Biofy Code of Conduct


Corporate integrity, responsible practices, and the safety and wellbeing of workers are of paramount importance to Biofy. These principles apply to all aspects of Biofy’s business.
These principles are reflected in this Code of Conduct (“Code of Conduct“), which establishes the minimum standards that must be met by Biofy when operating its business or providing products and services to its clients (“Clients”), including regarding:
• compliance with laws
• Biofy’s treatment of workers;
• workplace safety; • the impact of Biofy’s activities on the environment; and
• Biofy’s ethical business practices.


This Code of Conduct applies to all of Biofy’s personnel and all of Biofy’s offices. Biofy is responsible for compliance with the standards set out in this Code of Conduct (“Standards“) throughout its operations and throughout its entire company operations. Without limiting Biofy’s obligations hereunder, Biofy shall comply with the Standards in:
• all of its offices; and
• all of its operations, including with respect to operating and providing the Biofy services, intellectual property, labor, health, worker safety, and the environment.
Biofy seeks to work with suppliers, vendors, agents, and subcontractors and their respective Offices (“Partner(s)“) who have similar Standards.

Compliance with Laws

Biofy shall comply with all applicable national and local laws and regulations, including laws and regulations relating to all the Standards. Where this Code of Conduct requires Biofy to meet a higher standard than set out by law or regulation, Biofy shall meet such higher standards.

Diversity Equity & Inclusion

As part of Biofy’s ongoing commitment to diversity and inclusion, Biofy strives to recruit, hire, develop, retain and promote a diverse group of officers, directors, professionals, employees, consultants, and contractors. In furtherance of this commitment, Biofy strives to provide representation, opportunity, and access to historically “under-represented groups” (as defined below), within the bounds of applicable law. Biofy agrees to utilize all commercially reasonable efforts to ensure individuals working or interviewing who have a mobility disability or are visually or hearing impaired can access the interview location. Biofy acknowledges and understands that applicable employment laws prohibit discrimination on the basis of race, sex, national origin, disability, age, sexual orientation, gender identity, religion, veterans status and other protected categories. While it is Biofy’s goal to increase diversity, and Biofy will strive to seek out a broad spectrum of applicants for employment to ensure that under-represented groups are given a full and fair opportunity to be consider for available positions, Biofy will make employment decisions without regard to any protected characteristics, as required by applicable law. For purposes herein, “under-represented groups” are defined as those who identify themselves as (i) female, (ii) people of color, (iii) disabled, (iv) Lesbian, Gay, Bisexual, Transgender, Queer or otherwise Gender Fluid; (v) veterans; and/or (vi) a combination of diverse qualities identified in (i-v).

Data Security

Privacy and data security are core principles at Biofy. All internal and external products, services and activities must be carried out with applicable privacy and data security obligations and industry best practices in mind. Personnel should immediately raise to their direct reports any concerns about a potential violation of this key principle or a suspected security incident.

Compensation and Benefits

Biofy shall compensate all workers with wages, including overtime premiums, and benefits that at a minimum meet the higher of:
• the minimum wage and benefits established by applicable law;
• collective agreements, if any, and;
• an amount sufficient to cover basic living requirements.
Biofy’s obligation to compensate and provide benefits applies to all workers at all times, including during periods of training, apprenticeship, and probation.


Biofy shall:
• ensure that proof of payment is accurate, is clearly calculated, and enables workers to quickly verify the amount of payment and method of calculation; and
• maintain proper documentation of wage payments for their internal records.
Biofy shall not make any deductions from wages, except income tax withholding and those that are legally allowed.

Work Hours

Regular Work Hours Biofy shall not require or allow workers to work more than the lesser of:
• regularly-paid hours per week; or
• the maximum legally permitted number of regularly paid hours worked per week.
Overtime Work Hours
Additional overtime hours must not exceed the maximum legally permitted number of overtime hours worked per week.
Biofy shall:
• use an industry-accepted time-keeping system to track worker work hours; and
• develop work-hour policies to ensure compliance with this Code of Conduct and applicable law.

