Legal

Nuro Code of Business Conduct and Ethics

Supplier Code of Conduct

Nuro, Inc. is committed to the highest standards of product quality, safety, and business integrity. We want to ensure that working conditions in our supply chain are safe, that workers are treated with respect and dignity, and that our suppliers’ operations are conducted in a manner consistent with protecting the natural environment. We expect all of our suppliers and their subcontractors agreeing to this code to share the principles which are expressed in this Supplier Code of Conduct (“Code”) and to replicate these standards further down the supply chain.

The term “Supplier” or “Suppliers” means any natural person or business entity that is the source for goods or services, back to the primary production level. The Code is applicable to all Suppliers, including workers and employees of any of those Suppliers (including permanent, temporary, contract agency and migrant workers). This includes all workers providing work at a Supplier location, such as under an employment agency or service provider. It also applies to every subcontractor and third-party labor agency who performs work for our Suppliers pursuant to their contracts with us.

We reserve the right to verify compliance with this Code through internal or third-party assessments and to require implementation of corrective actions toward meeting the Policy. In cases where improvement is required, we will support the Supplier to establish clear milestones and processes to support their achievement. Suppliers agree to cooperate with any investigation or verification that we may request, either directly or through a third-party. Suppliers are also required to timely inform Nuro within 48 hours of learning of any breach of any of the principles and requirements articulated in this Code. Suppliers who fail to cooperate with our investigations or to comply with the Code may be subject to consequences up to and including termination of business.

Business Practices

Suppliers will implement management systems to facilitate compliance with all applicable laws, regulations, contractual agreements and generally recognized standards, and to promote continuous improvement with respect to the expectations set forth in this Supplier Code of Conduct.

Suppliers will have systems in place to:

  • Enable fair, confidential and anonymous grievance reporting for their employees and contractors, and follow-up without fear of reprisal, including whistleblower protections

  • Maintain books and records in accordance with applicable law and generally accepted accounting principles

  • Protect Nuro’s confidential information to which they have access, including all intellectual property, trade secrets, or financial information, and to safeguard any property belonging to Nuro while under their control

  • Prevent any form of corruption, extortion or embezzlement, including a zero-tolerance approach to bribery and kickbacks

  • Conduct their business in line with fair competition and in accordance with all applicable antitrust laws

We reserve the right to require Suppliers to provide a complete supply chain map to facilitate risk assessment and gauge compliance in our upstream supply chain. Suppliers shall be transparent, candid, and forthcoming about all known facilities used to produce products or services for us and provide such information upon request. At our request, Suppliers shall provide to us reports on the occurrence of substances in any materials supplied to us that may be restricted by, or require disclosure to, governmental bodies, and/or customers.

Labor Practices

We expect Suppliers to respect the personal dignity, privacy and human rights of each individual and:

  • Avoid any sort of child labor in their business operations in violation of the International Labor Organization’s (ILO) core labor standards

  • Uphold freely chosen employment practices, with no toleration for forced, prison, bonded, indentured, slave, or involuntary labor in their operations and supply chain

  • Provide employees with a written employment agreement that complies with local laws and regulations, and inform workers of their legal rights and employment conditions in a language understood by the employee

  • Respect the maximum number of working hours determined in the applicable laws and provide compensation paid to employees that comply with applicable national wage laws, with all overtime work paid at the legally mandated overtime rate, or in the absence of this, a premium wage

  • Protect equal opportunities for and treatment of its employees irrespective of skin color, nationality, ethnicity, race, disabilities, political or religious conviction, sexual orientation or gender identify, age, sex, social background, physical characteristics, union membership, family status, or pregnancy

  • Refuse to tolerate sexual harassment or discrimination, and provide employees with a workplace free of corporal punishment or torture, mental or physical coercion or verbal abuse of employees, or the threat of any such treatment

  • Respect the rights of employees to associate freely, join labor unions, seek representation, join works councils and engage in collective bargaining, as permitted by applicable law

  • Provide a safe and healthy working environment, including appropriate controls, safe work procedures, preventative maintenance and necessary technical protective measures to mitigate health and safety risks in the workplace

  • Identify and assess likely and potential emergency situations in the workplace and minimize their impact by implementing emergency plans and response procedures

  • Ensure that employees have access to potable drinking water and clean toilet facilities at all times at the workplace and that such accommodations, where provided, are clean, safe, affordable, and meet the basic needs of workers and conforms to applicable laws

