Polycor Inc.
| Date Issued | April 5, 2024 |
| Date Updated | April 5, 2024 |
| Approved by | Chief Executive Officer |
SUPPLIER CODE OF CONDUCT
The culture of Polycor Inc. and each of its subsidiaries (collectively “Polycor”) is founded on our values of Ownership,
Merit, Integrity and Respect that guide our behavior at all times and are essential to the pursuit of our corporate vision
to build the world’s leading natural stone company. These values require to conduct business with the highest ethical
standards. Reflecting this commitment and our values, all directors, executives, managers and employees of Polycor
are required to comply with Polycor’s Code of Conduct. To maintain these standards, Polycor requires all Polycor
suppliers and their subcontractors (“Suppliers”) to comply with the requirements and promote the values outlined in
this Supplier Code of Conduct (“Code”). The requirements of this Code are supplemental to the provisions of any
agreement or contract between Polycor and a Supplier and are legally binding on the Supplier.
If you have any questions with respect to this Code or would like to report a violation of this Code, please contact the Polycor Legal Department at legal@polycor.com.
Compliance with Laws, Rules and Regulations
Suppliers will operate in compliance with the applicable laws, rules and regulations of the jurisdictions in which they operate at all times.
Health and Safety
Suppliers will provide their workers with a safe and healthy working environment in accordance with all applicable laws and regulations, including providing access to information and instructions on safe work practices and hazard prevention.
Anti-Bribery
Suppliers will not solicit, accept, offer or give bribes, kickbacks or facilitation payments and will not otherwise engage in any form of bribery, extortion or embezzlement nor take any action that could violate, or could cause Polycor to violate, any anti- bribery laws or regulations. Any hospitality or entertainment offered by Suppliers to Polycor employees must be modest and infrequent and any gifts must be customary or business related and of nominal value.
No Child Labor or Forced Labor
Polycor does not engage in any form of human trafficking, does not use child labor or forced labor and does not tolerate these practices at any level of its supply chain. Suppliers must not hire anyone who is not of the minimum working age under local laws, nor force anyone to perform a task or provide a service against their will or under duress. Supplier employees must be free to terminate their employment with reasonable notice and not be required, in order to work, to submit their passport or work permit.
Compensation and Hours of Work
Suppliers will comply with all requirements under applicable employment laws including, without limitation, those regarding wages, working hours, overtime and benefits.
Discrimination, Harassment and Violence
Suppliers will maintain a workplace that is free from discrimination, harassment and violence and will notably ensure employment is not based on a person’s belief or any other personal characteristics.
Collective Bargaining
Suppliers will respect the legal right of workers to bargain collectively and to exercise lawful rights of free association.
Environment
Suppliers will comply with all environmental laws and regulations and report any instance of environmental non-compliance to the authorities. Suppliers should conduct their business in a manner that reduces their impact on the environment.
Responsible Sourcing of Minerals
Suppliers will take reasonable steps to ensure products provided to Polycor do not contain conflict minerals.
Information Security
Suppliers shall have appropriate policies, procedures and technical measures in place to comply with applicable privacy laws and regulations,
industry standards and contractual requirements, and to safeguard and prevent any unauthorized access to personal or confidential data or information provided by Polycor.
Due Diligence and Reports
Suppliers must be able to provide evidence of a due diligence process, including the establishment of policies and procedures, to ensure
compliance with this Code, Suppliers will comply with requests from Polycor, from time to time, to report on compliance on one or more of the matters included in this Code.
Audits
Polycor reserves the right to audit, directly or through third parties, Suppliers to ensure compliance with this Code, which may include, without limitation, employee interviews, facility inspections and records review. Polycor may periodically require a Supplier to provide it with written confirmation of its compliance with this Code.
