I. Purpose

Princeton Digital Group (or “PDG”) is committed to conducting business in a legal, ethical and socially responsible manner. We expect similar principled conduct from everyone with whom we have commercial dealings.

This Supplier Code of Conduct (or the “Code”) sets forth the basic requirements that we ask our Suppliers to respect and adhere to when conducting business with or on behalf of PDG.

II. Applicability

Suppliers shall include service providers, vendors, manufacturers, dealers, traders, agents, consultants, contractors, sub-contractors, joint venture partners or other third parties who have a business relationship with, sell, seek to sell, provide, seek to provide, any kind of goods or services to PDG.

This Supplier Code of Conduct is applicable to and shall be complied with by all Suppliers globally.

Suppliers shall also ensure that this Code is compiled with by their officers, directors, employees, agents, sub-contractors and other representatives.

III. Principles

Business Integrity
Anti-bribery and corruption:

  • Suppliers shall comply with all applicable domestic and foreign anti-bribery or anti-corruption laws and regulations including, without limitation, the U.S. Foreign Corrupt Practices Act of 1977, the U.K. bribery Act of 2010 and the Prevention of Corruption Act (Chapter 241) of Singapore.
  • Suppliers shall not engage in corruption, bribery or any activity which includes taking direct or indirect actions in furtherance of an offer, payment, promise to pay or authorization of the payment of anything of value, including but not limited to cash, checks, wire transfers, tangible and intangible gifts, favours, services, and those entertainment and travel expenses that go beyond what is reasonable and customary and of modest value, to:
  • (i) an executive, official, employee or agent of a governmental department, agency or instrumentality,
  • (ii) a director, officer, employee or agent of a wholly or partially government-owned or – controlled company or business,
  • (iii) a political party or official thereof, or candidate for political office, or
  • (iv) an executive, official, employee or agent of a public international organization (“Government Official”) or any other person; while knowing or having a reasonable belief that all or some portion will be used for the purpose of rewarding or:
  • (a) influencing any act, decision or failure to act by a Government Official in his orher official capacity,
  • (b) inducing a Government Official to use his or her influence with a government or instrumentality to affect any act or decision of such government or entity,
  • (c) inducing any person to use his or her influence to improperly affect any act or decision of such their employer.
  • (d) securing an improper advantage; in order to obtain, retain, or direct business.

Suppliers shall ensure that no part of the payments received by them (whether compensation or otherwise) from PDG will be used for any purpose that could constitute to violation of any applicable laws.

Gifts and entertainment:

Suppliers shall not accept / offer on behalf of PDG or offer to PDG’s employees any kind of gifts or personal benefits (monetary or otherwise) which could be perceived as a bribe. In all cases, gifts or entertainment shall not be accepted or offered to improperly influence any business relationship and must not violate applicable laws or ethical standards.

Conflict of interest:

A conflict of interest is a situation in which a Supplier has any interest (financial, personal or otherwise) with any employee / staff of PDG; which could potentially damage PDG’s interest.

Any such situation needs to be disclosed to the PDG management. If a Supplier becomes aware of an actual, potential or perceived conflict of interest that may impact its work for or with PDG,
it shall notify PDG immediately and depending on the circumstances, place adequate mechanisms to manage the conflict of interest situation.

Competing fairly:

PDG believes in the free market system where merit, quality, price, and other objective aspects are determining factors while conducting business:

  • (i) Suppliers of PDG shall refrain from any unfair competition under applicable anti-trust and competition laws and regulations, whether individually or through other entities or individuals.
  • (ii) Suppliers shall compete honestly, fairly and never participate in anti-competitive practices such as price fixing or bid rigging. Further, Suppliers shall not enter into any agreement(s), formally or informally, to unlawfully restrict competition.

Anti-money laundering and other economic crimes:

PDG has zero tolerance policy towards money laundering, terrorism financing or any other similar crime.

  • (i) Suppliers shall comply with applicable laws, rules and standards on money laundering and terrorist financing, abiding to both the letter and the spirit of those regulations.
  • (ii) Suppliers shall not engage or be suspected of having engaged in illegal or unethical activities.

Trade controls:

Suppliers shall know and comply with applicable import-export controls, economic sanctions and anti-boycott laws and shall refrain from carrying out any activities which may reflect as violation of these sanctions and laws by themselves or PDG. Further, Suppliers shall not participate in any other restrictive trade practices.