No Discrimination, Abuse, or Harassment

Biofy shall not discriminate in hiring, compensation, training, advancement or promotion, termination, retirement, or any other employment practice based on race, color, national origin, gender, gender identity, sexual orientation, military status, religion, age, marital or pregnancy status, disability, or any other characteristic other than the worker’s ability to perform the job.
Biofy shall treat workers with respect and dignity.
Biofy shall not subject workers to physical, verbal, sexual, or psychological abuse or harassment. Biofy must not condone or tolerate such behavior by its Partners.

Health and Safety

Biofy shall provide a safe, healthy, and sanitary working environment. Biofy shall implement procedures and safeguards to prevent workplace hazards, and work-related accidents and injuries, including procedures and safeguards to prevent industry-specific workplace hazards, and work-related accidents and injuries, that are not specifically addressed in these Standards.
General and industry-specific procedures and safeguards include those relating to:
• health and safety inspections;
• equipment maintenance;
• maintenance of offices;
• worker training covering the hazards typically encountered in their scope of work;
• fire prevention; and
• documentation and recordkeeping.


Biofy shall:
• ensure that all offices meet all applicable building codes and standards;
• without limiting Biofy’s obligations hereunder, ensure that all offices have:
• an adequate evacuation plan;
• adequate, well-lit (including emergency lighting), clearly marked, and unobstructed emergency exit routes, including exits doors, aisles, and stairwells;
• a sufficient number of emergency exit doors;
• adequate ventilation and air circulation;
• adequate lighting;
• post all notices as required by law; and
• adequate fire safety, prevention, alarm, and suppression systems.
If Biofy provides dining offices for its workers, it shall provide safe, healthy, and sanitary offices (including food preparation and storage areas) that comply with all the Standards set out in the Health and Safety section of this Code of Conduct. Without limiting Biofy’s obligations hereunder, Biofy shall obtain and maintain all food preparation permits and health certificates required by law.

Slavery and Human Trafficking

All labor must be voluntary. Biofy shall not support slavery or human trafficking in any part of its supply chain. Without limiting Biofy’s obligations hereunder, Biofy shall not support or engage in, or require any:
• compelled, involuntary, or forced labor;
• labor to be performed by children;
• bonded labor;
• indentured labor; and
• prison labor.

Compliance and Documentation

Biofy shall:
• Implement and maintain a reliable system to verify the eligibility of all workers, including:
• age eligibility; and
• legal status of foreign workers.
• Implement and maintain a reliable recordkeeping system regarding the eligibility of all workers.
Freedom of Movement Without limiting Biofy’s obligations hereunder, Biofy shall ensure that workers have the right to freedom of movement without:
• delay or hindrance; or
• the threat or imposition of any discipline, penalty, retaliation, or fine or other monetary obligation.

Freedom to Terminate Employment

Without limiting Biofy’s obligations hereunder, Biofy shall allow workers to terminate their employment or work arrangement, subject to any contractual commitments with the company.

Environmental Protection

Operation of Biofy’s Offices Biofy shall strive to conduct its business in ways that are ecologically friendly.

Gifts and Entertainment

Biofy must maintain the highest ethical standards. Biofy must not offer cash, favors, gifts, or entertainment to Biofy’s team members in violation of applicable laws. Biofy shall also comply with the Foreign Corrupt Practices Act (FCPA) and prohibits any form of illegal bribery and similar corruption.

Report Violations & Contact Information

Biofy personnel may self-report any violations of the Code of Conduct. Biofy personnel can also submit questions and comments regarding the Code of Conduct, to [email protected], Attn: Biofy Legal. Biofy shall not retaliate or take disciplinary action against any worker who has, in good faith, reported violations or questionable behavior, or who has sought advice regarding this Code of Conduct.