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Supplier Code of Conduct

Last updated: March 15, 2023

Supplier Code of Conduct
Supergoop's Code of Conduct outlines standards for conducting business in an ethical, lawful and responsible way. In accordance with these standards, Supergoop has established this Supplier Code of Conduct to ensure its suppliers are committed to the same principles.

Suppliers, their employees, agents, and subcontractors (collectively referred to as “Suppliers”) may enter into agreements with Supergoop to conduct business with us or on our behalf. All Suppliers are required to comply with this Supplier Code of Conduct, or at least all applicable laws and regulations. In rare circumstances, such agreements can still move forward if Supergoop identifies sufficient compensating controls in place to reasonably ensure legal compliance. Supergoop expects Suppliers to have strong corporate governance in place to support their compliance with this Code of Conduct. Supergoop may audit a Supplier upon reasonable notice to help confirm compliance with this Code of Conduct.

Supergoop reserves the right to discontinue a Supplier relationship in the event they are found to be acting unlawfully or in violation of this Code of Conduct or any applicable Supergoop policy.

This Supplier Code is based on internationally recognized standards, including the Universal Declaration of Human Rights and International Labor Organization’s Conventions.

Legal and Regulatory Compliance

Anti-Corruption: Never give or offer anything of value to gain an improper advantage, whether it be in dealings with government officials or the private sector. Suppliers are required to comply with all applicable laws and regulations, including, for example, the Foreign Corrupt Practices Act and United Kingdom Bribery Act of 2010.

Antitrust:Do not participate in any anti-competitive conduct such as discussing or exchanging competitively sensitive information or agreeing to geographic markets, customers or pricing with competitors. Suppliers are required to comply with all applicable antitrust and fair competition laws.

Trade:Comply with applicable import and export laws, act in accordance with trade restrictions of the US Treasury Departmentʼs Office of Foreign Assets Control (OFAC) and any other applicable trade restrictions.

Business Practices and Ethics

Conflicts of Interest:

Avoid conflicts of interest or even the appearance of conflicts of interest. Suppliers must not deal directly with any Supergoop employee whose spouse, domestic partner, or other relative has an interest in the Supplier as an employee, partner, owner, investor, or similar roles, including negotiating the Supplier contract. However, it is imperative that they disclose to their leader as soon as possible the existence of any actual or potential conflict of interest so that safeguards can be established to protect all parties.

Gifts and Hospitality:

Avoid giving gifts or providing lavish hospitality to Supergoop employees. If offering a gift or hospitality to an Supergoop employee, Suppliers should use good judgment and ensure it complies with applicable laws, and is consistent with local customs.

Records Management:

Accurately record, maintain, and report financial and business information. Ensure compliance with all applicable laws and regulations regarding such information. Supergoop reserves the right to audit such information with appropriate notice.

External Communications:

Do not speak publicly on Supergoop's behalf unless authorized to do so by Supergoop Legal.

Risk Management:

Implement internal policies, procedures, and controls to identify, address, and remediate risks addressed in this Code of Conduct as well as applicable legal requirements.

Training and Communication:

Communicate this Code of Conduct to all employees or contractors who will be conducting business with Supergoop and conduct training for employees, when necessary.

Labor Practices

Anti-harassment and Unlawful Discrimination: Provide equal opportunity employment and maintain a respectful work environment that is free of discrimination, violence harassment, and intimidation. Child Labor and Young Workers: Must not employ child labor. The term ‘child’ means any person employed under the age of 15 (or 14 where the law of the country permits) or under the minimum age for employment in the country, whichever is greater. Any supplier employing young workers (workers above the minimum age of employment but under the age of 18) must comply with applicable laws and regulations regarding hours,compensation and must avoid conditions or restrictions that could be harmful to their morals, health, safety and development.

Forced labor and Human Trafficking:

Must not use or benefit from any form of human trafficking, or forced or compulsory labor of any kind, be it prison, bonded, indentured or otherwise. Furthermore, mandatory overtime is not permitted, and workers must be allowed to leave their employment after giving reasonable notice. Im posing monetary fines, withholding identity papers (such as passports), work permits, remuneration or requiring recruitment deposits or other constraints as a condition of employment, is not allowed.


Provide compensation (including overtime and benefits) that at a minimum, complies with local laws. Suppliers must pay their employees in a timely manner and provide documentation detailing the basis of their pay (e.g., paystub).

Freedom of Association:

Abide by all applicable laws pertaining to freedom of association and collective bargaining. Do not retaliate against employees who choose to organize.

Health and Safety:

Must meet and strive to exceed requirements of applicable health and safety laws and regulations. Suppliers must maintain a clean, healthy and safe workplace. Any residential facilities must be similarly maintained. Work areas must be of a standard to prevent accidents, injuries and illnesses, and to ensure an adequate level of sanitation. Suppliers must reduce the potential for injuries and illnesses in the workplace by eliminating or minimizing workplace hazards and providing health and safety training to workers.

Environmental Protection Compliance with Environmental Laws and Regulations:

Abide by all applicable laws for hazardous materials, air emissions, waste, and wastewater discharges.

Ecological Footprint:

Conduct business in an environmentally responsible and sustainable manner, including: resource-efficient consumption of energy, water and other natural resources, minimizing waste and diversion from landfills, and reducing harmful chemical use.

Protection of Data, Intellectual Property, and Assets

Data Protection:

Protect confidential and proprietary information of Supergoop, Supergoop employees, members, and others with whom we do business. Information should not be disclosed without proper authorization and should only be used for a legitimate business purpose. All information uses must comply with all applicable laws, regulations, and governing contracts.

Protect Supergoop's Intellectual Property and Assets:

Protect and use Supergoop's intellectual property and tangible assets responsibly. Supergoop's intellectual property (including name, logo, trademarks, etc.) and tangible assets should be used for legitimate business purposes and only when authorized to do so by Supergoop.