  • (i) Suppliers shall consider all information received / accessed in relation to PDG, its business, affiliates, projects, vendors, clients and other third parties as confidential information and shall not disclose the same without prior written consent from PDG.
  • (ii) Suppliers shall apply reasonable security measures to protect confidential information from unauthorised and unlawful access, use, disclosure, alteration, loss, damage and destruction.
  • (iii) Suppliers shall handle and disclose the confidential information that they obtain during their relationship with PDG, only as authorised and directed by PDG and as required by applicable laws and regulations.
  • (iv) If the Supplier believes it has been given access to confidential information in error, the Supplier should immediately notify PDG of such access, and refrain from further distribution of the information.

Data protection:

Supplier shall comply with all applicable Data Protection and Information Security laws and regulations.

Intellectual property rights:

Suppliers shall ensure that they do not infringe on any intellectual property rights or copyrights of PDG.

Insider trading:

Suppliers shall not engage in insider trading or support the same. In addition, Suppliers may not induce anyone, by giving advice or in any other manner, to undertake such insider trading.

Financial controls:

Suppliers are expected to:

  • (i) Keep accurate, complete, fair, timely, transparent, and understandable financial and operational books, records, and accounts, and a system of effective internal records.
  • (ii) Create, retain and dispose of business records in accordance with applicable legal and contractual requirements.

PDG name and brand:

Suppliers shall not use the name of PDG, PDG’s logo, or the name or logo of any division, subsidiary or project of PDG or PDG’s trademarks and service marks without the prior written approval of PDG.

Standards for Responsible Supply Chain

The PDG Responsible Supply Chain Standard incorporates standards on human rights, labour rights and environmental, and anti-corruption principles as set out in the UN Global Compact – which is derived from the Universal Declaration on Human Rights, the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work, the Rio Declaration on Environment and Development, and the United Nations Convention against Corruption and the UN Guiding Principles on Business and Human Rights.

Suppliers shall comply with the PDG Responsible Supply Chain Standard:

Legal and compliance:

PDG Supplier Code of Conduct Suppliers shall operate in compliance with all applicable environmental, labour, and anti-corruption laws and regulations of the countries in which they operate, manufacture or conduct business.


Suppliers with significant environmental impacts shall maintain an effective environmental policy and/or environmental management system that supports environmental protection, prevention of pollution and prudent management of natural resources. Suppliers shall reduce the impact of their products and services on the environment and on communities and make reasonable efforts to meet industry best practice and standards with respect to the reduction of and reporting about energy use and greenhouse gas emissions.

Human rights and modern slavery:

Suppliers are subject to the PDG Modern Slavery Policy. Suppliers must conduct their business in a way that upholds human rights and shall not practice any form of modern slavery such as servitude, forced or compulsory labor, trafficking, or child labour. Suppliers shall not employ children under the age as defined by the International Labour Organization conventions or by national law, which is highest. Suppliers are also expected to establish effective procedures to identify, prevent, mitigate, and be accountable for modern slavery and other human rights impacts within their operations and supply chains, and are obliged to inform PDG if they become aware of any incidents of modern slavery within their operations or supply chains.


Suppliers shall provide equal opportunity and advancement opportunities for all employees regardless of age, colour (dis)ability, ethnicity/race, gender, gender identity, marital status, pregnancy/maternity, national origin, sexual orientation or religion.

Compensation and benefits:

Suppliers shall provide wages and benefits that comply with any applicable law, and which match prevailing local practices.

Hours of work:

Suppliers shall ensure that their employees are not required to work more than the local legal limits on regular and overtime hours.

Freedom of association:

Suppliers shall recognize and respect the right of their employees to freely associate and collectively bargain within the boundaries of the applicable law.

Humane treatment:

Suppliers shall treat their employees with respect and dignity and provide a work environment free of harassment, intimidation and bullying. Suppliers shall protect employees in raising concerns about business conduct.

Health and safety:

Suppliers shall provide a safe and healthy working environment in order to prevent workplace accidents and illness. This shall also apply to their employees’ residential facilities, if provided
by the Supplier.

IV. Communication and Monitoring

  • (i) We expect our Suppliers to take appropriate steps to communicate this Code to their officers, directors, employees, agents, sub-contractors and other representatives.
  • (ii) Suppliers shall allow PDG to check compliance upon request and reasonable notice.
  • (iii) Suppliers shall promptly notify PDG of any circumstances affecting compliance with or breaches of this Code including those involving their officers, directors, employees, agents, sub-contractors and other representatives.

V. Event of Violation

If a Supplier is in breach of this policy, PDG may require the Supplier to implement a corrective action plan to cure the non-compliance within a specified time period. If the Supplier fails to meet the corrective action plan commitment, PDG may terminate the current and future business relationship, including, but not limited to, cancellation of all existing orders between PDG and Supplier. PDG reserves the right to hold the Supplier responsible for reasonable costs of investigating any non-compliance.

VI. Declaration

Suppliers are required to certify that the Code has been reviewed, understood and agreed upon.