INCIDENT MANAGEMENT AND SUPPLIER EVALUATION POLICY

As part of the update of our Quality Management System, in accordance with the guidelines established by ISO 9001:2015, we hereby announce the adoption of this Incident Management and Continuous Supplier Evaluation Policy, which will be generally applicable throughout our organisation.

The fundamental purpose of this policy is to establish a systematic mechanism for monitoring, evaluation and continuous improvement that allows for the timely identification of deviations, prevents the occurrence of non-conformities and, where appropriate, implements effective corrective actions before such incidents have an irreversible impact on service delivery.

CONTINUOUS SUPPLIER EVALUATION PROCEDURE

An annual formal evaluation will be conducted for all suppliers who have maintained a commercial relationship with KNOWTRANSFER during the relevant period. The purpose of this evaluation is to assess the overall performance of each supplier based on the following objective criteria:

  • Timely Delivery Compliance: Verification of adherence to the established timelines for the execution of contracted services or projects.
  • Service Quality: Confirmation that the goods or services supplied meet the quality standards required by KNOWTRANSFER, in accordance with contractual specifications and applicable regulations.

In accordance with ISO 9001 quality management principles, an incident is understood as any event, whether positive or negative in nature, that may directly or indirectly affect the normal course of organizational activities.

As part of the supplier evaluation process, mechanisms will be implemented to minimize the impact of incidents on the final delivery of services to the client.

KNOWTRANSFER will classify incidents by severity levels and establish maximum allowable thresholds. Repeated non-compliance or exceeding these limits may result in the loss of authorized supplier status and, consequently, suspension or termination of the commercial relationship.

Incident Classification and Limits

Incidents detected during service execution shall be classified according to their severity and potential or actual impact on the client and the organization. The types of incidents, their descriptions, and the permitted limits for maintaining active supplier status are as follows:

Incident Type

Description

Permitted Limit

Critical

Incidents that jeopardize the continuity of client service, significantly affect corporate reputation, or compromise the fulfillment of essential contractual obligations.

0

Major

Incidents causing service delays or partial non-compliance, without affecting final service quality or corporate reputation.

1

Minor

Incidents that are resolved immediately, with minimal impact on project execution and no effect on client delivery timelines.

3

Total Maximum Tolerance

Maximum number of incidents of any type a supplier may accumulate before being reevaluated or excluded.

 

SUPPLIER CODE OF CONDUCT

At KNOWTRANSFER, we recognize that social and environmental responsibility is a core pillar of our corporate culture and must be shared and applied throughout our supply chain. Consequently, all suppliers engaged with KNOWTRANSFER must strictly comply with the principles, objectives, and obligations set forth in this Code of Conduct, regardless of the type of service provided or the legal nature of their contractual relationship with the company.

This Code is mandatory for all suppliers whose activities have a direct impact on KNOWTRANSFER processes and/or employees.

 

Social and Ethical Objectives

Suppliers shall conduct their activities in strict compliance with the law, business ethics, transparency principles, and respect for human rights and internationally recognized standards of responsible conduct. Specifically, suppliers shall observe the following obligations:

  • Legal and Regulatory Compliance: Adhere to all applicable local, national, and international legislation, as well as sector-specific regulations, ensuring the highest ethical, social responsibility, and transparency standards.
  • Fair Competition: Comply with competition laws and refrain from collusive practices, illegal agreements, abuse of dominant position, or any other anti-competitive behavior.
  • Economic Responsibility and Transparency: Execute all financial and commercial operations rigorously, traceably, and transparently, maintaining accurate accounting records accessible for control or audit purposes.
  • Prevention of Corruption and Money Laundering: Refrain from participating in, promoting, or tolerating fraudulent, corrupt, or illegal conduct, including offering or accepting bribes, improper gifts, hidden commissions, or facilitation payments. Any activities related to money laundering are strictly prohibited.
  • Conflict of Interest: Implement effective mechanisms to prevent, identify, and report situations in which personal, financial, or other interests may conflict with professional or contractual responsibilities to KNOWTRANSFER.
  • Data Protection and Confidentiality: Comply with applicable data protection laws and maintain the confidentiality of all information obtained within the commercial relationship. Such information may not be used or disclosed without KNOWTRANSFER’s express authorization, legal obligation, or judicial/administrative requirement. Applicable confidentiality agreement clauses shall always be enforced.
  • Intellectual and Industrial Property: Respect the intellectual and industrial property rights of KNOWTRANSFER and third parties, refraining from reproducing, using, or commercializing counterfeit or unauthorized products.

 

Environmental Objectives

KNOWTRANSFER and its suppliers share a firm commitment to environmental protection, strictly complying with applicable environmental legislation and promoting sustainable development.

A preventive approach shall be adopted to avoid or minimize any negative impact on natural resources and biodiversity, while fostering initiatives that reinforce corporate environmental responsibility throughout the supply chain.

Suppliers are required to comply with the following principles:

  • Environmental Management: Strict compliance with applicable environmental regulations and the continuous implementation, operation, and improvement of environmental management systems and procedures, with particular attention to significant environmental aspects arising from their activities.
  • Responsible Resource Use: Adopt measures for the efficient and sustainable consumption of natural resources, including water and electricity, promoting best practices in waste reduction and optimization.
  • Reduction of Greenhouse Gas Emissions: Implement effective actions to measure, control, and reduce greenhouse gas (GHG) emissions, actively contributing to climate change mitigation.

In the event KNOWTRANSFER identifies non-compliance with any of the above points, an assessment will be conducted, and, if necessary, the continuation of the contractual relationship with the supplier will be reviewed, potentially leading to suspension or termination in cases of serious or repeated non-compliance.