ValcoMelton Japan

Supplier Code of Conduct

V1.0 – 28 June 2024

This Supplier Code of Conduct applies to any organization that (i) contracts with Valco Melton to supply goods or services to Valco Melton, (ii) contracts with Valco Melton for the purposes of serving Valco Melton clients, or (iii) has entered into a business relationship with Valco Melton to establish eminence in the marketplace, including alliance relationships and reselling relationships (“Supplier”).

Valco Melton’s expectation is that its suppliers support its commitment to doing good for business, Valco melton stakeholders and their communities. This Code of Conduct (“Supplier Code”) outlines our expectations of Suppliers. Nothing in this Supplier Code supersedes more stringent provisions in any other more specific contract.

Suppliers are expected to use processes that comply with applicable local laws where they conduct business. Where the local provisions of law and this Supplier Code address the same subject, to the extent legally permitted, Suppliers should apply the provision which furthers the intent of this Supplier Code to the greater degree. Suppliers should establish and enforce policies which comply and align with the expectations of this Supplier Code. They are also expected to apply comparable standards downstream in their own supply chains.

Violations of this code should be reported upon discovery by the Supplier. Any violation may result in any of the following, or other, similar actions: asking the Supplier to audit its own organization or supply chain and to report on its findings; recommending or requiring corrective-action plans; or making the Supplier a non-preferred supplier. In some cases, the contract with the Supplier may be terminated.

Human Rights

Humane Treatment

Supplier shall treat workers with dignity and respect and not subject them to demeaning conditions.

Harassment

Supplier shall foster a culture and workplace that does not tolerate harassment, including sexual harassment, threats of harassment, or retaliation for reporting harassment.

Labor

Forced Labor

Supplier shall not use forced or involuntary labor nor demand work/service from an individual under threat or coercion. Work must be conducted based on freely agreed terms. Supplier shall not withhold or destroy, conceal, confiscate or deny access by workers to workers’ identity or immigration documents. Supplier shall not require nonprofessional migrant workers to bear any costs or fees associated with their recruitment, travel or migration processing.

Child Labor

Supplier shall not exploit child labor and shall not employ any workers under the applicable local minimum legal working age. Employment of workers under the age of 18 should not interfere with their compulsory education and should not, by the nature of the work or the circumstances in which it is carried out, be likely to harm their health, safety, or morals.

Discrimination

Supplier shall foster a culture that seeks to promote equal opportunity for all. Supplier shall not tolerate discrimination on the basis of gender, race, religion, age, disability, gender identity, sexual orientation, or those categories protected by local law. Job candidates and employees are expected to be evaluated based on their ability to perform the job.

Wages, working hours and other conditions

Supplier shall meet applicable standards regarding working conditions across its entire workforce, including, without limitation, laws, regulations, and standards relating to the payment of the minimum legal wage or a wage that meets local industry standards, whichever is greater; the observation of legally mandated break and rest periods; and the health and safety of the workers in the workplace.

Freedom of association and non-retaliation

Supplier should nurture an environment where business standards are clearly understood and there are clear channels for individuals to communicate openly with management without threat of retaliation, intimidation, or harassment. Additionally, Supplier should respect the legal rights of workers to freedom of association and not hinder the rights of workers to legally organize and join associations.

Health and safety

In addition to meeting minimum legal requirements for working conditions, Supplier is expected to provide a safe, healthy work environment (e.g., clean facilities, properly
maintained equipment, sufficiently lighted and ventilated facilities) and take necessary precautions to prevent accidents and injury.

Environment

Resource efficiency and waste minimization

Supplier shall seek to improve resource efficiency and reduce resource consumption including of raw materials, energy, water, and fuel. Supplier is expected to make reasonable efforts to eliminate or reduce levels of waste (both solid and wastewater) generated and to increase landfill diversion, reuse, and recycling. Supplier is encouraged to develop and use environmentally friendly innovations and practices that reduce negative environmental
impacts.

Pollution and emissions reduction

Supplier shall take reasonable steps to minimize emissions of greenhouse gases and of toxic and hazardous pollutants. Supplier is encouraged to track greenhouse gas emissions and to set science-based (in line with the Paris Agreement) greenhouse gas reduction goals.

Integrity, Ethics and Anti-corruption

Business integrity

Supplier shall not engage in any illegal or unethical behavior. Supplier is expected to uphold standards of fair business practices. Supplier shall endeavor to maintain its own confidential process to enable employees and contractors to report incidents of unethical behavior.

Corruption/bribery/financial crimes

Supplier shall neither make bribes nor accept them, nor induce or permit any other party to make or receive bribes on its behalf nor cause other parties, including Valco Melton,to violate any applicable anti-corruption or antibribery laws when working on behalf of or with the other parties including Valco Melton. Supplier shall use reasonable practices to prevent bribery in all forms and shall support efforts to fight corruption. Supplier shall not engage in or assist any third party with any money laundering, terrorist financing or other financial crime activities.

Gifts, entertainment and hospitality

Supplier shall not offer, accept or solicit any gifts, entertainment, or hospitality whereby there is reason to believe, or a reasonable and informed third party would likely conclude, that there may be intent to improperly influence decisions or impair objectivity related to its business dealings.

Conflict of interest

Supplier shall not allow bias, conflict of interest, or inappropriate influence of others to override its professional judgments and responsibilities. Supplier shall voluntarily declare any such conflicts involving Valco Melton personnel.

Reporting Violations

To report questionable behavior or a possible violation of this Supplier Code, you are encouraged to work with your primary Valco Melton contact in resolving your concern. If that is not possible or appropriate, you may report the issue to the relevant Valco Melton Human Resources Officer or by using the corporate contact channels.

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