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BlueTriton Guiding Principles

BlueTriton Brands, Inc. (“BlueTriton”) believes in operating with transparency, integrity and fairness in all our relationships and anticipates that our “Partners” – our vendors, suppliers, consultants, contractors, agents, subcontractors, and their employees will be guided by the same principles. These BlueTriton Guiding Principles (“Principles”) were developed to provide a framework to guide all BlueTriton relationships. These Principles set forth the minimum standards that we ask our Partners to respect and adhere to; however, they are not intended to replace your legal or other compliance obligations.

By providing products or services to BlueTriton, Partner warrants and guarantees, on an ongoing basis, to following these Principles, as updated from time to time:

a. Business Integrity. Partners will always act with integrity and will never, directly or through intermediaries, offer or promise any personal or improper advantage in order to obtain or retain a business or other advantage from a third Party, whether public or private. Partner shall never accept any such advantage in return for any preferential treatment from a third party.

b. Compliance with Laws. Partners shall always comply with all applicable federal, state, provincial, and local laws, rules, ordinances, regulations, and guidelines, voluntary industry standards, and other obligations, in connection with the Partner’s business as well as its dealings with BlueTriton.

c. Sustainability. Partner shall continuously strive to improve the efficiency and sustainability of its operations, which will include water conservation programs. Partner shall comply with all applicable environmental, occupational health and safety regulations and international conventions on environmental standards. Partner shall promote the safe and environmentally sound development, manufacturing, transport, use and disposal of its products. Partner shall ensure that product quality and safety meet the applicable requirements. Partner shall protect its employees’ and neighbors’ life and health, as well as the general public at large against hazards inherent in their processes and products. Partner shall use resources efficiently, apply energy-efficient and environmentally friendly technologies and reduce waste, as well as gas house gas and other emissions to air, pollution, water and soil. Partner shall minimize its negative impact on biodiversity, climate change and water availability to protect the livelihood of people and prohibit unlawful eviction and unlawful taking of land, forests and waters. Partner shall disclose, or communicate annual progress towards disclosing, the following sustainability performance metrics:

• Annualized Greenhouse gas emission footprint intensity for products purchased by BlueTriton, and when possible, the footprint should be in units of mass of CO2e per mass of products purchased by BlueTriton, i.e., tons of CO2e per ton of product purchased. This disclosure should cover scope 1 and scope 2 emission categories relevant to Partner’s business per the Greenhouse Gas Protocol. If this information is not directly disclosed to the company, other acceptable disclosure pathways include CDP, an annual sustainability report, or progress towards setting or maintaining a greenhouse gas emission reduction goal aligned with the Science-Based Target Initiative.

•Annualized recycled content of the Partner supplied products used in the packaging of the BlueTriton’ s products. If possible, recycled content rates for Partner’s products should be classified and reported as post consumer and post-industrial recycled content. Any agricultural and forestry developments and activities on local peoples’ land are subject to the free, prior and informed consent [FPIC] of the affected local communities, including indigenous peoples, with or without governmental consent for expansion. Partner shall work to preserve natural resources and conduct business in an ethical and collaborative way.

d. Labor Standard. Partner shall support the protection of internationally proclaimed human rights and fight forced and child labor (including modern slavery and human trafficking). Partner shall treat all employees with respect and will not under any circumstances, use or in any other way benefit from forced or compulsory labor and shall not use child labor in the manufacturing or packaging of any goods (it being understood that the term "child" herein refers to a person younger than the age of completing compulsory education, but in no case shall any child BlueTriton Guiding Principles 2 younger than fourteen years of age be employed in the manufacturing of goods). Partner shall only employ persons or engage and utilize third party providers who only employ or engage persons whose presence, is voluntary, and not to use prison labor, corporal punishment or other forms of mental or physical coercion as a form of discipline of its employees. Partner must ensure that its employees’ work is in compliance with all applicable laws and mandatory industry standards(1) pertaining to the number of hours and days worked. Partner’s employees must be provided with wages and benefits that comply with applicable laws and binding collective agreements, including those pertaining to overtime work and other premium pay arrangements. Partner shall not discriminate in hiring and employment practices on the grounds of criteria such as of race, color, religion, sex, age, physical ability, national origin, or sexual orientation.

e. Safety and Health. Partner and/or its contractor(s) shall provide employees with safe and healthy working environment and, where provided, safe housing conditions. At a minimum, potable drinking water, adequate sanitation, fire exits and essential safety equipment, access to emergency medical care, appropriately lit and equipped workstations must be provided. In addition, facilities must be constructed and maintained in accordance with the standards set by applicable codes and ordinances. All products and services delivered by the Partner and/or its contractor(s) must meet the quality and safety standards required by applicable law and with BlueTriton’s quality and safety requirements.

