Supplier Code of Conduct

Introduction

RRC Polytech is committed to conducting business in an ethical, legal, and socially responsible manner. RRC Polytech expects its suppliers to adhere to equivalent standards.

The RRC Polytech Supplier Code of Conduct (“Code of Conduct”) sets out the minimum ethical standards and business conduct for service providers and their representatives, employees and subcontractors including vendors, consultants, manufacturers, fabricators, distributors, or any entity that provides RRC Polytech with goods or services (collectively, “Suppliers”).

RRC Polytech expects all its Suppliers to affirm their compliance with the standards in this Code of Conduct and ensure the standards are being upheld by each of their subcontractors. The expectations set out in this Code of Conduct draw upon international standards and best practices in the areas of corporate governance, human rights and sustainability set out in RRC Polytech’s Sustainable and Socially Responsible Procurement Policy and are designed to provide Suppliers with a clear understanding of how they can meet RRC Polytech’s standards and conduct their business activities in compliance with the laws and regulations of the countries in which they operate.

Where there is a conflict between the language in this Code of Conduct and any agreement for products or services between RRC Polytech and the Supplier, it is understood that the terms in the executed agreement will apply.

Important: RRC Polytech reserves the right to monitor a Supplier’s compliance with this Code of Conduct and audit a Supplier’s control environment. RRC Polytech is entitled to request information from its Suppliers as to their compliance with the principles of this Code of Conduct.

A violation of this Code of Conduct by a Supplier may lead to an evaluation and an investigation by RRC Polytech. The Supplier is expected to implement corrective actions as soon as reasonably practicable to address any contraventions of this Code of Conduct. Any failure to comply with this Code of Conduct, whether discovered as a result of the report of a violation or otherwise, will result in the Supplier being placed on enhanced monitoring and may result in the termination of the Supplier’s relationship with the Company, in accordance with the applicable agreement between the parties.

Compliance with Laws

In all their activities, Suppliers must ensure that they conduct themselves in an ethical manner in compliance with the applicable laws, rules and regulations each jurisdictions in which they operate. Where applicable local laws impose less restrictive obligations on Suppliers, Suppliers are expected to adhere to the standards of this Code. Where applicable local laws impose greater obligations on Suppliers, Suppliers must comply with such laws and regulations.

Employee Treatment

Suppliers must maintain workplaces characterized by professionalism and respect for the dignity of every individual with whom their employees interact, including respect for differences such as gender, gender identity, gender expression, race, colour, age, disability, sexual orientation, ancestry, place of origin, ethnic origin, citizenship, religion, creed, marital or family status, pregnancy, record of offences and any other characteristic protected by law. Suppliers must not tolerate harassment, discrimination, violence, retaliation or other disrespectful or inappropriate behaviour. Suppliers must respect the dignity of their own employees and others, adhere to principles of diversity and maintain a respectful workplace.

No Discrimination

Discrimination in employment means any distinction, exclusion or preference with respect to recruitment, hiring, firing, wages, working conditions or terms of employment made on the basis of personal characteristics unrelated to inherent job requirements, that impairs equality of opportunity or treatment in employment. Suppliers are strictly prohibited from discriminating or disciplining on the basis of gender, gender identity, gender expression, race, colour, age, disability, sexual orientation, ancestry, place of origin, ethnic origin, citizenship, religion, creed, marital or family status, pregnancy, record of offences or any other characteristic protected by local law. Where local laws do not prohibit discrimination, or where they allow for differential treatment, the Company expects Suppliers to be committed to non-discrimination principles and not to operate in a way that unfairly differentiates between individuals.

No Harassment or Abuse

Harassment is behaviour or communications, whether written or verbal, which a reasonable person would consider to cause offence or humiliation or affect the dignity of a person and, in the context of employment, results in an intimidating, hostile or offensive atmosphere. Suppliers must not engage in physical, mental, verbal, sexual or any other abuse, inhumane or degrading treatment, corporal punishment or any form of harassment, including verbal, physical and written conduct.

No Forced Labour

The use of forced or compulsory labour by Suppliers is strictly prohibited. This includes work or services not voluntarily performed that is exacted or coerced from a person under threat, force or penalty, or threatened abuse of law or legal process, including any kind of involuntary or compulsory, indentured or bonded labour, slavery, servitude or other slavery-like circumstances. Workers must not be required, as a condition of employment, to make a deposit of or surrender any government-issued identification, passports, work permits or any other documents necessary for free movement and termination of employment. Suppliers must allow their workers the right to leave work and freely terminate their employment, taking into account legal notice period requirements.

