Code of Conduct
1. Introduction
Aira Group AB's and its subsidiaries’ (jointly, “Aira” or “we”) mission is to deliver clean energy-tech to every home, accelerating the transition to a decarbonized future. Our sustainable solutions prioritize today's needs without compromising tomorrow. We believe that strong partnerships with our suppliers are essential for reducing Europe’s reliance on fossil fuels for residential heating.
This Supplier Code of Conduct outlines our expectations and standards for sustainable practices, and we invite our suppliers to join us in creating a more responsible, resilient, and sustainable future. Together, we can drive positive change and make a meaningful impact on the planet.
Aira is committed to upholding the highest standards for human rights, environmental responsibility and ethical conduct throughout our operations and business partnerships, including our supply chain. Through this commitment, we believe we can help advance our contribution to sustainable development. This supplier Code of Conduct reflects our values and sets clear expectations for our supply chain partners, aligning with the principles of the UN Global Compact, the UN International Bill of Human Rights, ILO Declaration on Fundamental Principles and Rights at Work, ILO Basic Terms and Conditions of Employment, UN Guiding Principles for Business and Human Rights, OECD Guidelines for Multinational Enterprises and OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.
2. Who this Code applies to
The Supplier Code of Conduct (the “Code”) applies to all suppliers that deliver goods and/or services to Aira, including their respective employees, sub-suppliers, sub-contractors, intermediaries and consultants (hereinafter individually and collectively referred to as “Supplier”).
If you have any questions or comments about the content of this Code, please reach out to sustainability at airahome.com
3. Responsibilities, audits and implementation
Suppliers must comply with all applicable laws and internationally recognized sustainability standards. In cases of discrepancies, Suppliers must follow the stricter requirement. If any Code requirement conflicts with national law, the Supplier must inform Aira immediately.
The Code establishes conditions for Aira to evaluate the social, human rights, environmental and governance performance of Suppliers and their supply chain. Aira may at any time request that Suppliers complete and report a self-assessment and reserves the right to, with reasonable notice, conduct audits on Suppliers and their sub-suppliers’ supply chain regarding compliance to the Code and any agreed upon corrective action plan.
Suppliers are accountable for ensuring responsible business practices throughout their entire value chain. In cases of non-compliance, such as withholding audit rights or failing to fulfil any agreed-upon commitments, Aira reserves the right to terminate the contract. Any corrective actions must be managed within a reasonable timeframe.
Aira encourages Suppliers to continually improve their environmental and social management and due diligence systems in line with international sustainability standards.
4. Human Rights
Aira is committed to respecting internationally recognized human rights in its operations and business relationships. The responsibility of Aira is to identify, prevent, address, track, communicate and enable access to remedy for risks and impacts to human rights and the environment throughout our value chain, in line with the UNGPs and OECD Guidelines for Multinational Enterprises.
4.1. Freedom of Association and the Right to Collective Bargaining
Suppliers shall respect the right of workers to freely and without interference or retaliation establish and join unions or worker representation and to bargain collectively.
4.2. Forced Labor
Suppliers must not engage in any form of forced, bonded, or involuntary labor. They must provide workers with clear written contracts in a language they understand and ensure all workers are legally entitled to work, with proper documentation. Suppliers shall not impose unreasonable movement restrictions or withhold identification documents. Workers should never be charged fees for uniforms or protective equipment.
Suppliers must comply with all applicable laws relating to modern slavery (e.g. UK Modern Slavery Act), which shall include as a minimum to ensure no forced labor or human trafficking in their operations or supply chains, and take immediate action if violations are found.
4.3. Child Labor and Young Workers
Child labor is not tolerated in any form. Suppliers shall only employ workers who are at least 15 years old, the legal minimum age, or the age for completing compulsory education, whichever is highest. Young workers aged 15-18 may be employed, but not in work that risks their health, safety, or morals, per ILO Conventions. It is of the highest importance to always protect children from being forced into harmful work.
4.4. Wages and Benefits
Suppliers shall pay wages and benefits at a minimum according to applicable laws, industry standards and relevant collective agreements, whichever is highest. Wages for a regular working week (not including overtime pay) shall always be sufficient to meet basic needs and provide some discretionary income. The level of wages shall reflect the level of skills and qualifications regardless of gender, national background, or other personal characteristics. Overtime should be paid according to local regulation. Wage deductions as discipline are prohibited and pay structures must be clearly communicated to workers.
4.5. Non-Discrimination
Suppliers shall not discriminate based on race, caste, ethnicity or national origin, age, gender, sexual orientation, gender identity and expression, disability, pregnancy, religion, political affiliation, union membership, covered veteran status, protected genetic information or marital status in hiring and employment practices.
4.6. Working Hours
Suppliers shall ensure that a regular working week is in accordance with the provisions of ILO Convention 1. Overtime should be voluntary, clearly documented and be restricted to the specifications defined in ILO conventions. The Supplier must give breaks, annual paid leave and one day off every week unless a collective agreement defines exceptions.
4.7. Harassment
There shall be no harsh and inhumane treatment including any sexual harassment, sexual abuse, corporal punishment, mental or physical coercion or verbal abuse of workers, nor the threat of any such treatment.
