SOURCING PROCEDURE

Offering Business Courtesies: Any employee who offers a business courtesy must assure that it cannot reasonably be interpreted as an attempt to gain an unfair business advantage or otherwise reflect negatively upon [COMPANY NAME]. An employee may never use personal funds or resources to do something that cannot be done with [COMPANY NAME] resources. Accounting for business courtesies must be done in accordance with approved company procedures.

Other than to our government customers, for whom special rules apply, we may provide nonmonetary gifts (i.e., company logo apparel or similar promotional items) to our customers. Further, management may approve other courtesies, including meals, refreshments or entertainment of reasonable value, provided that:

 The practice does not violate any law or regulation or the standards of conduct of the recipient’s organization.

 The business courtesy is consistent with industry practice, is infrequent in nature and is not lavish.

 The business courtesy is properly reflected on the books and records of [COMPANY

NAME].

SOURCING PROCEDURE

The purpose of this policy is to ensure that [COMPANY NAME] collaborates with suppliers who share our values regarding sustainability.viii We expect that our suppliers, as a minimum, follow our human rights and sustainability principles when conducting their own business. This is the starting point for entering into and maintaining a business relationship with [COMPANY NAME].

The following applies to all suppliers providing products and/or services to [COMPANY NAME]:

 Suppliers must not utilize involuntary labor of any type. This shall include, but not be limited to, forced, indentured, bonded or prison labor.

 Suppliers must not utilize child labor. For purposes of the Code, a “child” will be considered any person younger than (i) fifteen (15) years old; (ii) the minimum age for completing compulsory education in the country of manufacture; or (iii) the minimum age for employment in such country, whichever is the highest.

 Suppliers must treat each of their employees with respect and dignity. As such,

Suppliers shall not subject any employee to physical, sexual, verbal or other forms of harassment, coercion or abuse.

 Suppliers shall not subject any employees or applicants for employment to unlawful discrimination.

 Suppliers must pay each of their employees at least the minimum wage, and supply the minimum benefits, required by applicable local laws. In the absence of applicable local laws, Suppliers shall provide minimum wages and benefits consistent with industry practice in such locations.