f. Trade Control. Partner will comply with all applicable export control, import, customs and economic sanctions laws and regulations of the United States and other governments (collectively, Trade Control Laws”) in its performance and in the import, export, re-export, shipment, transfer and use of products or services provided to BlueTriton. Trade Control Laws include, but are not limited to, the U.S. Export Administration Regulations, the Customs Modernization Act of 1993, Foreign Trade Regulations and the economic sanctions rules and regulations implemented under statutory authority and/or President's Executive Orders and administered by the U.S. Treasury Department's Office of Foreign Assets Control and any export or import requirements imposed by the U.S. Food and Drug Administration. Partners will not take part in any bribery, corruption or money laundering. Partners specifically agrees that it will not export, re-export, import or otherwise transfer, directly or indirectly through any third parties or otherwise, BlueTriton’ s Products to or from, or originating in other country that is designated as a sanctioned country by the U.S. Government or to, from or for use by any party included on, or owned or controlled by and party included on, any of the restricted party lists maintained by the U.S. Government, including, but not limited to, the Specially Designated Nationals List administered by the U.S. Treasury Department's Office of Foreign Assets Control and the Denied Persons List, Unverified List or Entity List maintained by the U.S. Commerce Department's Bureau of Industry and Security.

g. U.S. Foreign Corrupt Practices Act. Partner agrees, for itself and its employees, agents and intermediaries, that it will: (i) at all times comply with the U.S. Foreign Corrupt Practices Act; (ii) not pay, or offer to pay, and will not permit or suffer any agent, intermediary or employee to pay, or offer to pay, directly or indirectly, any money or thing of value, to any official of the government of any nation or political subdivision thereof, or any of their agencies, instrumentalities, corporations or ventures, or to any political party, official thereof, or any candidate, for the purposes of influencing the acts, omissions or decisions, in an official capacity, of such official, party or candidate in violation of his/her or its lawful duty or inducing him/her or it to exercise his/her or its influence to affect or influence any act or decision of such government or instrumentality or to obtain or retain business for the other party in violation of the U.S. Foreign Corrupt Practices Act or other applicable anti-bribery laws; and (iii) immediately notify BlueTriton should Partner become aware of information that suggests a possible violation of the US Foreign Corrupt Practices Act has occurred.

h. Not Discriminate. Partner will take affirmative action to ensure that applicants for employment, during the hiring process, and all employees are treated during employment without regard to their race, color, religion, sex, sexual orientation, gender identity or national origin (“Status”). Partner shall prohibit discrimination against qualified individuals based on their status as protected veterans or individuals with disabilities and prohibit discrimination against all individuals based on their Status. BlueTriton also supports these aspects in the selection of our Partners.

i. Audit and termination of the supply agreement. BlueTriton reserves the right to verify the Partner’s compliance with these Principles. In case BlueTriton becomes aware of any actions or conditions not in compliance with the Partner’s commitment, BlueTriton reserves the right to demand corrective measures. BlueTriton reserves the right to terminate any agreement with any Partner who does not meet its commitment. BlueTriton thanks you for your commitment to operating with transparency, integrity and fairness. The principles above are not intended to be an exhaustive list of Partner’s legal obligations or to limit Partner’s obligations. It is Partner’s responsibility to ensure that it complies with all laws applicable to its business operations and the provision or products and/or services to BlueTriton.

If Vendor is subject to a separate agreement with BlueTriton. any conflict between these Principles and any executed agreement shall be resolved in favor of the agreement. BlueTriton reserves the right to update these Principles from time to time, without notice and to verify your compliance herewith.

Should you have any concerns about illegal or improper conduct, please contact the AlertLine at 1-800-622-0829 from anywhere in the United States.

(1)© (2023) – BlueTriton Brands, Inc. 1 Including but not limited to: (i) Title VII of the Civil Rights Act of 1964, Sections 1981 and 1983 of the Civil Rights Act of 1866, the Age Discrimination in Employment Act and Executive Order 11141, the Equal Pay Act, the Americans With Disabilities Act and Sections 503 and 504 of the Rehabilitation Act of 1973, and any other federal, state, provincial, or local laws prohibiting discrimination, harassment, or retaliation in employment; (ii) Employee Retirement Income Security Act of 1974, Family and Medical Leave Act of 1993, and any other similar federal, state, provincial, or local laws; (iii) all laws governing or related to the payment of wages, including the Fair Labor Standards Act of 1938 and any state, provincial or local laws governing the amount, time, place, and manner of wage payments during employment and at termination, and all other wage and hour laws, including those governing the provision of accurate itemized wage statements, expense reimbursement, paid time off, posting and notice requirements, and other obligations; (iv) the Fair Credit Reporting Act, and all other federal, state, provincial, and local laws related background checks and drug testing; (v) all federal, state, and provincial tax laws, and laws related to unemployment, disability, and workers’ compensation insurance; and (vi) any other laws regulating employment. With respect to each such law, Partner will both perform the Plant Services and maintain and preserve documents related to the performance of the Plant Services as the law requires.