Supplier Code of Conduct

Overview

Corporate integrity, the safety and wellbeing of workers across the supply chain, and responsible product sourcing are of paramount importance to CraftMark Bakery. These principles are reflected in this Supplier Code of Conduct, which establishes the minimum standards that must be met by any Supplier that sells goods to or does business with CraftMark Bakery regarding: business integrity; workplace standards and practices; health and safety; and environmental practices.

All Suppliers must comply with the standards set out in this Supplier Code of Conduct as a condition of doing business with CraftMark Bakery. Suppliers refers to any third-party vendor that provides goods or services including, but not limited to raw materials, ingredients, and packaging component providers; maintenance, repair, and operations (MRO) providers; contract manufacturers; consultants, contractors, or other service providers; labor providers; logistics providers; and information systems providers. CraftMark Bakery expects that its Suppliers encourage and work with their own suppliers, vendors, agents, and subcontractors (“Partners”) to ensure that they also strive to meet the standards set forth in this Supplier Code of Conduct or any equivalent set of standards adopted by the Supplier.

BUSINESS INTEGRITY

1.1. Ethical Standards: Suppliers must maintain the highest ethical standards. Suppliers are expected to comply with all applicable laws and regulations. All forms of illegal or inappropriate activity, including, but not limited to, corruption, misrepresentation, extortion, embezzlement, bribery, acceptance of inappropriate gifts, or anticompetitive activities are strictly prohibited and may result in termination of any or all supply agreements with CraftMark Bakery and possible legal action.

1.2. Proper Use of Company Assets and Information: Suppliers shall respect and not infringe the intellectual property ownership rights of CraftMark Bakery, including, but not limited to, proprietary information, copyrights, patents, trademarks, and trade secrets. Suppliers shall protect CraftMark Bakery confidential information and shall not divulge any CraftMark Bakery information that a prudent business person would consider sensitive or which is designated by CraftMark Bakery as sensitive, proprietary, or confidential.

1.3. Accuracy of Business Records: Suppliers shall record and report facts accurately, honestly and objectively. Records must be accurate in all material respects. Do not hide, fail to record, or make false entries. All financial books and records must conform to generally accepted accounting principles or make appropriate disclosure of any variances from such principles. Suppliers should utilize appropriate audit and compliance processes for all aspects of their business.

2. WORKPLACE STANDARDS & PRACTICES

2.1. Authorization to Work and Documentation: Suppliers must only employ workers with the legal authorization to work. Authorization must be validated by the appropriate documentation.

2.2. Forced Labor and Human Trafficking: Suppliers may not use any form of forced, bonded, indentured, or prison labor. All work must be voluntary and workers should be free to leave work or terminate their employment with reasonable notice. Workers must not be required to surrender any government-issued identification, passports, or work permits as a condition of employment.

2.3. Child Labor: At a minimum, suppliers must adhere to child labor guidelines as defined by the International Labor Organization (ILO). Hazardous work may not be done by anyone below the age of 18, and such individuals must provide documented and informed consent.

2.4. Non-Discrimination: Suppliers may not discriminate against any worker based on race, color, age, gender, sexual orientation, ethnicity, disability, religion, political affiliation, union membership, national origin, or marital status in hiring and employment practices such as applications for employment, promotions, rewards, training, job assignments, wages, benefits, discipline, termination, and retirement.

2.5. Harassment: Suppliers must be committed to a workplace free of harassment. Suppliers may not threaten workers with or subject them to harsh or inhumane treatment, including sexual harassment, sexual abuse, corporal punishment, mental coercion, physical coercion, or verbal abuse.

2.6. Freedom of Association: In the event their workers have lawfully chosen to be represented by third parties, CraftMark Bakery expects suppliers to bargain in good faith and not to retaliate against workers for their lawful participation in labor organization activities.

2.7. Working Hours: Suppliers must provide for reasonable working hours, including maximum work hours, overtime, vacation time, leave periods, and public holidays. Work schedules must comply with all applicable laws, collective agreements, and contracts negotiated with CraftMark Bakery.

2.8. Rules Regarding Physically Demanding Work: Suppliers must identify, evaluate, and control worker exposure to physically demanding tasks, including manual material handling, heavy lifting, prolonged standing, and highly repetitive or forceful assembly tasks.

2.9. Wages and Benefits: CraftMark Bakery expects suppliers to compensate their workers fairly and competitively relative to their industry in full compliance with applicable local and national wage and hour laws, and to offer opportunities for workers to develop their skills and capabilities. All workers shall be provided with written and understandable information about their employment conditions with respect to wages before they enter employment and about the specifics of their wages for the pay period concerned each time that they are paid. Deductions from wages as a disciplinary measure shall not be permitted nor shall any deductions from wages not provided for by national law be permitted without the expressed permission of the worker concerned. All disciplinary measures should be recorded.

3. QUALITY, HEALTH & SAFETY

3.1. Work Environment: Workers shall be provided access to clean toilet facilities and to potable water and, if appropriate, sanitary facilities for food storage. Accommodations, if provided, shall be clean, safe, and meet the basic needs of the Workers. Work conditions shall include proper ventilation, light, temperature, and noise levels, aligned with type of industry and all applicable laws.