5. Occupational Health and Safety Management
Suppliers shall provide and maintain a safe work environment and integrate sound health and safety management practices into their operations. They are required to obtain, keep current, and comply with all necessary health and safety permits. Workers have the right to refuse unsafe work and to report any unhealthy conditions.
Suppliers must identify, assess, and manage occupational health and safety hazards by prioritizing hazard elimination, substitution, and controls, along with the use of appropriate personal protective equipment. To prevent accidents and incidents, potential safety hazards and emergency situations should be mitigated through proper design, comprehensive risk assessments, engineering solutions, safe work procedures, emergency plans, response protocols, and mandatory training. Onsite facilities and accommodations must ensure safety, dignity, and hygiene, meeting national and international standards.
6. Environment
Aira's mission is to bring clean energy tech to every home, reducing emissions from residential heating. We continuously assess our environmental processes, and our suppliers play a critical role in achieving our environmental and circularity ambitions.
6.1. Environmental Responsibility and Management Systems
Suppliers shall maintain an effective environmental policy and environmental management system, consistent with ISO 14001 or EMAS, that promotes environmental responsibility and enables continuous improvement of their environmental performance and impact.
6.2. Climate impact and data
Suppliers shall strive to reduce the climate impact of their operations and value chain. They must take steps to reduce dependence on fossil fuels, with a priority on transitioning to renewable energy sources. Aira may communicate supplier specific decarbonization targets in contracts with suppliers and third parties.
Suppliers shall assist Aira in the evaluation of the products and services they deliver, including data to perform life cycle assessments as well as end of life scenarios to follow. In addition, suppliers shall provide information regarding their carbon footprint and calculation methodology.
Suppliers shall develop appropriate metrics and targets to measure climate performance, including but not limited to the annual corporate greenhouse gas (GHG) emissions (covering GHG protocol scopes 1, 2 and 3), product GHG intensity or use of renewable energy. Where this information is not publicly available, Aira may request annual climate performance data.
6.3. Resource Efficiency and Circularity
Suppliers shall implement and control effective actions to reduce their use of energy, water, raw material and packaging materials. Suppliers shall implement a circularity approach to minimize use of virgin materials as far as possible.
6.4. Emissions and Waste Handling
Suppliers shall control and implement actions to reduce emissions to air, water and waste of all types. Waste handling management for hazardous and non-hazardous material must be developed and monitored.
6.5. Protection of Biodiversity
Suppliers shall protect natural ecosystems and seek opportunities for biodiversity conservation linked to their activity. Suppliers must understand the connections that its business may have with biodiversity loss and, as relevant, act to safeguard biodiversity.
Suppliers shall develop appropriate metrics and targets to measure performance.
6.6. Material Compliance
Suppliers must ensure that the products delivered to Aira comply with all legal requirements for placement on the European Single Market and the United Kingdom Internal Market. This includes any specific regulations applicable in individual member states or the UK. Upon request, Suppliers shall provide Aira with the necessary declarations, technical documentation, and test reports to demonstrate compliance.
Suppliers must ensure that all products provided to Aira comply with relevant material regulations. This includes avoiding restricted substances and ensuring that prohibited substances are not used at all, in compliance with applicable law. Suppliers should regularly assess their materials against the ECHA candidate list for substances of very high concern and ensure compliance with directives regarding hazardous materials.
Additionally, Suppliers must adhere to regulations that limit the use of specific hazardous substances in electrical and electronic equipment. Suppliers are required to provide documentation confirming compliance with these regulations upon request.
6.7. Responsible Sourcing of minerals
As part of their broader human rights and environmental due diligence, Suppliers shall exercise due diligence on minerals and materials in their supply chain, which at a minimum includes conflict minerals (tin, tantalum, tungsten, gold) and battery minerals.
Suppliers shall take effective measures to reasonably assure that minerals in the products, parts, components, and materials they produce do not directly or indirectly harm human rights or contribute to conflict and make available their due diligence measure to Aira upon request.
7. Ethics
Aira has a zero-tolerance policy towards any and all forms of bribery, corruption, extortion, money laundering, and embezzlement. Suppliers shall adhere and reject all corrupt practices, including but not limited to facilitation payments and receipt or giving of gifts. Suppliers are responsible for ensuring that their employees, subcontractors and other representatives comply with appropriate anti-corruption and bribery practices.
Personal interest or relationships shall not influence suppliers in decision making. Suppliers shall be proactive in managing potential conflicts of interest in collaboration with Aira. All business dealings should be transparently performed and accurately reflected in Suppliers’ financial records. Standards of fair business, advertising and competition should be upheld. Suppliers shall provide notification to Aira of counterfeit product(s) when warranted.
7.1. Privacy
Suppliers shall comply with privacy and information security laws and regulatory requirements when personal information is collected, stored, processed, transmitted, and shared. Suppliers shall commit to protecting the reasonable privacy expectations of personal information of everyone they do business with.
7.2. Intellectual Property
Intellectual property rights are to be respected; transfer of technology and know-how is to be done in a manner that protects intellectual property rights.
8. Grievance Mechanism
Suppliers are expected to provide or cooperate in remedying human rights or environmental harm they have caused or contributed to, in line with UN and OECD guidelines. They must establish appropriate grievance mechanism meeting UN Guiding Principles criterion and ensure individuals raising concerns, including whistleblowers, face no reprisals.