This Code sets forth minimum requirements of any entity providing goods or services to Applegate EDM (hereinafter a “Supplier”). These requirements are consistent with Applegate’s values and are applicable to all Suppliers and their respective affiliates and subsidiaries globally.

1. Compliance with Laws

Supplier shall at all times operate in full compliance with all applicable laws, rules and regulations (collectively “Laws”).

2. Labor

Supplier shall uphold the human rights of workers and treat them with dignity and respect.

a. Supplier shall only employ or engage workers who meet the applicable minimum legal age requirement, except that in no event shall Supplier employ any person under the age of 16, even if local Laws permit otherwise. Notwithstanding the foregoing, Supplier may allow individuals age 15 or older to work as part of a bona fide apprentice program. Such apprentice program must be approved under local Laws and be intended to provide instruction in one or more particular industrial disciplines as part of enrollment in an educational institution.

b. Supplier shall not use or engage in any indentured or forced labor, slavery, servitude, or human trafficking.

c. Supplier shall set working hours, wages and over-time pay in compliance with all applicable Laws. Workers shall be paid at least the minimum legal wage or a wage that meets local industry standards, whichever is greater.

d. Supplier shall employ workers on the basis of their ability to do the job and treat them with dignity and respect. Supplier shall not engage in any discrimination or harassment, whether based on gender, race, color, religion, ethnicity, social background, age, sexual orientation, national origin, disability, political conviction or any additional legally protected characteristics.

3. Health & Safety

Applegate EDM is committed to being a leader in safeguarding the health and safety of employees, officers, directors, agents and contractors (“Personnel”).

a. Supplier shall comply with Applegate’s Safety Policy, Applegate’s EHS handbook and any site-specific safety requirement or protocol while on-site at Applegate’s location or at an Applegate customer location on behalf of Applegate.

b. Supplier shall:

i. Ensure a safe work environment and minimize physical and chemical hazards through preventative maintenance and safe work procedures as well as ongoing
safety training.

ii. Provide workers with appropriate personal protective equipment where hazards cannot be adequately controlled by other means.

iii. Provide and properly maintain physical guards, interlocks and barriers where machinery presents a potential injury hazard to workers.

iv. Provide training and ensure that its Personnel are appropriately trained and educated in respect of health and safety matters.

4. Environment

At Applegate EDM, environmental considerations are an integral part of our business practices.

a. Supplier shall maintain all required environmental permits and registrations and follow the operational and reporting requirements of such permits.

b. Supplier shall comply with regulated substance and product content specifications and with any applicable Laws prohibiting or restricting the use, content or handling of specific substances. Supplier shall provide Applegate any information relative to the foregoing, including, but not limited to, Material Declarations, as applicable.

c. Supplier shall minimize environmental pollution and make continuous improvements to reduce or eliminate solid waste, wastewater and air emissions by implementing appropriate conservation measures in their production, maintenance, and facility processes.

d. Supplier shall manage, control, treat and/or dispose of non-hazardous solid waste, wastewater, and/or air emissions generated from operations as required by applicable Laws, before discharge.

5. Ethics and Compliance

Supplier shall commit to the highest standards of ethical conduct when dealing with its personnel, suppliers, customers and other relevant stakeholders.

a. Supplier shall accurately record and disclose information regarding its business activities, structure, financial situation, and performance in accordance with applicable Laws as well as prevailing industry business practices.

b. Supplier shall prohibit any and all forms of fraud, extortion, theft or embezzlement by its personnel.

c. Supplier shall respect intellectual property rights and safeguard Applegate information. Transfer of technology and know-how shall be done in a manner that protects intellectual property rights.

d. Supplier shall implement processes and procedures and exercise due diligence to detect and avoid counterfeit parts.

e. Applegate is committed to ensuring that the products it sells do not incorporate “conflict minerals” (minerals which are smelted into tin, tantalum, tungsten and gold). Supplier shall:

(i) Perform sufficient due diligence into Supplier’s supply chains to determine whether products sold or provided to Applegate contain tin, tantalum, tungsten or gold, and, if so, whether and to what extent those metals are sourced from conflict-free smelters;

(ii) Report to Applegate the results of such due diligence to enable Applegate to comply with its legal obligations and policy goals; and (iii) Commit that any such metals are sourced only from conflict-free smelters.

f. Supplier shall implement processes to address the confidentiality and protection of an employee who in good faith raises a concern, makes a report, or assists with an investigation related to potential ethical or criminal violations.

6. Anti-Corruption

Applegate is committed to complying with all anti-corruption Laws that prohibit bribes, kickbacks, or other corrupt actions to obtain or retain business or obtain any improper advantage.

a. No Bribes or Kickbacks. Supplier shall not directly or indirectly solicit, receive or offer any form of bribe, kickback, or other corrupt payment, to or from any person or organization, including but not limited to government agencies or officials, companies or personnel of those companies.

b. Gifts and Entertainment. When doing business with or conducting business on behalf of Applegate, Supplier may, for legitimate business purposes:

(i) offer gifts or entertainment to suppliers, customers or other business associates; or

(ii) accept gifts or entertainment offered by suppliers, customers or other business associates; provided, however, that in each instance the gift or entertainment:

• Is unsolicited;
• Is not illegal or in violation of this Code;
• Is not a bribe, kickback or other illicit payment;
• Is not given in exchange for any consideration;
• Would not embarrass Applegate if disclosed publicly; and
• Does not create the appearance (or an actual or implied obligation) that the gift giver is entitled to preferential treatment, an award of business, better prices or improved terms of sale.

7. Compliance Monitoring

Supplier shall allow Applegate and/or any of its representatives or agents access to Supplier’s facilities and all relevant records associated with the products and services provided to Applegate.

Supplier and Applegate shall establish a mutually agreeable date and time for access. However, risks to Applegate’s business may require immediate access to the products, services and associated records and Supplier shall accommodate Applegate’s reasonable access as required. Supplier also agrees to cooperate with Applegate to investigate any allegations of wrongdoing, misconduct or corruption.

8. Application

Supplier shall contractually require its suppliers and/or subcontractors to conform to standards of conduct equivalent to the provisions of this Code. Applegate reserves the right to audit Supplier’s suppliers and/or subcontractors for compliance to this Code and Supplier shall accommodate Applegate’s request. Supplier shall also ensure that its personnel shall comply with this Code when providing goods or services to Applegate.

9. Breach

Supplier shall promptly report to Applegate any known breach of this Code and implement a corrective action plan to cure all non-compliance within a specified time period (furnished to Applegate in writing). Applegate reserves the right to terminate the business relationship, including but not limited to suspending placement of future orders and potentially current production. Applegate reserves the right to hold Supplier responsible for reasonable costs of investigating noncompliance.