3.2. Health and Safety Practices: Suppliers must apply safe work practices, including regulatory and contract specific requirements, to all activities. Suppliers must conduct health and safety risk assessments to identify and evaluate potential risks in order to prevent and mitigate employee exposure to hazards. Workers should be trained on all appropriate health and safety procedures, with training in the appropriate language. Workers must always be provided appropriate personal protective equipment and instructed on its appropriate use. When working or performing services on CraftMark Bakery property, Suppliers must adhere to the safe work practices and policies of CraftMark Bakery with respect to those locations.

3.3. Occupational Safety: Suppliers must establish procedures and systems to manage, track, and report occupational injury and illness. Such procedures and systems should clearly identify the process for reporting and should provide steps to classify and record injury or illness cases, investigate cases, implement corrective actions to eliminate their causes, provide necessary medical treatment, and facilitate the workers' return to work.

3.4. Emergency Prevention, Preparedness, and Response: Suppliers must anticipate, identify, and assess emergency situations and events and minimize their impact by implementing emergency plans and response procedures, including emergency reporting, worker notification and evacuation procedures, worker training and drills, appropriate first-aid supplies, appropriate fire detection and suppression equipment, adequate exit facilities, and recovery plans.

3.5. Product Quality & Safety: Suppliers must provide CraftMark Bakery with high-quality products, ingredients, and services that meet all applicable quality and food-safety standards. Suppliers must demonstrate that they have robust food safety and quality management systems, following Hazard Assessment and Critical Control Points (HACCP) principles. Suppliers must immediately report to CraftMark Bakery any concerns about product safety.

3.6. No Alcohol or Drug Use: Suppliers must not report to work or engage in any work for or on behalf of CraftMark Bakery, or in any fashion represent, or make any representations on behalf of CraftMark Bakery, while under the influence of illegal drugs or alcohol. In addition, suppliers may not possess illegal drugs or controlled substances while on CraftMark Bakery premises or while conducting business with or for CraftMark Bakery. This prohibition does not include legally obtained medications used as directed by a licensed medical practitioner that do not create a safety risk.

4. ENVIRONMENTAL PRACTICES

4.1. Compliance: Suppliers shall conduct their operations in compliance with all local laws and regulations relating to the environment, including those relating to waste disposal, emissions, and hazardous material handling. Suppliers must obtain, maintain, and keep current all required environmental permits and registrations and follow the operational and reporting requirements of such permits.

4.2. Wastewater and Solid Waste Emissions: Wastewater and solid waste generated from operations, industrial processes, and sanitation facilities must be monitored, controlled, and treated as required by applicable laws and regulations before discharge or disposal.

4.3. Air Emissions: Air emissions of volatile organic chemicals, aerosols, corrosives, particulates, ozone depleting chemicals, and combustion by-products generated from operations must be characterized, monitored, controlled, and treated as required by applicable laws and regulations before discharge.

4.4. Hazardous Materials: Suppliers must identify and manage substances that pose a hazard if released to the environment and comply with applicable labeling laws and regulations for recycling and disposal. Suppliers must ensure safe handling, movement, storage, recycling, reuse, and disposal of all hazardous substances. Suppliers must post Material Safety Data Sheets in the primary language of its workers for any hazardous or toxic substances used in the workplace and train workers who may encounter such substances in the workplace.

4.5. Environmental Practices and Responsibilities: Suppliers shall strive to minimize its negative impact on the environmental by ensuring that its operations do not directly contribute to issues including, but not limited to deforestation and loss of biodiversity. As applicable for suppliers producing or sourcing agricultural commodities, suppliers shall implement measures to protect both soil and water resources. Suppliers of any products of animal-derived materials shall comply with local and international regulations and standards on the ethical, humane and legal treatment of animals, including the “Five Freedoms of Care” as endorsed by the World Organization for Animal Health.

4.6. Pollution Prevention and Resource Reduction: Suppliers must endeavor to reduce or eliminate waste of all types, including water and energy, by implementing appropriate conservation measures in its facilities, in its maintenance, and production processes.

5. ENFORCEMENT & COMPLIANCE

5.1. Management Accountability: Suppliers must manifest their commitment to implementation of the principles of this Supplier Code of Conduct by having or establishing an appropriate management system to address compliance with these principles and detection and correction of any non-compliance. An appropriate management system should include management accountability, adherence to all legal and customer requirements, and clear communication throughout the supply chain.

5.2. Transparency: Suppliers should adopt a transparent approach to working with CraftMark Bakery, including the disclosure of relevant policies and procedures. If requested, supplier will disclose the geographical location of facilities producing raw materials for CraftMark Bakery, as well as the origin of raw materials within the supplier’s own direct supply chain. Supplier will take responsibility to implement the requirements of this Code of Conduct and associated due diligence processes with those in its own direct supply chain.

5.3. Audits and Inspections: Each supplier should conduct audits and inspections to ensure their compliance with this Supplier Code of Conduct and applicable legal and contractual standards. CraftMark Bakery reserves the right to conduct periodic, announced inspections of supplier’s facilities and records to verify compliance with these standards.

5.4. Enforcement: CraftMark Bakery reserves the right to terminate its business relationship with any supplier who violates this Supplier Code of Conduct or whose suppliers or subcontractors violate this Supplier Code of Conduct. CraftMark Bakery reserves the right to terminate its business relationship with suppliers who fail to provide written confirmation to CraftMark Bakery that they have a program in place to monitor their suppliers and subcontractors for compliance with this Supplier Code of Conduct.