  • Respect the rights and titles to property and land of individuals, indigenous peoples and local communities and ensure that negotiations regarding property and land adhere to principles of free, prior and informed consent, as well as contract transparency and disclosure

Environmental Practices

We are committed to operating in a way that respects the environment, is thoughtful about the use of natural resources, and is focused on continuous improvement. At a minimum, we expect that Suppliers will:

  • Act in compliance with the applicable statutory and international standards, and industry best practices, for protecting the natural environment

  • Work to reduce their carbon footprint through investment in energy efficient buildings and processes, optimization of supply chains and distribution networks, and a transition to renewable energy sources

  • Protect water resources by minimizing use of water in their operations, avoiding contamination from their operations, and reducing the impact on the water resources of the surrounding communities, especially in areas of high baseline water stress

  • Follow local and international legal standards for extracting and refining minerals and other resources

  • Reduce waste-to-landfill through strategic sourcing initiatives, reuse and recycling practices, optimized manufacturing and packaging systems, and employee training

  • Identify and carefully manage the use, storage, transportation, and disposal of hazardous materials, chemicals and substances consistent with local law and industry best practices, including providing relevant employees with proper training for safe handling, storage and disposal and developing processes to prevent or mitigate accidental spills and releases into the environment

Environmental Health & Safety (EHS) Policy Statement

Mission

Nuro’s mission is to better everyday life through robotics. In support of this, we are committed to conducting our operations in a way that minimizes impact on the environment and creates a healthy and safe workplace. We prioritize continuous improvement and commit to continued transparency and environmental accountability.

This policy applies to all prospective and current employees of the company as well as volunteers, contractors, and consultants. Suppliers are expected to abide by these same values.

Goals & Objectives

The EHS team is expected to meet or exceed the following objectives of Nuro’s EHS Policy:


1. Ensure compliance with all applicable legal and other EHS obligations.
2. Prevent injuries and ill health by minimizing safety and environmental risks.
3. Commit to reducing pollution, waste, and conserving resources.
4. Commit to world class emergency management standards by providing emergency equipment, procedures, and routinely performing inspections, evacuations, and training.
5. Educate, train, and motivate Nurons to work in a safe, environmentally responsible manner.
6. Foster openness and dialogue on EHS matters with our stakeholders, both internal and external; communicating risk, performance, and progress.
7. Actively improve EHS performance by performing periodic external audits and internal review and assessments.

Health and Safety

Every employee has a right to be safe at work. We are committed to follow applicable standards and create a hazard-free workplace. Our priorities are divided into three areas:

1. Preventative action

  • We comply with all applicable health and safety regulations.
  • We prioritize continuous improvement against workplace hazards, and continuously develop Job Hazard Analysis and Trainings to better and more safely enable our population.
  • We provide job-specific PPE.
  • We regularly conduct site inspections, and proactively work with independent 3rd parties to audit our compliance measures.

2. Emergency Preparedness and Response:

  • Emergency Response Plans are developed for all facilities.
  • Fire extinguishers, AED’s, First Aid Kits, and Fire Detection systems are in place across all facilities.
  • Evacuation plans, including muster points, are posted in every building, and available digitally on Nuro’s Intranet Site, and available in paper form for all guests/visitors upon arrival.

3. Additional actions:

  • We continuously review our policies and procedures to respond to changing best practices and/or new occupational health and safety regulation:
  • We catalog and analyze our site audits to develop Leading and Lagging indicators to proactively improve safety and compliance.
  • We regularly consult experts to ensure compliance with our programs and policies.

Environment

  • We power our facilities using electricity from renewable sources.
  • We will endeavor to design and source sustainable products & materials to conserve natural resources and minimize utility consumption.
  • We seek to effectively divert waste through reuse, recycle, and compositing programs.
  • We believe in the benefits of LEED and WELL Design principles, and employ them into our spaces as possible.

Governance

Nuro’s EHS Policy is implemented through an EHS Management System. Governance and Responsibility for implementing the policy is held by Nuro’s Safety Leadership Team, composed of key leaders and senior executive team responsible for ensuring that environmental and industrial hygiene are integrated into all business decision-making functions.


Labor and Human Rights Policy

At Nuro, we are on a mission to better everyday life through robotics. That mission motivates us to uphold human rights in our relationships with employees, customers, suppliers, partners and in the communities in which we operate.

