1.1 Digital Matter upholds the highest standards of environmental stewardship, social responsibility, and ethical governance. This ESG Policy
sets out our global principles and commitments to sustainable, ethical, and lawful business practices, applied consistently across our
operations, supply chain, and commercial relationships.
1.2 This policy reinforces our dedication to compliance with applicable environmental, labour, trade, human rights, and corporate
governance laws, as well as alignment with recognised international principles and best practice frameworks.
1.3 This policy should be read together with Digital Matter’s Anti-Bribery and Corruption (ABC) Policy, Conflict Minerals Statement,
Whistleblower Policy, and any other applicable corporate policies, standards, and procedures.
3.1 This policy applies to:
3.2 By engaging with, conducting business for and/or on behalf of, supplying goods and/or services to, and/or otherwise entering into any contractual and/or commercial relationship with Digital Matter, all persons/entities described in clause 3.1.1 are deemed to have read, understood, and accepted the terms of this policy. Such acceptance shall be both express and/or tacit, and shall bind such a person/entity to comply with this policy unconditionally, for the duration of their relationship with Digital Matter.
3.3 Where this policy conflicts with an applicable local law and/or a binding contract, the more stringent requirement shall apply, provided
it is lawful to do so.
4.1 Conflict Minerals, shall mean minerals as referenced in Digital Matter’s Conflict Minerals Statement (including, but not limited to, tin,
tantalum, tungsten, and gold) originating from conflict-affected and/or high-risk areas.
4.2 Counterfeit Parts, shall mean any product, component, and/or material whose origin, performance, and/or compliance is
misrepresented, including items that are mislabelled, unlawfully altered, or otherwise presented as genuine when they are not.
4.3 ESG, shall mean Environmental, Social, and Governance principles guiding responsible and ethical corporate conduct.
4.4 ILO Core Conventions, shall mean and collectively refers to eight fundamental conventions adopted by the International Labour
Organization, namely Forced Labour Convention, 1930 (No. 29), Freedom of Association and Protection of the Right to Organise
Convention, 1948 (No. 87), Right to Organise and Collective Bargaining Convention, 1949 (No. 98), Equal Remuneration Convention,
1951 (No. 100), Abolition of Forced Labour Convention, 1957 (No. 105), Discrimination (Employment and Occupation) Convention, 1958
(No. 111), Minimum Age Convention, 1973 (No. 138), Worst Forms of Child Labour Convention, 1999 (No. 182).
4.5 Modern Slavery, shall encompass slavery, servitude, forced or compulsory labour, human trafficking, and child labour.
4.6 Prohibited End Use/User, shall mean any product use, recipient, and/or application that breaches applicable export control, sanctions, or trade restriction laws, and/or that involves sensitive and/or high-risk use cases such as military applications, surveillance of individuals, and/or other activities contrary to applicable law and/or Digital Matter’s ethical standards.
4.7 UN Guiding Principles on Business and Human Rights, shall mean the "Guiding Principles on Business and Human Rights: Implementing the United Nations ‘Protect, Respect and Remedy’ Framework", as endorsed by the UN Human Rights Council in its resolution 17/4 of 16 June 2011.
5.1 Digital Matter complies with applicable national, regional, and/or international laws, including those governing environmental
protection, labour, trade, competition, export controls, sanctions, human rights, and corporate governance.
5.2 All persons/entities bound by this policy must comply with applicable laws in the jurisdictions in which they operate and/or in which
Digital Matter conducts business.
6.1 Digital Matter upholds, supports and applies the UN Guiding Principles on Business and Human Rights and the ILO Core Conventions.
6.2 Digital Matter prohibits all forms of Modern Slavery and requires fair, safe, and humane working conditions across its operations and supply chain.
6.3 Suppliers and/or partners must:7.1 Digital Matter maintains a safe and healthy workplace in compliance with applicable occupational health and safety laws.
7.2 Measures include, but are not limited to, hazard identification, risk assessments, appropriate personal protective equipment (PPE), training, incident reporting, and regular safety inspections.
7.3 Facilities under Digital Matter’s control and/or those of its manufacturing partners must be clean, sanitary, and maintained to applicable
standards.
8.1 Digital Matter commits to minimising environmental impact and promoting sustainable practices throughout its value chain.
8.2 Digital Matter shall:9.1 All operations must actively prevent pollution and/or optimise resource use.
9.2 Measures include, where applicable, reducing hazardous substances, avoiding unnecessary emissions, promoting recycled and/or recyclable materials, and engaging suppliers who demonstrate sustainable sourcing practices.
10.1 Digital Matter shall, as required, maintain accurate environmental records and/or reports and shall obtain, maintain, and/or renew any necessary environmental permits.
10.2 Where appropriate, Digital Matter may publicly disclose relevant sustainability metrics and/or improvement initiatives.
11.1 Digital Matter sources materials responsibly and in accordance with its Conflict Minerals Statement.
11.2 Suppliers must, upon request, disclose the origin of materials and/or components and take reasonable steps to ensure supply chains are free from Conflict Minerals, where possible and at all times in line with Digital Matter’s Conflicts Mineral Statement.
