This Supplier Code of Conduct (“Code”) reflects the values and policies of KIK Custom Products Inc. and its direct and indirect subsidiaries (“KIK”). This Code applies to all KIK vendors and suppliers, including their sub-tier suppliers and subcontractors (collectively “Suppliers”).

By entering into a supplier agreement, accepting a purchase order, or providing goods or services to KIK, Suppliers agree to comply with this Code in connection with the products or services that they sell to KIK, and to confirm adherence to these requirements throughout their supply chains through appropriate due diligence measures and contractual controls.

1. Compliance with all Laws

Suppliers must comply with all applicable national, regional, and local laws and regulations, including those related to labor and employment, immigration and authorization to work, health and safety, environmental protection, and fair business practices.

2. Labor and Employment Practices

Suppliers must maintain fair and lawful labor practices, and must:

• Verify each worker’s legal right to work and that the worker’s age meets or exceeds the minimum working age;
• Never require workers to lodge original identification papers or monetary deposits upon starting work;
• Compensate workers fairly, but in no case less than the applicable minimum wage, for all hours worked in accordance with applicable law, including payment of all overtime premiums and legally mandated benefits;
• Ensure working hours comply with legal limits and include appropriate periods of rest;
• Treat workers with dignity and respect and prohibit harassment, abuse, corporal punishment, or any cruel or abusive disciplinary practices;
• Prohibit discrimination or unfair treatment based on legally protected characteristics; and
• Respect workers’ right to organize, collectively bargain, and join a union or trade association of their choice.

3. Health and Safety

Suppliers must provide a safe and healthy work environment and take appropriate measures to prevent workplace injuries and occupational illness.

4. Child labor and Human Trafficking

Suppliers must not use forced, bonded, or indentured labor, nor engage in human trafficking. Suppliers must under no circumstances employ individuals under the age of 16. Workers under the age of 18 must not perform hazardous work, work that interferes with schooling, or work during any legally prohibited timeframe.

5. Environmental Protection

Suppliers must comply with all national, regional, and local environmental laws applicable to their business and must responsibly manage wastewater, stormwater, waste, air emissions, and recyclable materials. Suppliers must handle, store, transport, and dispose of chemicals and hazardous waste properly.

6. Responsible Sourcing

Suppliers must ensure that goods supplied to KIK are not produced using labor or materials sourced from parties subject to economic sanctions imposed by the United States, Canada, South Africa, Australia, or the European Union or otherwise in violation of applicable trade laws.

Suppliers must responsibly source conflict minerals such as tin, tungsten, tantalum, and gold, and comply with all laws, regulations, and international standards related to these conflict minerals so as to avoid contributions to conflict or human rights abuses. KIK prohibits the use of conflict minerals from noncompliant smelters.

Suppliers must ensure their supply chains are not used for illegal or improper purposes, including supporting smuggling, terrorism or fraud.

7. Anti-Bribery and Corruption

Suppliers must comply with all applicable anti-bribery and anti-corruption laws and must not, directly or indirectly, offer, promise, authorize, or provide anything of value to improperly influence any business decision or obtain an improper advantage.

8. Fair Dealing

Suppliers must compete fairly and solely on the basis of their products and services. Any Supplier must notify KIK if it becomes aware of any personal interests, activities or relationships of a KIK employee that interferes with objective business decisions.

Suppliers must not offer KIK employees travel, frequent meals, or expensive gifts. Suppliers are strictly prohibited from offering cash or cash equivalents, such as gift cards, to KIK employees.

Suppliers must not share KIK’s confidential or competitively sensitive information with third parties or improperly provide KIK with such information regarding KIK’s competitors.

9. Reporting

Suppliers must maintain a mechanism through which their workers can report their concerns anonymously and offer protection against retaliation. All reports must be promptly investigated and appropriately addressed.

10. Business Records

Suppliers are expected to maintain accurate, transparent, and detailed records of their business with KIK, including their compliance with this Code.

11. Updates to this Code of Conduct

KIK reserves the right to update this Code from time to time without notice. Suppliers are responsible for reviewing the most current version and ensuring ongoing compliance with its requirements.

12. Auditing

KIK reserves the right to assess, audit and monitor Suppliers’ compliance with this Code and to take appropriate steps to address any non-compliance. KIK also reserves the right to discontinue any relationship if KIK determines that there has been a violation of this Code. KIK expects Suppliers to cooperate with KIK in all due diligence activities, including providing data and information necessary for KIK to conduct investigations or meet its reporting obligations regarding activities in its supply chain.