Compliance
  • 7. Social Media and Brand Use
  • 8. Compliance Monitoring
  • 9. Whistleblowing Reporting
  • 10. Applicability and Updates
  • 11. Ongoing Compliance

Introduction

By accessing and using Umasenso by EmergeLocal, Inc. (“Umasenso”) is committed to the highest standards of ethics, sustainability, and corporate responsibility. We expect the same from all third-party suppliers, contractors, consultants, and vendors (“Suppliers”) who provide products and services to Umasenso. This Supplier Code of Conduct (“Code”) outlines Umasenso’s expectations and minimum standards in the areas of ethics, compliance, labor, environment, and business integrity. Suppliers are expected to adhere to this Code, comply with all applicable laws and regulations, and ensure that their own suppliers and subcontractors do the same.

Overview

The Code reflects EmergeLocal’s values and sets forth what is expected of its Suppliers with respect to the following topics:

  • Ethical Business Conduct
  • Data Privacy and Security
  • Labor and Human Rights
  • Health, Safety, and Well-being
  • Environmental Stewardship
  • Governance and Compliance
  • Social Media and Brand Use
  • Compliance Monitoring and Corrective Actions
  • Whistleblowing and Incident Reporting
  • Applicability and Updates
  • Ongoing Compliance

1. Ethical Business Conduct

1.1. Anti-Corruption and Bribery Suppliers must not engage in any form of corruption, bribery, extortion, embezzlement, or kickbacks. This includes direct or indirect offers of anything of value to obtain or retain business or an improper advantage.

1.2. Gifts and Entertainment Suppliers must avoid giving or receiving gifts, entertainment, or hospitality that could improperly influence business decisions or create a conflict of interest.

1.3. Conflicts of Interest Suppliers must disclose any actual or potential conflicts of interest, including any personal relationships with Umasenso employees that could affect impartiality.

2. Data Privacy and Security


2.1. Confidentiality Suppliers must protect confidential information belonging to Umasenso, its clients, and employees. This includes both proprietary information and personal data.

2.2. Data Protection Suppliers must comply with all applicable data protection and cybersecurity laws, including the Philippine Data Privacy Act of 2012 (R.A. 10173), its Implementing Rules and Regulations, and National Privacy Commission issuances. If processing personal data on behalf of Umasenso, the Supplier shall implement reasonable and appropriate organizational, physical, and technical security measures, aligned with best practices and industry standards such as ISO 27001, SOC 2, or NIST Cybersecurity Framework (CSF).

3. Labor and Human Rights

Umasenso is committed to respecting human rights in all aspects of its operations and expects the same from its Suppliers.

3.1. No Forced or Child Labor Suppliers must not use any form of forced, bonded, indentured, or involuntary labor. Child labor is strictly prohibited in any stage of operations.

3.2. Fair Working Conditions Suppliers must comply with applicable wage, benefit, and working hours laws and provide employees with written employment agreements where required.

3.3. Non-Discrimination and Inclusion Suppliers must not discriminate based on race, color, gender, sexual orientation, religion, age, disability, marital status, or any other protected characteristic.

3.4. Freedom of Association Suppliers must respect workers’ rights to freely associate, organize, and bargain collectively in accordance with applicable laws.

4. Health, Safety, and Well-being

Suppliers must provide a safe and healthy working environment for all workers, including proactive health and safety management systems to prevent accidents and occupational illnesses.

5. Environmental Stewardship

Suppliers must operate in an environmentally responsible and resource-efficient manner, complying with all environmental laws and regulations. This includes compliance with the Philippine Environmental Impact Statement (EIS) System, DENR Administrative Orders, LGU ordinances, and other applicable rules on pollution control, waste management, and environmental permitting.

Efforts to reduce energy consumption, manage waste, and minimize carbon emissions are also encouraged.

6. Governance and Compliance

6.1. Compliance with Laws Suppliers must comply with all applicable national and local laws, rules, and regulations in the countries where they operate.

6.2. Anti-Fraud and Accurate Reporting All financial records, reports, and submissions must be accurate and reflect the true nature of the transactions.

6.3. Subcontracting Suppliers shall not subcontract any part of their obligations without prior written consent from Umasenso. Any approved subcontractors must comply with the same obligations under this Code.

7. Social Media and Brand Use

Suppliers must not make public statements on behalf of Umasenso or use its name, trademarks, or branding without prior written permission. Responsible and respectful conduct is expected when referring to Umasenso on any platform. This includes but is not limited to press releases, case studies, marketing materials, or any form of promotional content referring to Umasenso as a client, without explicit approval.

8. Compliance Monitoring and Corrective Actions

Umasenso reserves the right to assess Suppliers’ compliance through audits, self-assessments, or documentation requests. In cases of non-compliance, Umasenso may request corrective actions or terminate the relationship for material breaches.

9. Whistleblowing and Incident Reporting

Umasenso is committed to maintaining a culture of integrity, transparency, and accountability. To support this commitment, we provide clear channels for reporting actual or suspected violations of company policies, applicable laws, or this Supplier Code of Conduct.

9.1. Scope This policy applies to all Umasenso employees, Suppliers, contractors, and third-party stakeholders. Concerns may include, but are not limited to:

  • Fraud, bribery, or corruption
  • Labor or human rights violations
  • Health, safety, and environmental issues
  • Data privacy or information security breaches
  • Unethical business practices
  • Any violation of applicable law or Umasenso policies

9.2. Reporting Channels Reports may be submitted confidentially via the following: Umasenso maintains a single point of contact (sirt@umasenso.com) for receiving and responding to all incident reports. Security or data privacy incidents affecting Umasenso must be reported within 24 hours of discovery, along with a preliminary assessment and mitigation plan.

9.3. Confidentiality and Non-Retaliation Umasenso ensures that all reports will be handled with strict confidentiality and in accordance with applicable laws. Retaliation against individuals who, in good faith, report a concern or participate in an investigation is strictly prohibited.

10. Applicability and Updates

This Code is not intended to override any applicable laws or contractual terms between Umasenso and the Supplier. Umasenso may revise this Code from time to time and expects Suppliers to stay informed of updates.

11. Ongoing Compliance

Umasenso may request Suppliers to submit an annual attestation confirming continued adherence to this Code. Suppliers must cooperate with periodic audits or compliance reviews, including the submission of relevant documentation when requested.