No Human Trafficking

Suppliers are prohibited from engaging in or benefiting from any form of human trafficking. This includes the recruitment, transportation, transfer, harbouring or receipt of persons, by means of the threat or use of force or other forms of coercion, abduction, fraud, deception, abuse of power or a position of vulnerability. Giving or receiving payments or benefits to achieve the consent of a person having control over another person for the purpose of exploitation is strictly prohibited.

No Child Labour

Suppliers must not employ individuals below the minimum age permitted by local law. Suppliers must operate in compliance with local laws and the core International Labour Organization (“ILO”) standards regarding child labour, including ILO Convention 138. Suppliers are also strictly prohibited from using child labour contrary to ILO Convention 182.

Health and Safety

Suppliers shall provide a safe and healthy working environment and comply with applicable local health and safety laws and industry standards to prevent accidents and injuries arising out of or occurring in the course of work, or occurring as a result of the operation of the Supplier’s facilities.

Freedom of Association and Collective Bargaining

Suppliers must comply with local laws regarding the activities of trade unions, work councils and their organizational activities. Suppliers shall recognize and respect the right of employees to freedom of association and collective bargaining in accordance with local laws. Workers and employers shall have the right to establish and join labour organizations of their own choosing and elect their representatives, for the purpose of furthering and defending the interests of workers or of employers.

Wages and Benefits

Suppliers shall pay all employees at least the minimum wage or the appropriate prevailing wage in its country of origin, whichever is higher, comply with all legal requirements on wages, and provide any benefits required by law or contract. Deductions from wages as a disciplinary manner shall not be permitted and payment shall occur in a timely manner with pay stub or similar documentation.

Hours of Work

Suppliers must establish work schedules and overtime policies, abiding by maximum hour and work week laws, rest period requirements, overtime, vacation and holiday time requirements and any other local law requirements.

Overtime Compensation

Suppliers shall be compensated for overtime hours at such premium rate as is legally required in the country of manufacture or, in those countries where such laws do not exist, at a rate at least equal to their regular hourly compensation rate.

Anti-Corruption Business Practices and Bribery

Suppliers must never offer, ask for, give or receive any form of bribe, kickback, any other type of improper payment, or attempt to gain influence or competitive advantage through improper means. Suppliers must also never offer to give facilitation payments (i.e., payments to foreign public officials to expedite or secure the performance of any act of a routine nature that is part of that official’s duties or functions). Suppliers must ensure that the requirements of all anti-corruption laws are met, including, but not limited to, Canada’s Corruption of Foreign Public Officials Act. No payments, gifts or other benefits may be given, directly or indirectly, to public officials, political parties or political candidates for the purpose of influencing government decisions in RRC Polytech’s or a Supplier’s favour or securing any other improper advantage. Suppliers are expected to ensure that payments made to agents or other third parties are not used, in whole or in part, to influence government decisions or secure any other improper advantage. Suppliers must not engage in any form of corruption, extortion, embezzlement and/or money laundering.

Environmental Responsibility

Suppliers will conduct their operations with minimal environmental impact, respect applicable laws and regulations concerning the environment and adopt required rules, procedures, contingency measures and management systems in order to ensure their operations are managed safely, ecologically and sustainably. Suppliers should take necessary measures in order to prevent pollution, and conserve, recycle and rationally use the natural resources required for their operations.

Subcontractors and Sources

Where Suppliers are outsourcing any activities in connection with RRC Polytech, Suppliers must monitor the outsourcing or subcontracting engagement to ensure compliance with the Suppliers’ contractual obligations and with this Code of Conduct, and must provide evidence of such monitoring to the Company upon request.

Acknowledgement

RRC Polytech requires all Suppliers to confirm that:

The Supplier has received a copy of and read RRC Polytech’s Supplier Code of Conduct.
To the best of its knowledge, it is in compliance with the Supplier Code of Conduct.
It shall comply with and agrees to be bound by the Supplier Code of Conduct and will not take any action or fail to take any action that violates the Supplier Code of Conduct.
The Supplier Code of Conduct shall form part of any agreement entered into between the Supplier and the Company whether or not expressly incorporated into such agreement.

Procurement and Logistics