Supplier Code of Conduct and Ethics Policy

Sycomp has adopted the Responsible Business Alliance (RBA), formerly the Electronic Industry Citizenship Coalition’s (EICC) Code of Conduct as our supplier code of conduct.

The RBA Code of Conduct (“Code”) establishes standards to ensure that working conditions in the electronics industry or industries in which electronics is a key component and its supply chains are safe, that workers are treated with respect and dignity, and that business operations are environmentally responsible and conducted ethically. The Code encourages Participants to go beyond legal compliance, drawing upon internationally recognized standards, to advance social and environmental responsibility and business ethics. In alignment with the UN Guiding Principles on Business and Human Rights, the provisions in this Code are derived from key international human rights standards including the ILO Declaration on Fundamental Principles and Rights at Work and the UN Universal Declaration of Human Rights.

Sycomp expects its suppliers to acknowledge and adopt the principals of this code. Supplier compliance and performance associated with the requirements of this code will be measured by Sycomp as applicable based on the nature of the business transacted. If supplier performance does not meet Sycomp’s expectations, suppliers may be placed on performance improvement plans and/or potentially disengaged as a Sycomp supplier.

Suppliers must be committed to upholding the human rights of workers, and to treat them with dignity and respect as understood by the international community. This applies to all workers including temporary, migrant, student, contract, direct employees, and any other type of worker.

1. Forced Labor and Anti-Human Trafficking
   Forced, bonded (including debt bondage) or indentured labor or involuntary prison labor, slavery or trafficking of persons are prohibited to be used by suppliers. This includes transporting, harboring, recruiting, transferring, or receiving vulnerable persons by means of threat, force, coercion, abduction, or fraud for the purposes of exploitation. All work must be voluntary, and workers shall be free to leave work at any time or terminate their employment. Workers must not be required to surrender any government issued identification, passports or work permits as a condition of employment. Excessive fees relating to employers’ or agents’ recruitment, or other related fees are unacceptable. Any other fees charged to workers must be disclosed.
2. Child Labor Prohibition
   Child labor is prohibited to be used in any stage under any circumstances. The terms “child” refers to any person employed under the age of 15, or under the age for completing compulsory education, or under the minimum age for employment in the country, whichever is greatest. The use of legitimate workplace apprenticeship programs, which comply with all US laws and regulations, is acceptable. Workers under the age of 18 shall not perform work that is likely to jeopardize the physical or mental health or safety of young workers.
3. Working Hours
   Regular workweeks are not to exceed the maximum set by local law. Further, workers shall be allowed at least one day off per seven-day week. Finally, a workweek should not be more than 60 hours per week, including overtime, except in emergencies or unusual situations, or as mandated by local laws.
4. Wages and Benefits
   Compensation paid to workers shall comply with all applicable wage laws, including those relating to minimum wages, overtime hours and legally mandated benefits. In compliance with local laws, workers shall be compensated for overtime and shall be provided the basis on which they are being paid in a timely manner via appropriate documentation. Deduction from wages as a disciplinary measure shall not be permitted.
5. Humane Treatment
   Suppliers must commit to a workplace free of harassment and abuse. Workers shall not be subject to, or threatened with, harsh and inhumane treatment, including any race, gender, and religious discrimination, sexual harassment, psychological harassment, sexual abuse, corporal punishment, mental or physical coercion or verbal abuse of workers.
6. Anti-Discrimination
   Suppliers must be committed to a workforce free of harassment and unlawful discrimination. It may not engage in discrimination based on any basis prohibited by applicable/ local law. Sycomp embraces diversity and equal opportunity as fundamental principles and key components of its corporate strategy and strongly encourages all of its Suppliers to do the same.
7. Freedom of Association
   As legally permitted, Supplier shall freely allow workers to associate with others, form, and join (or refrain from joining) organizations of their choice, and bargain collectively, without interference, discrimination, retaliation, or harassment. In the absence of formal representation, supplier shall ensure that workers have a mechanism to report grievances and that it facilitates open communication between management and workers.

Workers physical and mental health, safety, and well-being are important to Sycomp. Supplier shall provide and maintain a safe work environment and integrate sound health and safety management practices into its business. Workers shall have the right to refuse unsafe work and to report unhealthy working conditions.