This labor and human rights policy is the formalization of our commitment to uphold and respect these rights and the values they represent. We endorse and base our definition of human rights on the United Nations’ Universal Declaration for Human Rights and our policy aligns with the International Labor Organization’s 1998 Declaration on Fundamental Principles and Rights at Work. These documents focus on dignity, respect, and equality, without discrimination, for all people. We are committed to upholding these rights and values. We expect that our suppliers will also support and promote these values in their own operations and in those of their own suppliers, consistent with our Supplier Code of Conduct. We recognize that we are part of the communities in which we operate, and we are committed to engaging in good faith with communities on issues important to them.

We are committed to identifying adverse human rights impacts resulting from or caused by our business activities and addressing these issues in fair and equitable ways.

Nuro’s Public Trust Department is responsible for implementing this policy. All employees are expected to abide by this policy.

Diversity, Inclusion, and Belonging

Diversity, inclusion, and belonging is a priority for Nuro. We are committed to building a team that provides access, opportunity, and growth for people from underrepresented groups at all levels of our company. We conduct regular, data-driven reviews of our progress, and are focused on taking meaningful action to advance diversity hiring and the experience of current employees. Nuro proudly supports several employee resource groups that are voluntary and employee-led. At Nuro, we embrace each other’s differences because we believe that the ability to see and act through various lenses leads to a stronger sense of belonging and engagement.

Discrimination and Harassment

Nuro is an equal opportunity employer. We make employment decisions on the basis of merit and business needs. We do not unlawfully discriminate against, nor do we tolerate unlawful harassment by any person, including co-workers, managers, and third parties, on the basis of race, color, religion (including, but not limited to, religious creed, dress, and grooming practices), citizenship, political activity or affiliation, marital status, age, national origin, ancestry, mental or physical disability, genetic information, medical condition, military or veteran status, sexual orientation, gender identity, gender expression, sex, gender, pregnancy, childbirth, taking or requesting statutorily protected leaves, or any other characteristics protected under applicable federal, state, or local laws. We are dedicated to this policy with respect to recruitment, hiring, placement, promotion, transfer, training, compensation, benefits, employee activities and general treatment during employment.

Employee Compensation, Development, and Privacy

We compensate employees competitively relative to the industry and local labor market. We work to ensure full compliance with applicable wage, work hours, overtime, and benefits laws. We regularly conduct pay equity analyses in all countries where we have significant employee presence and take action to address statistically significant disparities.

We are committed to equipping our employees with the skills needed to succeed at their job. We foster continuous professional growth, learning and development. We offer a variety of training opportunities and mentorship programs to Nuro employees.

We respect our employees’ privacy and comply with all applicable laws regulating the disclosure of personal information, including data protection laws. We are transparent in our use of data, and protect the rights of our employees, contractors, customers, and business partners.

A Safe, Healthy, and Secure Workplace

We are committed to providing a healthy and safe workplace and complying with applicable health and safety laws and regulations, as well as internal requirements.

We work to provide and maintain a safe, healthy, and productive workplace by addressing and remediating identified risks of accidents, injury, and health impacts. While accidents and injuries are rare, we are nevertheless committed to engaging with our employees to continually improve the health and safety in our workplace.

We are committed to maintaining a workplace that is free from violence, harassment, intimidation and other unsafe or disruptive conditions due to internal and external threats. Security safeguards for employees are provided, as needed, and are maintained with respect for employee privacy and dignity.

Forced Labor, Human Trafficking, and Child Labor

Nuro opposes the use of all forms of forced labor, including prison labor, indentured labor, bonded labor, military labor, modern forms of slavery and any form of human trafficking.

Nuro strictly follows local and national laws restricting the employment of underage workers. Regardless of local laws, Nuro does not hire workers under the age of 18, except in limited cases such as for work-study or supervised internships. We encourage the development of potential future employees using internships or student worker programs. However, these programs should be designed for the benefit and include training of the students. Participants in such programs may not perform work that is likely to endanger their health or safety, and all participants are fairly compensated for their work based on local laws.

Freedom of Association

We respect our employees’ right to join, form or not to join a labor union as permitted by law, without fear of reprisal, intimidation, or harassment. Where employees are represented by a legally recognized union, we are committed to establishing a constructive dialogue with their freely chosen representatives.

Environmental Protection

Nuro strives to reduce the impact to the environment of goods delivery by designing zero-emission vehicles that replace trips by personally-owned vehicles powered by fossil fuels, by using renewable energy to power our electric vehicles, and by taking steps to reduce our environmental footprint.

