CNG

Supplier Code of Conduct

Central National Gottesman (“CNG”) is a privately held global trade and distribution company guided in all we do by a strongly held commitment to environmental sustainability and social responsibility.

CNG’s culture has been built by five generations of family ownership and the company has maintained these essential values through over 137 years in business. As such, we choose suppliers and business partners whose operations reflect the same commitment to high ethical standards, protection of the earth’s resources, health and safety in the workplace, and integrity in transacting business at every level.

CNG expects all suppliers together with their respective affiliates, subsidiaries and divisions, (each a “Supplier”) to adhere to the standards set forth in this Supplier Code of Conduct (“Code”). Each Supplier is responsible for ensuring that its employees, representatives, and subcontractors understand and comply with this Code.

Wages and Human Rights

Supplier will comply with all applicable laws and regulations with respect to wages, working hours, benefits and overtime. Supplier will respect and comply with all applicable laws regarding payment of wages, freedom of association and the right to collective bargaining without fear of retaliation. Supplier will not engage in any form of child labor or the exploitation of children in any of its facilities or operations. Supplier will not engage in any form of involuntary, forced or bonded or compulsory labor, or human trafficking and will adopt a zero tolerance policy against child labor, modern slavery and human trafficking. Supplier will not impose unreasonable restrictions on employees’ basic liberties. Supplier will not engage in any discriminatory practices or tolerate any form of discrimination or harassment, including due to age, gender, marital status, pregnancy, religion, ethnic or national origin, political affiliation, disability, or any other characteristic protected under applicable law. Supplier will communicate its nondiscrimination policies to its employees, and Supplier will address worker concerns about illegal or discriminatory conduct and resolve substantiated concerns according to its policies.

Health and Safety

Supplier will comply with all applicable health and safety laws, regulations, and standards. Supplier will have established procedures to maintain a safe and healthy workplace, including providing adequate ventilation, lighting, temperature controls and appropriate preventative maintenance, including protective equipment in compliance with the law.

Environment

Supplier will comply with all applicable environmental laws, regulations and sound industry standards, including compliance with any applicable environmental permitting or reporting requirements. Supplier will seek ways to conserve natural resources and energy, reduce waste and the use of hazardous substances, and minimize any adverse effects on people, communities and the environment. Supplier will, and will encourage its supply chain to, collaborate with CNG in its sustainability efforts where possible.

Corruption, Bribes, Illegal Payments, and Conflicts

Supplier will not participate in any form of bribery and will not offer inappropriate gifts or entertainment to CNG employees or government officials or to anyone else on CNG’s behalf, intended to influence them to take or not take a course of action or for any other improper purpose. Supplier will not make direct or indirect political contributions on CNG’s behalf. Supplier will comply with all anti-bribery laws, including without limitation, the U.S. Foreign Corrupt Practices Act of 1977. Supplier will not enter into any arrangement with a CNG employee that would make it difficult for such CNG employee to work objectively and effectively on CNG’s behalf. Supplier will not participate in any form of boycotts, or otherwise engage in any anti-competitive or unfair trade practices.

Intellectual Property and Data Privacy

Supplier must protect all of CNG’s intellectual property rights and confidential or proprietary information and must also protect any personally identifiable information of CNG or its customers from unauthorized use, access, destruction and disclosure.

Compliance and Laws

In addition to the compliance requirements described above, Supplier must be aware of and comply with all other applicable laws and regulations in all of the locations of its operations.

Assurance of Compliance

Supplier is expected to self-monitor its compliance with this Code and inform CNG in a timely manner of any non-compliance by reporting to cnglegal@cng-inc.com. CNG may request Supplier to verify its compliance through a self-assessment questionnaire, third-party assessment and/or onsite audit. Supplier will reasonably cooperate with any such requests by or on behalf of CNG. Failure to report and remediate non-compliance could adversely affect awards by CNG of future business or result in termination.

“Central National Gottesman” and “CNG” refer to Central National Gottesman Inc. and each of its divisions and subsidiaries.