Supplier Code of Conduct

SWM's Supplier Code of Conduct

Introduction

This Supplier Code of Conduct outlines the minimum standards SWM International and its affiliated companies (SWM) require their Suppliers (as defined below) to comply with when doing business with SWM, in addition to complying with all laws and regulations that are applicable to the Supplier. The Supplier will respond without delay to any request from SWM aiming at the implementation of existing or new laws or regulations on SWM premises. Should a conflict arise between the standards listed below and local laws or regulations, Suppliers will be expected to comply with the laws and regulations of the jurisdictions in which they operate.

A “Supplier” is any person or legal entity which provides SWM with products or services. In addition to Suppliers who have a direct contractual relationship with SWM, this definition also includes the Suppliers’ sub-suppliers. “SWM Representatives” include the company’s employees and legal representatives. We expect Suppliers to produce, preserve, and deliver the product and/or service in conformity with agreed upon specifications and to provide any relevant information, results, or performance ratings related to the product and/or service.

The Supplier shall have appropriate management systems in place to enable adherence to this Code of Conduct or its own equivalent code of conduct as well as all other relevant and applicable laws and regulations. The functioning and quality of the management system shall be in proportion to the size, complexity, and risk environment of the Supplier’s business. The Supplier shall adopt a systematic approach to the assessment, mitigation, and management of risks related to human and labor rights, occupational health and safety, responsible business practices, and environmental impact. All applicable laws, regulations, and contractual terms governing the Supplier’s assignments shall be duly applied and communicated, with sufficient training provided to relevant employees and business partners. The Supplier shall have systems in place to enable the reporting of Code of Conduct-related grievances (e.g., a whistle-blowing system) to the Supplier’s management team. The Supplier shall communicate this Code of Conduct or its own equivalent Code of Conduct to its own suppliers and sub-suppliers.

Human Rights and Labor Standards

The use of slavery, forced or compulsory labor (including prison labor), and human trafficking and exploitation are prohibited. Suppliers are expected to comply with the requirements of ILO Convention No. 138 on the minimum age for admission to employment and work and to not employ any workers below 15 years (14 years in certain developing countries) or the minimum age according to national legislation, whichever is higher. Suppliers shall provide a harassment-free work environment and shall ensure that their employees and contractors do not suffer harassment, physical or mental punishment, or other forms of abuse.

SWM values diversity and inclusion. Discrimination in any form will not be practiced, including discrimination based on distinction, exclusion, or preference based on race, color, sex, sexual orientation, age, ethnic or national origin, religion or personal beliefs, disability, or any other status protected by law.

Environmental Health and Safety (EHS)

The Supplier is required:

• to fulfill all applicable legal EHS requirements, including the EU Registration, Evaluation, Authorisation, and Restriction of Chemicals (REACH) directive, where applicable,
• to have a written EHS policy of its own, to demonstrate management’s commitment to EHS, and to assign responsibility for EHS within its organization,
• to ensure that operational controls such as rules and procedures are in place and communicated to all relevant employees,
• to increase its employees’ awareness of health and safety issues, to enhance safety culture through open
• communication, and to ensure that its staff have received appropriate EHS training,
• to measure and monitor its EHS performance and hazards with the help of properly conducted workplace inspections and audits,
• to assign responsibility for environmental and safety issues within its organization,
• to report and investigate all health and safety incidents,
• to have emergency preparedness and response procedures in place,
• to ensure that relevant employees have appropriate know-how and experience in relation to environmental and safety issues, as well as resources to enable them effectively to meet their responsibilities,
• to ensure that written instructions covering all processes with potential environmental impacts, such as the storage and handling of hazardous materials, are available and that the relevant information is communicated to all employees involved,
• to proactively work to prevent emergencies and ensure the capacity to react appropriately to such events by analyzing, identifying, and adopting suitable preventive and corrective measures,
• to handle environmental and safety violations and complaints systematically and communicate them to employees and external stakeholders, including SWM if affected,
• to provide SWM with up-to-date material safety data sheets (MSDS or SDS), as applicable, and any other relevant documents and information requested by SWM,
• to optimize the use of resources and minimize the generation of emissions and waste.

Wages and Working Hours

At a minimum, wages and working hours will comply with all applicable wage and hour laws rules, and regulations, including minimum wage, overtime, and maximum hours in the country concerned.

The Supplier is required:

• to pay employees at least the minimum wage and applicable overtime wages defined by national laws or any applicable collective agreements,
• to apply normal working hours that comply with applicable laws and collective agreements,
• to provide all employees with at least one rest day in seven consecutive working days.

Compliance with the EU Timber Regulation

SWM expects all applicable Suppliers to fully comply with the EU Timber Regulation. Suppliers should not engage in practices that contribute to deforestation and should seek third party certification (FSC, PEFC, or an alternative credible standard) for supplied timber and timber-derived materials. SWM supports practices that end deforestation and the illegal harvest of timber.

Responsible Business

The Supplier is required to conduct its business in full compliance with SWM’s Supplier Code of Conduct or the Supplier’s own equivalent ethical rules. This means, among other things, that the Supplier is required:

• to conduct business in full compliance with all applicable antitrust and fair competition laws,
• to prevent situations where there is a conflict of interest between the Supplier and SWM,
• to act in compliance with all applicable anti-corruption laws, including the Foreign Corrupt Practices Act and the UK Modern Bribery Act, by, among other things, refusing to receive or offer bribes, facilitation payments, or anything of value for the purpose of obtaining or retaining business or any improper benefit or advantage,
• to act in compliance with all rules and regulations related to the safety and quality requirements of products and services, including rules defined by SWM for work conducted at SWM locations,
• to transparently and accurately record and disclose details of its business activities, corporate structure,
• financial situation, and performance in accordance with applicable laws and regulations,
• to maintain the integrity of confidential data.

SWM Representatives shall always pay for their own travel and accommodation costs when visiting the Supplier, attending conferences, or conducting other business. The Supplier shall not offer any SWM Representatives any gifts, hospitality, or expenses that could be considered unreasonable or inappropriate with regard to possible business transactions, although reasonable meals incidental to business discussions are permitted. Suppliers shall promptly disclose to SWM at compliance@swmintl.com or to SWM’s third party hotline at 1-866-614-4821 any situation that is or may be perceived to be a conflict of interest which involves SWM employees or any suspected violation of this Supplier Code.

Enforcement

If SWM finds that the Supplier is not meeting the requirements and expectations set out in this Supplier Code, SWM will offer guidance specifying which issues need to be corrected or improved. The Supplier must then take corrective actions promptly as advised by SWM. SWM nevertheless reserves the right to cancel outstanding orders, suspend future orders, or terminate the contract with the Supplier in case of a material breach of this Supplier Code. When a conflict exists between this Supplier Code and an executed supply agreement, the conditions and terms of the supply agreement will supersede this Supplier Code.