1. Occupational Health and Safety
   Supplier shall identify, evaluate, and manage occupational health and safety hazards through a prioritized process of hazard elimination, engineering controls, and/or administrative controls. Supplier shall provide workers with job-related, appropriately maintained personal protective equipment and instruction on its proper use. Workers are not to be disciplined for raising safety concerns. Suppliers shall comply with all applicable quality, health, safety, and environmental regulations. All required permits, licenses, and registrations will be obtained, maintained, and kept up-to date. As required by local regulations, Sycomp encourages our suppliers to apply sound practices to identify, measure, register and report on the level of hazardous substances, restricted materials, and “conflicted resources” used in their products to ensure a high level of protection of health/welfare, protection of the environment, and to promote alternative (non-animal) uses for testing.
2. Emergency Preparedness
   Supplier shall identify and assess potential emergency situations. For each situation, Supplier shall develop and implement emergency plans and response procedures that minimize harm to life, environment, and property.
3. Occupational Injury and Illness
   Procedures and systems are to be in place to prevent, manage, track and report occupational injury and illness, including provisions to: i.) encourage worker reporting; ii.) classify and record injury and illness cases; iii.) provide necessary medical treatment; iv.) investigate cases and implement corrective actions to eliminate their causes; and v.) facilitate return of workers to work.
4. Industrial Hygiene
   Worker exposure to chemical, biological, and physical agents to be identified, evaluated, and controlled. Engineering or administrative controls must be used to control overexposures. When hazards cannot be adequately controlled by such means, worker health is to be protected by appropriate personal protective equipment programs.
5. Sanitation, Food and Housing
   Suppliers shall provide workers with reasonably accessible and clean toilet facilities and potable water, and clean drinking water. Supplier-provided dining, food preparation, and storage facilities shall be sanitary.
6. Physically Demanding Work
   Suppliers should have in place procedures and systems to identify, evaluate, and control worker exposure to the hazards of physically demanding tasks.
7. Machine Safeguarding
   Production and other machinery shall be evaluated for safety hazards. Where machinery presents an injury hazard to workers, measures must be taken to install safety precautions on the equipment. This equipment must be properly monitored and maintained.

Sycomp believes that protecting the environment and environmental responsibility is a fundamental responsibility of all good corporate citizens with whom we do business. Suppliers shall develop, implement, and maintain environmentally responsible business practices and take measures to ensure in business operations, adverse effects on the community, environment and natural resources are to be minimized while safeguarding the health and safety to the public.

1. Carbon Neutrality
   Sycomp encourages our suppliers and partners to share our commitment to sound sustainability practices; using good faith efforts to obtain the products and/or services from their resale partners and delivering those products and/or services to Sycomp on a carbon neutral basis.
2. Environmental Permits and Reporting
   Suppliers shall obtain, keep current, and comply with all required environmental permits. Supplier shall comply with the reporting requirements of applicable permits, regulations, and fillings.
3. Pollution Prevention and Resourcing Reduction
   Suppliers shall reduce energy, water, and natural resource consumption by implementing conservation and substitution measures. Suppliers shall minimize hazardous substances consumption by implementing reduction and substitution measures.
4. Hazardous Substance Management
   Supplier shall implement a systematic approach to identify, manage, reduce, and responsibly dispose of or recycle hazardous substances. Chemicals and other materials posing a hazard if released to the environment, should be identified, and managed to ensure safe handling, movement, storage, recycling or reuse and disposal.
5. Wastewater and Solid Waste
   Suppliers shall characterize, monitor, control and treat wastewater and solid waste generated from operations, industrial processes, and sanitation facilities as required prior to discharge or disposal.
6. Air Emissions
   Supplier shall identify, manage, reduce, and responsibly control air emissions emanating from its operations that pose a hazard to the environment. Supplier shall conduct routine monitoring of the performance of its air emission control systems.
7. Materials Restrictions
   Suppliers are to adhere to all applicable laws, regulations and customer requirements regarding prohibition or restriction of specific substances, including labeling, recycling, and disposal.

Sycomp requires its Suppliers, their sub-tier suppliers, and any other 3rd party agents to uphold the highest standards of ethics in their business operations.