We recognize the significant implications regarding respect for human rights that land use and water use across our value chain may have, and that historically, businesses’ land use and water use decisions have significantly impacted marginalized groups. We recognize that water is a human right and respect the human need for sustainable water supplies, safe drinking water, and protection of both ecosystems and communities through proper sanitation.

Reporting Concerns

As part of our commitment to providing a workplace that encourages feedback and fosters psychological safety, Nuro Listens is a confidential and anonymous hotline that allows Nurons to report any issues or concerns. Any violation of this policy should be reported immediately. We will not tolerate any retaliation for reporting any concerns. Employees may file a report via the Nuro Listens portal from anywhere in the world via the internet or a toll free number, or via text in North America. Employees also have the ability to report concerns directly to the human resources or legal departments.

Members of the community can also contact Nuro directly with any feedback, by emailing us at feedback@nuro.ai or by calling 1-833-NURO-BOT.

Sustainability Position Statement

At Nuro, our mission is to better everyday life through robotics. We measure our success by how many people’s lives are substantially improved by our products.

We believe that the work we are doing at Nuro can promote more efficient use of our resources, our time, and our attention. For all of us. But only if we do it correctly.

We recognize that our communities face environmental and social issues with long histories, and they will require solutions that go well beyond technology. But we believe autonomous and electric goods delivery can ameliorate these issues. We are committed to building a business that lowers the cost of goods delivery, and thereby improves equitable access. We’re also focused on helping to decarbonize the economy.

At Nuro, we strive to judge ourselves based on our actions. We aim to deliver a service that will have a meaningful impact on sustainability, and take action to improve the sustainability of our own business.

“Our technology will be a part of daily life, driving on the streets where our children play, our pets walk, and where we live. All of this is to say that we have to make sure that what we are doing is right and safe, not just the easiest path. We put long-term interests ahead of short-term convenience… We believe that by being transparent and working together, we will build the greatest technology in the world.”

- Jiajun Zhu, Nuro Co-Founder, What Drives Nuro’s Culture

ESG Framework

We organize our sustainability efforts into three workstreams: Governance, Sustainable Products and People. Within those workstreams, we have identified eleven material topics. This framework focuses us on the most important topics and helps us communicate consistently with stakeholders.

Governance

  1. Corporate governance and business ethics
  2. ESG management
  3. Sourcing and supply chain
  4. Public policy and advocacy

Sustainable Products

  1. Climate
  2. Product Safety
  3. Data Privacy and Security
  4. Design for Environment

People

  1. Diversity and inclusion
  2. Employee health and safety
  3. Community engagement

ESG Guiding Principles

  • Focus on impact: focus on actions that have the greatest material impact on sustainability.
  • Prioritize safety: on the road, in our facilities, and in the way we design our products.
  • Bake sustainability into the business: we will measure our success by how many people’s lives are substantially improved by our products.
  • Bring others along: Be inclusive, and collaborate with other stakeholders when possible.
  • Be transparent and authentic about our sustainability progress—even when we’re not perfect.

Supporting Documents

Our ESG Position Statement is supported by policies on specific topics:

  • Code of Business Conduct and Ethics: Intends to deter wrongdoing and to promote business conduct consistent with our core values.
  • Supplier Code of Conduct: Aims to ensure that working conditions in our supply chain are safe, that workers are treated with respect and dignity, and that our suppliers’ operations are conducted in a manner consistent with protecting the natural environment.
  • Environment, Health and Safety Policy: Reflects our commitment to conducting our operations in a way that minimizes impact on the environment and creates a healthy and safe workplace.
  • Labor and Human Rights Policy: Formalizes our commitment to uphold and respect these rights and the values they represent.
  • Privacy Policy: Describes how Nuro handles personal information in connection with our business practices, including our delivery services, websites, mobile applications, retail partner programs, and when the public otherwise interacts with us.

Governance and Oversight

We have formalized ESG management and oversight mechanisms to ensure sustainability is embedded into decision-making processes and that we hold ourselves accountable for our ESG performance.

  • Board of Directors: Provides oversight on ESG program.

  • Operating Committee: Sets our ESG course and ensures appropriate resources are allocated to initiatives.

  • ESG Steering Committee: A cross-functional group of leaders from every area of the company, the ESG Steering Committee is responsible for the development and implementation of ESG policies and programs, as well as tracking and reporting ESG performance indicators.