12.1 Digital Matter prohibits the use and/or supply of Counterfeit Parts in any Digital Matter product.
12.2 Measures of prevention include supplier verification, serialisation and/or unique device identification, tamper-evident controls, and appropriate quality assurance testing.
12.3 Digital Matter reserves the right to audit and/or verify compliance and/or to reject and/or quarantine suspected Counterfeit Parts.
13.1 Digital Matter enforces a zero-tolerance approach to bribery, corruption, and/or unethical conduct.
13.2 All persons/entities bound by this policy must comply with Digital Matter’s Anti-Bribery and Corruption (ABC) Policy.
13.3 Insider trading and/or misuse of confidential and/or non-public information is prohibited.
13.4 Digital Matter will comply with applicable competition and/or antitrust laws and expects the same of its partners.
14.1 Digital Matter complies with applicable export control and/or sanctions laws and/or regulations, including those of Australia, the United States, the United Kingdom, the European Union, and/or the United Nations, where applicable.
14.2 Digital Matter reserves the right, in its sole and/or absolute discretion, to refuse and/or restrict supply to certain individuals, entities,
jurisdictions, and/or for certain uses (including Prohibited End Uses/Users), and to require end-use and/or end-user screening and/or
certifications.
15.1 Digital Matter protects personal and/or confidential information and operates information security controls aligned to ISO27001.
15.2 All persons/entities bound by this policy must comply with applicable data protection and/or privacy laws, contractual confidentiality
obligations, and Digital Matter’s information security standards.
16.1 All third-party relationships, including, but not limited to, agents, resellers, manufacturers, and/or suppliers, must be subject to proportionate risk-based due diligence before engagement.
16.2 Such third parties must meet compliance standards no less stringent than those set out in this policy, ABC Policy, and/or the Conflicts Mineral Statement, and must flow down equivalent requirements to their sub-suppliers and/or subcontractors.
16.3 Digital Matter reserves the right to audit and/or verify compliance and to require remediation, suspension, and/or termination for noncompliance.
17.1 All persons/entities bound by this policy must maintain accurate, complete, and transparent records demonstrating compliance with this policy.
17.2 Records must be made available for inspection upon lawful request, subject to applicable confidentiality and/or data protection obligations.
18.1 Digital Matter may, at its sole and absolute discretion, offer ESG-related training and/or guidance to persons/entities bound by this policy.
18.2 Such training may include awareness of relevant laws, recognising risks and/or improper conduct, and/or understanding reporting procedures.
19.1 A breach of this policy shall be considered a serious violation of applicable contractual terms and/or standards and may result in suspension and/or termination of the contractual relationship, suspension or dismissal of an employee, legal action, and/or necessary regulatory reporting.
19.2 Persons/entities bound by this policy, whether during and/or after the contractual relationship, must promptly report any suspected and/or actual breach, and/or any concern relating to environmental, social, human rights, ethical conduct, export controls/sanctions, and/or supply chain integrity.
19.3 Reports can be made to:19.4 Retaliation, victimisation, and/or any adverse treatment against a whistleblower is strictly prohibited.
19.5 All whistleblowers shall be protected in accordance with Digital Matter’s Whistleblower Policy, applicable statutory protections and/or any national whistleblower legislation in the jurisdiction concerned.
19.6 All reports will be acknowledged within five (5) business days, and an initial assessment will be conducted to determine scope, urgency, and/or risk.
19.7 Where appropriate, a formal investigation will be initiated; all persons are required to cooperate fully.
19.8 Investigations may include interviews, document review, and/or forensic analysis; findings will be documented and, where legally permissible, a summary outcome will be communicated to the reporter.
19.9 Corrective actions may include remediation, disciplinary measures, contract termination, recovery of losses, and/or referral to competent authorities.
19.10 Records of reports and/or investigations will be retained in accordance with applicable data retention requirements.
20.1 Without limiting any other rights or remedies available under law, contract, and/or equity, Digital Matter reserves the right, in its sole and/or absolute discretion, to take any lawful action, implement any measure, and/or exercise any contractual and/or statutory right necessary to enforce this policy, prevent harm, protect operations, and/or safeguard its name, goodwill, and/or reputation.
21.1 This policy shall be governed by, and construed in accordance with, the laws of Western Australia, without its conflicts of law principles.
21.2 All disputes arising from and/or in connection with this policy shall be subject to the non-exclusive jurisdiction of the courts of Western Australia, and/or any other court of competent jurisdiction in any territory in which Digital Matter maintains an office, branch, and/or principal place of business, without prejudice to enforcement in any such jurisdiction.
22.1 This policy shall be reviewed periodically and/or may be amended at any time to ensure continued compliance with applicable laws, regulations, and/or best practice standards.
22.2 The most current version of this policy shall be made available on Digital Matter’s official website, or such other publicly accessible location as determined by Digital Matter from time to time. It is the responsibility of all persons/entities bound by this policy to review the then-current version prior to engaging with Digital Matter, as envisaged in 3. Any continued or renewed engagement with Digital Matter after the publication of any amendments, shall constitute conclusive acceptance of the most recent version of this policy.