1. Business Integrity
   The highest standards of integrity are to be upheld in all business interactions. Suppliers shall have a zero-tolerance policy to prohibit any and all forms of bribery, corruption, extortion, and embezzlement. All business dealings should be transparently performed and accurately reflected on Supplier’s business books and records. Monitoring and enforcement procedures shall be implemented to ensure compliance with anti-corruption laws including but not limited to the United Kingdom Bribery Act and the United States Foreign Corrupt Practices Act. Suppliers should conduct appropriate risk-based diligence prior to engaging contractors or third parties.
2. No Improper Advantage
   Bribes or other means of obtaining undue or improper advantage are not to be promised, offered, authorized, given, or accepted. This prohibition covers bribes to any government or public international organization officials, political parties, candidates for political office, employees of state owned or controlled companies, or any director, officer, employee or agent of a commercial customer or supplier. It also covers promising, offering, authorizing, giving, or accepting anything of value, either directly or indirectly through a third party in order to obtain or retain business, direct business to any person, or otherwise gain an improper advantage. This includes, without limitation, gifts, gratuities, favors, entertainment, and travel (including without limit to family members and friends of such individuals). Kickbacks, either directly or indirectly, to obtain or reward favorable treatment in any transaction and facilitation payments are also prohibited. Suppliers shall document accurately, timely and in full all transactions related to all business involving Sycomp. Supporting documentation for each transaction shall be maintained by Suppliers and made available for inspection by Sycomp.
3. Disclosure of Information
   Information regarding Supplier labor, health and safety, environmental practices, business activities, structure, financial situation, and performances to be disclosed in accordance with applicable laws, regulations, and prevailing industry practices. Falsification of records and/or misrepresentation of conditions or practices are unacceptable.
4. Protection of Intellectual Property
   Intellectual property rights are to be respected; transfer of technology and know-how is to be done in a manner that protects intellectual property rights; and customer information is to be securely safeguarded and access should be monitored and controlled on a regular basis. Contractor access to customer source code or design specifications should be highly restricted and appropriate controls should be put in place. Whistleblower Protection and Anonymous Complaints Supplier shall provide an anonymous complaint mechanism for managers and workers to report workplace grievances. Supplier shall protect whistleblower confidentiality and prohibit retaliation.
5. Fair Business, Advertising and Competition
   Standards of fair business, advertising and competition are to be upheld. Appropriate means to safeguard customer information must be available and used.
6. Conflicts of Interest
   Suppliers must be free to act with total objectivity in their business dealings with Sycomp, and thus, must avoid conflicts of interest. If a potential or actual conflict of interest arises that impedes a Supplier’s ability to act objectively in the business relationship with Sycomp, the Supplier must disclose all relevant details to Sycomp.
7. Privacy
   Suppliers are committed to protecting the reasonable privacy expectations of personal information of everyonethey dobusiness with, including suppliers, customers, consumers, and employees. Suppliers are to comply with privacy and information security laws and regulatory requirements when personal information is collected, stored, processed, transmitted, and shared.
8. Insider Trading
   Supplier must comply with all applicable insider trading and securities laws governing transactions in public company securities. If Supplier possesses or has access to material, nonpublic information about a public company in connection with its engagement with Sycomp, it must use that information solely for the purpose for which it was provided to Supplier. It may not use that information to trade in that public company securities and Supplier not provide the information to others so they can trade in said securities. Suppliers must take reasonable precautions to ensure their employees are not engaging in insider trading as it relates to said public company securities.
9. International Trade Controls
   If you are involved in the transfer of goods or services across national borders on behalf of our company or our customers, you must comply with all applicable laws and company policies regarding international trade restrictions, regardless of where you are located. If U.S. law conflicts with a local trade law, U.S. law may apply.
10. Export Compliance
    Supplier must comply strictly with all applicable export and import laws and regulations and not export, re-export, transfer, divert, release, import or disclose any products in violation thereof, or disclose any Sycomp confidential information to another person or entity except under license or as otherwise permitted under such laws and regulations.

Sycomp believes that sound management systems such as those identified below, and commitment are key to enriching the social and environmental well-being of our supply chain. Supplier shall have policy statements affirming its commitment to corporate social and environmental responsibility endorsed by executive management. Supplier should implement or maintain, as applicable, a management system that facilitates compliance with this Supplier Code and the law, identifies and mitigates related operational risks, and facilitates continuous improvement.

1. Accountability and Responsibility
   Supplier shall identify company representatives for ensuring implementation of the management systems and associated programs, which should be reviewed by a senior manager on a regular basis. The management systems and associated programs should include a process to identify monitor and understand applicable laws, regulations and customer requirements (such as Supplier Code), training for managers and workers to understand and implement Supplier’s policies and meet the applicable legal, regulatory and customer requirements, and an ongoing process to assess workers’ understanding of and obtain feedback on practices and conditions covered by this Supplier Code and to foster continuous improvement.
2. Audits, Assessments and Certifications
   Supplier shall have a process to identify the legal compliance, environmental, health and safety and labor practice and ethics risks associated with Supplier’s operations, determine the relative’s significance for each risk and implement appropriate procedures and controls to control the identified risks. Supplier shall have written standards, performance objectives, targets, and implementation plans, including periodic assessments of the performance against those objectives. It shall also perform periodic self-evaluation to ensure conformity to legal and regulatory requirements, the content of this Supplier Code and customer contractual requirements related to social and environmental responsibility. Where applicable, Supplier shall have a process for timely correction of deficiencies identified by internal or external assessments, inspections, investigations, and reviews.
3. Documentation and Records
   Supplier shall have processes and controls to ensure accurate books and records, and creation and maintenance of documents and records to ensure regulatory compliance and conformity to company requirements and this Supplier Code along with appropriate confidentiality to protect privacy.

Supplier is encouraged to immediately report events of questionable, fraudulent, or illegal nature that are, or may be in violation of this Supplier code, or other applicable laws or regulations, to Sycomp via email at [email protected] or Sycomp’s Ethics Web portal (www.sycomp.ethicspoint.com). If you wish to contact via phoneline, phone numbers are available on Sycomp’s Ethics Web portal.