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Supplier Code of Conduct

SUPPLIER CODE OF CONDUCT POLICY

American CyberSystems, Inc.’s d/b/a ACS Solutions and its subsidiaries and affiliates (collectively “ACS Solutions”) Supplier Code of Conduct Policy, as may be amended from time to time, outlines ACS Solutions’ process it undergoes to evaluate and vet a Supplier as well as establish a Supplier Code of Conduct (the “Supplier Code”) that outlines a clear set of standards and protocols that are required to be respected and adhered to by all Suppliers. The Supplier Code embodies ACS Solution’s commitment to internationally recognized standards, relevant statutory requirements, and industry standards.

ACS Solutions is committed to ensuring that each business decision is aligned with its fundamental core values of Passion, Respect, Integrity, Diversity and Excellence (PRIDE). ACS Solutions’ Supplier Code embodies PRIDE into practice.

ACS Solutions requires all Suppliers to comply and uphold the policies, procedures, standards, and principles as set forth in the Supplier Code. ‘Supplier’ refers to service providers, business partners, vendors, traders, agents, sub-agents, consultants, contractors, sub-contractors, third-parties; including their employees, agents and other representatives; and any other individual/entity that has a business relationship with ACS Solutions.

Suppliers are first evaluated and vetted to ensure that conducts itself with the utmost integrity, by reviewing whether such Supplier poses a financial risk, a cyber risk, an operational risk and finally a reputation risk. Once a Suppliers are approved, Suppliers are required to abide by this Supplier Code and ensure that this Supplier Code is communicated throughout their supply chain by adopting efficient management systems, policies, procedures, and training. Suppliers are required to ensure that any work performed for and/or on behalf of ACS Solutions is done in full compliance with the Supplier Code, all applicable statutes, rules, and regulations, and in accordance with the highest standards of ethical business conduct. Suppliers are also reviewed on a regular basis to ensure that the Supplier has not become a financial risk, a cyber risk, an operational risk, or a reputational risk.

ACS Solutions requires its Suppliers to abide by all applicable statutes, rules, and regulations in the markets where it operates, however, where principles and standards differ from this Supplier Code, ACS Solutions expect its Suppliers to comply with the more stringent standards and principles.

Furthermore, ACS Solutions is an Equal Opportunity Employer and prohibits any kind of unlawful discrimination and harassment. ACS Solutions is committed to the principle of equal employment opportunity for all employees and to providing employees with a work environment free of discrimination and harassment on the basis of race, color, religion or belief, national origin, citizenship, social or ethnic origin, sex, age, physical or mental disability, veteran status, marital status, domestic partner status, sexual orientation, or any other status protected by the statutes, rules, and regulations in the locations where it operates. ACS Solutions expects and requires its Suppliers to comply, and require that the Supplier ensure that its suppliers, service providers, contractors, sub-contractors, vendors,etc. comply, with all applicable federal, state, and local equal employment opportunity statutes, rules, and regulations.

Full compliance to the Supplier Code is required in addition to compliance with any other contract a Supplier may have with ACS Solutions. Deviations from or violations of the Supplier Code are unacceptable. Suppliers must promptly notify ACS Solutions in the event there is any breach or inconsistencies in adherence to the Supplier Code. Failure to comply with the Supplier Code will result in termination of the relationship with the Supplier in addition to any other remedy ACS Solutions may have at law.

By entering into any agreement ACS Solutions, the Supplier acknowledges its acceptance of the Supplier Code and intention to comply with the requirements.

Last updated December 16, 2020.