Supplier code of conduct

Introduction

At Juniper Square, corporate integrity, responsible product sourcing, and the safety and well-being of workers across our global supply chain are of the utmost importance. We expect all of our vendors, partners, agents, consultants, and providers of goods and services, or anyone working on behalf of Juniper Square (each a “Supplier” and collectively “Suppliers”) to uphold similar values.

This Supplier Code of Conduct (“Supplier Code”) sets out Juniper Square’s expectations for our Suppliers in the areas of business integrity, labor practices and human rights, health and safety, and environmental impact. It establishes the minimum standards that any Supplier doing business with Juniper Square, Inc. or its affiliates and subsidiaries (collectively “Juniper Square”) must meet.

Compliance with Laws

To ensure consistency and mutual commitment, Juniper Square requires that all Suppliers, including their employees, representatives, subcontractors, agents, and suppliers, (“Partners”), comply with all applicable laws and regulations in the jurisdictions in which they operate. Suppliers are also expected to comply with this Supplier Code.

Anti-Bribery and Corruption

When evaluating business partners or engaging with Suppliers, Juniper Square does not offer or take bribes and we do not permit others to exert undue pressure or influence on us. We expect our Suppliers to do the same. As such, Suppliers must comply with all applicable anti-bribery and anti-money laundering laws and will strictly prohibit all forms of bribery, kickbacks, and other corruption.

Business Records and Accounting

Suppliers will accurately reflect their business dealings in their books and records regarding sales of products, services, or other expenditures with respect to Juniper Square. Suppliers will not engage in false or misleading accounting practices.

Conflicts of Interest

A conflict of interest exists when a Supplier’s business or personal interests interfere with, or has the appearance of interfering with, the best interests of Juniper Square. We expect our Suppliers to be transparent about any actual, potential, or perceived conflicts of interest with Juniper Square and avoid activities that could interfere with their contractual responsibilities to Juniper Square unless they have provided notice to Juniper Square of the conflict of interest and received Juniper Square’s consent to proceed.

Suppliers will avoid conflicts of interest with Juniper Square and will disclose to Juniper Square any situation that reasonably could be expected to give rise to an apparent or actual conflict of interest regarding its relationship with Juniper Square.

Examples of a conflict of interest that must be disclosed to Juniper Square include (but are not limited to) close personal relationships between the Supplier and Juniper Square personnel, payment of incentives to Juniper Square personnel, and Juniper Square personnel also acting as the Supplier’s director, officer, or shareholder.

Ethical Conduct

Suppliers will adhere to the highest standard of ethical conduct in their business practices and will engage in honest and fair dealings with their current and potential customers. Suppliers will not engage in any misleading or deceptive practices, misrepresent their products, services, and processes, or make unfair, misleading, inaccurate or false claims about, or comparisons with, competitor offerings.

Fair Competition and Antitrust

Suppliers will comply with all applicable competition and antitrust laws and regulations.

Additionally, Suppliers will not discuss or agree with any competitors to illegally fix or control prices, coordinate during a bidding process, limit the production or sale of products or product lines, or divide or allocate markets, territories, products, customers, or suppliers. Suppliers will only use legal means to gather information about sellers of products that compete with Juniper Square products.

Protection of Information

Suppliers will comply with all applicable data privacy laws and regulations when processing the personal or identifying information of Juniper Square and Juniper Square’s employees, workers, customers and end users, and suppliers. Suppliers will use reasonable measures to protect the confidentiality of information they receive and comply with all confidentiality and data security obligations in their contracts with Juniper Square and their other business partners.

Trade and Export Controls

Suppliers will strictly comply with all applicable trade laws, including export, import, customs, sanctions, embargoes, boycott, and other trade compliance laws and regulations.

Slavery and Human Trafficking

Suppliers must ensure that all labor is voluntary and all workers are free to terminate their employment at any time in accordance with applicable law. Suppliers will not support or engage in slavery or human trafficking in any part of its supply chain. Suppliers will not, and will ensure that their Partners do not, support, engage in, or require any compelled, involuntary, or forced labor, bonded labor, prison labor, indentured labor, or child labor.

Fair Compensation, Working Hours, and Lawful Employment

Suppliers must comply with all local wage laws, including those relating to minimum wages, overtime hours, and legally mandated benefits, and will ensure that wages and benefits are paid on time. Overtime must be voluntary and wage deductions shall not be used as disciplinary measure. Suppliers must also ensure that their workers have reasonable work schedules that comply with local laws – workweeks are not to exceed the maximum set by local law and Suppliers must provide rest days and public holidays.

Prior to employing any worker, Suppliers will review and validate all relevant documentation to ensure that such worker has the legal right to work in that jurisdiction.

Freedom of Association

Suppliers will respect employees’ lawful right of free association, as well as their right to join, form, or not join a labor union or otherwise engage in collective bargaining in accordance with local laws. Suppliers will permit workers to openly communicate and share grievances with management about working conditions without fear of retaliation, punishment, threats, or harassment.

Health and Safety

We expect our Suppliers to provide a safe and healthy place for their Partners and communities. Suppliers will promote safe and secure workplaces and will have policies and practices in place to ensure the health and safety of their employees. Suppliers will take all necessary steps to provide a safe working environment.

Fair Treatment, Non-Discrimination, and Diversity and Inclusion

Suppliers will maintain a workplace where business activities are conducted with respect and where treatment is fair and without abuse. Suppliers will comply with all applicable laws on non-discrimination and anti-harassment in hiring and employment.

Provide Grievance Procedures

Suppliers will provide employees with reasonable, effective, accessible, and culturally appropriate procedures so that workplace concerns can be brought to management for appropriate resolution. Suppliers will strictly prohibit all forms of retaliation against workers for raising workplace concern.

Environmental Protection

We strongly encourage our Suppliers to engage in environmentally conscious activities and to demonstrate social responsibility in their business practices and policies.

Suppliers will conduct their operations in ways that comply with all applicable environmental laws, regulations, and standards. Suppliers should consider their environmental impact when making business decisions and are encouraged to develop and maintain practices to reduce pollution, conserve resources, and promote energy efficiency.

Compliance Monitoring

Suppliers will monitor their operations and their compliance with applicable laws and regulations and this Supplier Code through appropriate due diligence, audits, and other relevant activities.

Reporting Misconduct

In order to promote a high standard of ethical and professional conduct, we have established an ethics reporting hotline, where, as permitted by law, employees, customers, and Suppliers can address any issues on a confidential and anonymous basis. We expect our Suppliers to report any known or suspected violations of this Supplier Code, laws, or regulations to Juniper Square by emailing procurement@junipersquare.com.

Updates to this Supplier Code

Juniper Square reserves the right to make updates to this Supplier Code of conduct at any time. Suppliers must comply with the then-current version of the Supplier Code as posted at INSERT URL ONCE FINAL.