ETHICS AND INTEGRITY

To maintain and strengthen high ethical standards, SMI created an ethics training program for employees which emphasizes the importance of business ethics and integrity in the workplace.

Additionally, SMI has developed an updated Code of Ethics and Business Conduct with enhancements to integrity and safety. These improvements provide more concise guidance on preventing integrity breaches and reporting them if they do occur. The updated Code is set to be distributed across all SMI employees in mid-2023.

SMI maintains an anonymous whistle-blower hot line for all stakeholders to report incidents of wrongdoing and noncompliance. Any reported incidents are reviewed and appropriately handled by the human resources department. The hot line promotes accountability and ensures stakeholders have a mechanism to report ethical concerns.

All ethics and integrity matters are overseen by the Chief Legal Officer and Senior Vice President of Human Resources.

Human Rights Commitments At Smi

In conjunction with the Company’s commitment to the Ten Principles of the UN Global Compact, SMI complies with all laws regarding freedom of association, privacy, collective bargaining, immigration, work hours and wages, forced, compulsory, and child labor, human trafficking, corruption, and discrimination.