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Supplier Code of Conduct

EFFECTIVE DATE: FEBRUARY 1, 2022

NAVIGATING THESE TERMS

I. SLAVE LABOR AND HUMAN TRAFFICKING

Supplier will not use forced or involuntary labor of any type and will not engage in human trafficking at any level of its supply chain. Human trafficking involves any use of force, fraud, or coercion to obtain some type of labor or commercial sex act and is strictly prohibited.

II. CHILD LABOR

Supplier will not use child labor. The term “child” refers to any person employed under the age of 16 (or under the age of 15 where the law of the country permits), or under the age for completing compulsory education, or under the minimum age for employment in the country, whichever is greatest.

III. WAGES & BENEFITS

Supplier will, at a minimum, comply with all applicable wage and hour laws and regulations, including those relating to minimum wages, overtime hours, piece rates and other elements of compensation; and provide legally mandated benefits.

IV. WORKING HOURS

Supplier will not exceed prevailing local work hours and will appropriately compensate overtime. Workers shall not be required to work more than 60 hours per week, including overtime, except in extraordinary business circumstances and with their consent. In countries where the maximum work week is less, that standard shall apply. Employees should be allowed at least one day off per seven-day week.

V. NONDISCRIMINATION

Supplier will not discriminate in hiring and employment practices on grounds of race, religion, age, nationality, social or ethnic origin, sexual orientation, gender, gender identity or expression, marital status, pregnancy, political affiliation or disability.

VI. RESPECT & DIGNITY

Supplier will treat all employees with respect and will not use corporal punishment, threats of violence or other forms of physical coercion or harassment.

VII. FREEDOM OF ASSOCIATION

Supplier shall respect the legal rights of employees to join or to refrain from joining worker organizations, including trade unions. Supplier has the right to establish favorable employment conditions and to maintain effective employee communication programs as a means of promoting positive employee relations that make employees view third-party representation as unnecessary.

VIII. HEALTH & SAFETY

Supplier will provide their employees with a safe and healthy workplace in compliance with all applicable laws and regulations. Consistent with these obligations, Supplier must have and implement effective programs that encompass life safety, incident investigation, chemical safety, ergonomics etc., and provide the same standard of health and safety in any housing that is provided for employees.

IX. PROTECTION OF THE ENVIRONMENT

Supplier will operate in a manner that is protective of the environment. As a minimum, supplier must comply with all applicable environmental laws, regulations and standards, such as requirements regarding chemical and waste management and disposal, recycling, industrial wastewater treatment and discharge, air emissions controls, environmental permits and environmental reporting. Supplier must also comply with any additional environmental requirements specific to the products or services being provided to Buyer as called for in design and product specifications and contract documents.

X. LAWS, INCLUDING REGULATIONS AND OTHER LEGAL REQUIREMENTS

Supplier will comply with all applicable laws and regulations in all locations where they conduct business and/or distribute and import

XI. ETHICAL DEALINGS

Buyer expects the supplier to conduct business in accordance with the highest ethical standards. Supplier must strictly comply with all laws and regulations on bribery, corruption, and prohibited business practices, including compliance with the Foreign Corrupt Policies Act (FCPA). Violations of this paragraph will be immediate grounds for buyer to terminate any supplier relationship.

XII. MONITORING/RECORD KEEPING

Supplier must maintain documentation necessary to demonstrate compliance with Buyer’s Supplier Code of Conduct and must provide Buyer with access to that documentation upon request.