Vendor Conduct Policy

Laws, regulations and contracts
Our suppliers must act with honesty and integrity and in compliance with all applicable laws and regulations in doing business with government officials in any country, including personnel employed by government-controlled or stateowned enterprises. Suppliers must comply with all conditions, and other provisions specified in the Arbitech purchase order. When performing international business, or if the primary place of business is outside of the United States, suppliers must comply with local laws and regulations.

Anti-corruption
We have a zero-tolerance policy for corruption, and prohibit anyone conducting business on our behalf to engage in activities not in concurrence to our policy. Suppliers must use reasonable efforts to promote among their business partners adherence to this Code of Conduct, and exercise due diligence to prevent and detect corruption in all business arrangements. Our suppliers must comply with the anti-corruption laws that govern operations in the countries in which they do business, such as the U.S. Foreign Corrupt Practices Act and the U.K. Bribery Act.

Gifts/Business courtesies
We expect our suppliers in the offering or receipt of any gift or business courtesy not give or receive business gifts unless of nominal value and permitted by law, and regulation.

Financial responsibility/Accurate records
We expect our suppliers to accurately record, maintain, and report business documentation, including but not limited to, financial accounts, sales & purchasing orders, all written communications for a reasonable time period, and all pertinent business regulatory and administrative records.

Confidential/Proprietary information
Our suppliers should safeguard all sensitive information, including safeguarding proprietary and confidential information disclosed by Arbitech, physical property or personal data of Arbitech and its employees and customers, which is in their care or possession, and use any such information only for the business purpose for which it was provided.

Employee, health & product safety
Suppliers must protect the health, safety and welfare of those who may be affected by their activities by complying with all applicable environmental health and safety laws, regulations and directives. Supplier must ensure that their personnel are aware of their contribution to product safety as well as their contribution to product or service conformity.

Equal opportunity
We expect our suppliers to provide equal employment opportunity to employees and applicants for employment without regard to race, ethnicity, religion, color, sex, national origin, age, military veteran status, ancestry, sexual orientation, gender identity or expression, marital status, family structure, genetic information, or mental or physical disability.

Harassment
We expect our suppliers to promote a safe, respectful and productive workplace by establishing and maintaining fair employment practices, including complying with laws that prohibit harassment. For a copy of the Arbitech antiharassment policy, for which vendors are subject to, please contact the compliance department.

Drug-free workplace
Our suppliers must maintain a safe and healthful workplace for their employees free of illegal drugs or controlled substances.

Human rights
We expect our suppliers to treat people with respect and dignity, encourage diversity and diverse opinions, promote equal opportunity for all, and help create an inclusive and ethical culture. Supplier must ensure that their personnel are aware of the importance in ethical behavior.

Human trafficking
We expect our suppliers to not engage in the use of forced labor, indentured labor, involuntary prison labor, or trafficking of persons. This includes transporting, harboring, recruiting, transferring, or receiving vulnerable persons by means of threat, force, coercion, abduction, or fraud for the purpose of exploitation.

Child labor
We expect our suppliers to ensure that child labor is not used in the performance of work. The term "child" refers to any person under the minimum legal age for employment where the work is performed.

Arbitech maintains a robust compliance regime and its policies are updated from time to time. Any questions should be referred to the compliance department at compliance@arbitech.com.