Subcontractor and Supplier Code of Conduct

I. Labor
We respect human rights. We stand against slavery, servitude, debt bondage, human and sex trafficking, and unlawful child labor. We expect Suppliers to do the same and to comply with all fair labor laws, operate safe workplaces that are free from discrimination and harassment, provide equal opportunities regardless of protected status, and pay fair wages.

II. Environment/Sustainability
We respect the environment. Suppliers must follow all environmental laws and uphold the Company’s efforts to maintain sustainable practices.

III. Regulatory Compliance
We respect the law. Suppliers must comply with all applicable laws and regulations.

IV. Privacy, Confidentiality and Information Security
We respect privacy. Suppliers must protect the Company’s and its customers’ and employees’ confidential assets and information to which it has access. Suppliers must design and maintain technical and organizational measures to provide appropriate protections for this information. Suppliers must only use, access, and disclose personal data and confidential information provided by or on behalf of the Company as permitted by and necessary to perform their agreements with the Company.

V. Anti-Bribery and Corruption
We stand against bribery and corruption. Suppliers must not offer anything of value to public officials to improperly influence decisions or obtain or retain an unfair business advantage. “Anything of Value” includes cash, gifts, travel, meals, entertainment, lodging, donations, loans, employment, and tangible or intangible items. “Public Officials” include (A) employees or representatives of (1) national, state, local, or other governments including entities owned or controlled by them, (2) political parties, (3) public international organizations, or (4) members of a royal family; (B) political parties or candidates; and (C) anyone acting for or on their behalf.

VI. Prohibited Parties & Transactions
We comply with government trade restrictions. Our Suppliers are not, are not owned by or acting on behalf of, and will not engage on the Company’s behalf, anyone (A) listed on a government sanctions or prohibited party list, (B) located in or incorporated under the laws of a sanctioned or embargoed country or (C) otherwise a target of sanctions that would prohibit or restrict the Company from engaging with them.

VII. Transparency
We value transparency. Suppliers must have a transparent policy for reporting workplace concerns that protects individuals from retaliation. If legally permitted, Suppliers must promptly forward any subpoenas, regulatory requests, media inquiries, or other third-party requests concerning the Company. Suppliers must provide supporting documentation for any expenses submitted for reimbursement. On request, Suppliers must provide information necessary to confirm their compliance with this Code, our agreements, and applicable law.

VIII. Responsibility
We value accountability. Suppliers must ensure subcontractors comply with the Code and take responsibility for their actions. If Suppliers violate this Code, the Company may permit them to respond and correct it – unless the violation is severe or incurable or there is a violation of law.