Supplier Code of Conduct

Kingsdown Group is strongly committed to conducting its business in a lawful and ethical manner,engaging only with suppliers that are committed to the same principles, to ensure a long-term, sustainable, and successful relationship for all parties.

This Supplier Code of Conduct (the “Code of Conduct”) describes the requirements and ways of working that Kingsdown Group applies together with its upstream supply chain third parties. In some cases, this Code of Conduct goes beyond compliance with applicable laws and draws upon internationally recognized standards to advance social and environmental responsibility. When differences arise between the standards set forth in this Code of Conduct and legal requirements, the stricter standard shall apply, in compliance with applicable law.

Violations of this Code of Conduct may jeopardize the supplier’s business relationship with Kingsdown Group, up to, and including termination. This Code of Conduct applies to Kingsdown Group’ suppliers and their subsidiaries, affiliates, and subcontractors (each a “supplier”) providing goods or services to Kingsdown Group, or for use in or with Kingsdown Group products.

Suppliers shall continuously exercise due diligence to reasonably verify conformance with this Code of Conduct within their entire supply chain. Suppliers shall develop policies and management systems to identify risks and migration measures to correct deviations from this Code of Conduct among their own suppliers.

Kingsdown Group believes the protection of human rights throughout our supply chain is a critical part of our mission and is committed to respecting all human rights across our full value chain. This protection applies to all individuals, inclusive of migrant workers, women, and children.

A. Forced Labor: Suppliers shall not use involuntary, enslaved, forced, prison, or debt bondage labor of any kind. Suppliers shall not be involved in human trafficking activity and shall not use any corporal punishment, physical or psychological abuse, or threats of violence, or coercion to secure or retain their workers. Suppliers shall not require payment of fees or the surrendering of identification as a condition of employment. All workers shall be provided with the terms of their employment in a language they understand.

B. Child Labor: Suppliers shall not employ children that are under 15 years of age, or 14 years of age where local law allows, or under the legal minimum age for employment in the country, whichever is greatest. Any employment of workers under the age of 18 shall not interfere with schooling or vocational education and shall not expose children to risks that could cause health, safety, or moral harm, as specified in the ILO Worst Forms of Child Labour Convention.

C. Anti-Discrimination and Fair Treatment: Suppliers shall treat all workers with respect. There will be no unlawful discrimination, harassment or abuse of any kind based on race, caste, national origin, religious affiliation, age, disability, gender, physical appearance, marital status, sexual orientation, union membership, veteran status, political opinion, or HIV/AIDS status in relation to employment practices such as hiring, promotion, compensation, termination, retirement, or any other aspect of their work.

D. Wages and Benefits: Suppliers shall provide compensation directly to employees that includes wages, overtime pay, and benefits that meet or exceed the legal minimum standards. Where there is no legislated minimum wage, suppliers shall provide wages that are comparable to relevant standard industry wages. Wages shall be paid promptly and in full. Wage deductions shall not be used to keep workers tied to the employer or to their jobs.

E. Work Hours and Overtime: Suppliers shall ensure that work schedules and overtime are consistent with all applicable laws and collective bargaining agreements, whichever affords the greater level of protection, including maximum hour and rest period laws. Workers shall receive annual leave and public holidays in accordance with local law.

F. Ethics and Integrity: Suppliers must adhere to the highest ethical standards and comply with all applicable laws, rules, and regulations. Specifically, they must fully comply with requirements related to bribery, labor, and anti-corruption laws (such as the U.S. Foreign Corrupt Practices Act, UK Bribery Act, and Bill S-211, known as Fighting Against Forced Labour and Child Labour in Supply Chains Act). Gifts and entertainment should not be used to obtain improper advantages or influence.

G. Freedom of Movement: Workers shall have unrestricted access to necessities such as clean drinking water and toilets during both work and non-work hours at the work site or in employer-provided or arranged housing. Workers’ freedom of movement shall not be unreasonably restricted.

H. Data Privacy and Security: Suppliers must protect the privacy of individuals and the security of confidential assets and information. Confidential assets and information (including those of clients) must be safeguarded.

I. Inclusion and Diversity: Kingsdown Group fosters an inclusive culture and expects suppliers to celebrate diversity while rejecting any form of discrimination. Suppliers should promote inclusion and diversity within their own operations.

J. Wellbeing, Health, and Safety: Suppliers should prioritize the wellbeing, health, and safety of their workforce. Suppliers shall meet or exceed all applicable health and safety laws, regulations, and industry standards in this area. Suppliers shall provide workers with a safe, clean, and healthy work environment. Non-retaliation policies for reporting workplace concerns are encouraged.

K. Environment: Suppliers are expected to act responsibly toward the environment. In addition to complying with all applicable environmental laws, we expect suppliers to continually improve their own environmental performance, including, but not limited to, reducing greenhouse gas emissions, reducing, or optimizing the use of water, energy, and agriculture inputs, and minimizing water pollution and waste. Kingsdown Group may require suppliers to provide information regarding environmental standards and environmental metrics and measures.

L. Confidential Information and Intellectual Property: Kingsdown Group’s confidential information must be protected and must not be used inappropriately or to support insider trading activity. Suppliers shall respect intellectual property rights and safeguard customer and other protected information. Suppliers shall manage technology and know-how in a manner that protects intellectual property rights, protected information, and business operations to protect itself and its customers’ business continuity.

M. Origin Mapping: Suppliers must be capable of disclosing potential sources of primary origin associated with their products or services provided to Kingsdown Group. Kingsdown Group may ask suppliers for supply chain mapping back to the origin to facilitate assessment of upstream supply chain compliance. If suppliers do not have this capability today, Kingsdown Group expects them to share a path towards compliance.

N. Grievances: Suppliers shall provide grievance mechanisms that are transparent, anonymous (where allowed by law), unbiased, responsive, confidential, and communicated to workers across their supply chain.

O. Audits, Assessments, and Compliance: Kingsdown Group may audit compliance with this Code of Conduct. Suppliers must respond within the allotted time to all audits, assessments, and document requests from Kingsdown Group related to the delivery of their products or services. If an audit identifies a violation of this Code of Conduct, the supplier shall act promptly to correct the situation to Kingsdown Group’s satisfaction.

P. Conflict Materials: Our suppliers who provide components, parts or materials containing Conflict Minerals must work with us to achieve conflict-free sourcing. Components, parts, or materials, which either directly or indirectly contribute to conflict, are unacceptable. Our suppliers must define, implement and communicate to sub suppliers their commitment to responsible sourcing and legal compliance. Our suppliers must work with sub-suppliers to ensure traceability of these Conflict Minerals at least to the smelter or refiner level. Traceability information must be maintained and recorded for five years and provided to us upon request. Our suppliers are encouraged to support industry efforts to enhance traceability and responsible practices in global mineral supply chains.