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Global Code of Conduct

For Suppliers, Vendors, and Business Partners 

Last updated: May 15, 2025 

At WTFN, Inc., operating as COOCHY, we are committed to conducting business ethically, legally, and responsibly. This Global Code of Conduct (“Code”) outlines the standards we expect all our external business partners—including suppliers, manufacturers, contractors, subcontractors, consultants, and vendors (“Suppliers”)—to uphold while working with us. 

OUR VALUES 

We are committed to high standards in environmental, social, and governance (ESG) practices. We only work with Suppliers who meet or exceed applicable legal and regulatory requirements and operate with integrity. Adherence to this Code is required and forms part of any contract or agreement with COOCHY.  

SUPPLIER RESPONSIBILITIES 

Compliance: Suppliers must fully comply with all applicable local, national, and international laws, including those governing labor, safety, and trade. 

*Communication: Suppliers must communicate this Code to their workers and subcontractors and ensure they follow it. 

Monitoring: COOCHY reserves the right to audit compliance, including via third-party platforms. 

Violations: Breaches of this Code are considered breaches of contract. 

If you have questions about this Code, contact us at info@hellcoochy.com  

LABOR & HUMAN RIGHTS STANDARDS 

No Forced Labor or Human Trafficking 

Suppliers must not engage in or benefit from forced labor. Workers must be free to leave employment, retain personal documents, and not be subject to coercion or abuse. 

No Child Labor 

The minimum employment age must comply with ILO guidelines or local law, whichever is stricter. 

No Abuse or Harassment 

Physical or verbal abuse, intimidation, or threats are prohibited. 

Wages, Hours & Benefits 

Suppliers must follow all labor laws regarding compensation, working hours, breaks, and time off. Employees must receive at least one day off per week. 

Health & Safety 

Suppliers must: 

  • Provide a safe, clean, and healthy working environment 

  • Follow all health and safety laws and industry standards 

  • Ensure access to potable water and sanitary facilities 

Misconduct Reporting 

Suppliers are encouraged to implement systems that detect and address worker mistreatment or policy violations. 

ANTI-CORRUPTION & BUSINESS INTEGRITY 

No Bribery or Corruption 

Suppliers must not participate in bribery, kickbacks, or unethical business conduct. Internal controls should prevent such activities. 

Laws & Regulations 

Suppliers must comply with all anti-corruption laws, including the U.S. Foreign Corrupt Practices Act (FCPA), and maintain transparent financial records. 

Competition & Fair Dealing 

Suppliers may not fix prices, rig bids, or restrict fair competition. Payments must be made to accounts under the Supplier’s name. 

Conflicts of Interest 

Suppliers must avoid conflicts of interest and have policies in place to guide employee conduct. 

Gifts & Entertainment 

Gifts or entertainment offered must be reasonable and not intended to influence business decisions. Suppliers may not provide gifts, funds, or favors to any employee of COOCHY.  

GUIDING PRINCIPLES & STANDARDS 

This Code is grounded in globally recognized standards, including: 

  • The Ethical Trading Initiative (ETI) Base Code: [ethicaltrade.org](http://www.ethicaltrade.org/) 

  • The United Nations Universal Declaration of Human Rights: [un.org](https://www.un.org/sites/un2.un.org/files/2021/03/udhr.pdf) 

  • International Labour Organization (ILO) Fundamental Conventions: [ilo.org](https://www.ilo.org) 

We reserve the right to update this Code at any time and will notify Suppliers of changes. Thank you for partnering with us in building a responsible and ethical supply chain.