NZTRADESOURCING LTD

Code of Conduct

NZ TRADE Sourcing Code of Conduct sets out the standards of behavior we expect of all suppliers doing business with NZ TRADE Sourcing LTD, wherever they are located in the world. We expect our suppliers to adhere to our business principles, as set out in this Code, and to share our commitment to sound and ethical business conduct.

Suppliers are requested to share the Code with their employees, partners, sub-contractors, and suppliers involved in the supply of goods or services to NZ TRADE Sourcing LTD and to require that their partners, sub-contractors, and suppliers comply with the Code as if they were the supplier itself.

1. Compliance with laws and regulations

All NZ TRADE Sourcing suppliers and their employees must, as a minimum standard, comply with all applicable laws and regulations of the countries in which they operate.

Suppliers must:

• Not engage in anti-competitive behavior, bribery, or corruption, nor must they permit anyone acting on their behalf to engage in such activities.

• Ensure that all products, services, and shipments for NZ TRADE Sourcing adhere to all applicable international trade compliance and export laws, rules and regulations.

2. Employees

NZ TRADE Sourcing suppliers are expected to provide an inclusive working environment in which their employees should feel respected and valued, and in which they are able to make the best use of their skills, free from discrimination and harassment.

Suppliers must:

• Employ only workers who meet the minimum applicable legal age requirement. Suppliers must comply with all applicable child labor laws and, irrespective of local practice, must not employ any person under the age of 16.

• Set employees’ working hours and pay in compliance with all applicable laws. Employees should be paid at least the minimum legal wage or a wage that reflects local industry standards, whichever is greater.

• Not engage in or support the use of forced or compulsory labor. Suppliers must not procure work or service from any person under the threat of any menace. Suppliers’ employees must be free to leave their employment with reasonable notice, and they must not be required to surrender any passports or work permits as a condition of employment.

• Not discriminate against employees on the grounds of race, nationality, gender, sexual orientation, marital status, religion, political belief, disability or age.

• Treat their employees with dignity and respect, and not display behavior which offends, humiliates or threatens others.

3. Health and safety

NZ TRADE Sourcing is committed to ensuring the safe and responsible operation of its business at all times. NZ TRADE Sourcing expects its suppliers to demonstrate a similar regard for the health and safety of its employees and to users of any materials supplied to Allied Metal Company.

Suppliers are expected to:

• As a minimum, comply with all applicable health and safety laws, regulations and standards, and any additional health and safety requirements stipulated by NZ TRADE Sourcing as a condition of supply.

• Ensure a safe work environment, and minimize physical and chemical hazards through proper design, engineering and process controls, preventative maintenance and safe work procedures.

• Provide employees with appropriate personal protective equipment, and adequate training.

4. Environment

NZ TRADE Sourcing believes that protecting the environment by minimizing its environmental impact will help to secure the long term future of its business. NZ TRADE Sourcing expects environmental protection to be a similar priority for its suppliers in all significant aspects of their activities.

Suppliers are expected to:

• As a minimum, comply with all applicable environmental laws, regulations and standards, and maintain all required environmental permits and licenses.

• Control pollution, consume resources effectively and use materials that minimize the environmental impact of operations.

• Endeavour to reduce or eliminate solid waste, wastewater and air emissions by implementing appropriate conservation measures in their production and facility processes.

5. Ethics

NZ TRADE Sourcing expects its suppliers to commit to the highest standards of ethical behavior when dealing with their employees, their own suppliers and their customers.

Suppliers are expected to:

• Prohibit all forms of fraud, deception, corruption and extortion by their employees, officers, directors or agents.

• Adhere to standards of fair business and competition.

• Accurately report information regarding their business activities and performance in accordance with all applicable laws and regulations.

• Respect intellectual property rights and safeguard third parties’ confidential information.

• Uphold all internationally recognized human rights wherever their operations are based.

• Ensure their products do not incorporate “conflict minerals” (minerals mined in conditions of armed conflict and human rights abuses, and which are sold or traded by armed groups, most predominantly in the Democratic Republic of Congo and adjoining countries), and perform sufficient due diligence on their own supply chains to ensure that any materials sold to NZ TRADE Sourcing containing tin, tantalum, tungsten or gold are sourced from conflict-free smelters.

6. Anti-corruption

Allied Metal Company is committed to complying with all anti-corruption laws that prohibit bribes, kickbacks and other corrupt actions to obtain or retain business, or obtain any improper advantage.

Suppliers must:

• As a minimum, comply with all applicable anti-corruption laws when conducting business with NZ TRADE Sourcing.

• Not, directly or indirectly, accept or offer any form of bribe, kickback or other corrupt payment from or to any person or organization, including government agencies, private companies and their respective employees.

• Ensure any gifts or hospitality offered to NZ TRADE Sourcing employees are customary and reasonable in terms of value and frequency, and not intended to improperly influence a business decision or impair independence or judgment.

• Ensure any third parties who provide goods or services on their behalf operate at all times in accordance with these standards.

Raising concerns

Suppliers who have a serious concern regarding any issue which may breach this Code should raise the matter with the appropriate NZ TRADE Sourcing senior management.

Confidential reports may also be submitted via e-mail to [email protected]