Supplier Code of Conduct

1. Overview & Purpose

At IPS, we are committed to conducting business with integrity, ethical standards, and social and environmental responsibility. We expect our suppliers, vendors, contractors, and business partners (collectively, “Suppliers”) to share these core values and adhere to the principles outlined in this Supplier Code of Conduct (“Code”).

2. Ethics & Business Conduct

Suppliers must adhere to the highest standards of integrity and fair dealing:

• Anti-Corruption & Anti-Bribery: Suppliers must strictly prohibit all forms of bribery, extortion, kickbacks, or embezzlement. Compliance with the U.S. Foreign Corrupt Practices Act (FCPA) and local anti-corruption laws is required.
• Conflicts of Interest: Suppliers must avoid situations that create a real or perceived conflict of interest with IPS. Any potential conflicts must be promptly disclosed.
• Fair Competition: Suppliers must conduct business in full compliance with antitrust and fair competition laws.
• Data Privacy & Security: Suppliers must safeguard sensitive, proprietary, and personal data provided by IPS, its employees, or its customers, ensuring compliance with applicable data protection laws.

3. Labor & Human Rights

Suppliers must treat all workers with dignity, respect, and fairness:

• Freely Chosen Employment: Forced, bonded, indentured, or involuntary prison labor is strictly prohibited.
• Child Labor Prevention: Child labor is strictly forbidden. Workers must meet the local legal minimum age for employment or age 15, whichever is higher.
• Fair Working Hours & Compensation: Compensation paid to workers must comply with all applicable wage laws, including minimum wage, overtime, and legally mandated benefits.
• Non-Discrimination & Anti-Harassment: Suppliers must foster a workplace free of harassment, abuse, and unlawful discrimination based on race, color, gender, age, religion, disability, national origin, or sexual orientation.
• Freedom of Association: Workers must be permitted to associate freely and bargain collectively in accordance with local laws.

4. Health & Safety

Suppliers must provide a safe and healthy working environment for all employees:

• Workplace Safety: Suppliers must identify, assess, and minimize exposure to potential safety hazards through proper controls, preventative maintenance, and safety training.
• Emergency Preparedness: Suppliers must implement clear emergency plans, including evacuation routes, fire detection, and appropriate response procedures.
• Occupational Health: Measures must be in place to reduce physical strain, repetitive motion injuries, and exposure to chemical or biological hazards.

5. Environmental Responsibility

Suppliers are encouraged to minimize their environmental impact and support sustainable operations:

• Environmental Permits & Compliance: All required environmental permits and approvals must be maintained and kept current.
• Resource Management: Suppliers should actively work to reduce waste, energy consumption, greenhouse gas emissions, and water usage in their operations.
• Hazardous Materials: Chemical and hazardous substances must be safely stored, handled, transported, and disposed of in compliance with environmental laws.

6. Management Systems & Compliance

To ensure ongoing compliance with this Code, Suppliers are expected to:

• Maintain Records: Retain accurate documentation to demonstrate compliance with this Code and allow access for periodic audits by IPS or its designated representatives.
• Sub-Tier Supply Chain Management: Pass down principles consistent with this Code to their own suppliers and sub-contractors.
• Reporting Violations: Maintain a confidential mechanism for employees to report ethical or legal violations without fear of retaliation.