Adero Ethical Supply Chain Policy

Adero respects internationally recognized human rights and environmental standards and places them at the core of our business practices. We believe that no business should ever be complicit in human rights abuses. We promote greater environmental responsibility and we encourage the development and use of environmentally friendly technologies.

The Adero Ethical Supply Chain Guidelines are a reflection of our values. We strive to apply these values in everything we do. We select business partners who make a commitment to adhere to these Guidelines and to engage their employees in their implementation.

We are committed to a process of continuous improvement. We recognize that our own business practices can impact our business partners' ability to implement these Guidelines and we commit to addressing our impacts that are related to these Guidelines. Business partners agree to take responsibility for their business impacts, to correct problems when they are found and to build management systems that prevent problems from reoccurring.

All business partners will have in place a supplier management system that addresses their own Code of Conduct (including ethical treatment of their suppliers) in all their interactions with their suppliers.

All business partners will obey all applicable laws and regulations, and in cases where either the Guidelines or the applicable laws are stricter, the higher of the two shall apply.

Forced Labor: Our business partners shall not use forced labor whether in the form of prison labor, indentured labor, bonded labor or otherwise.

Child Labor: Our business partners shall not employ workers below the age of 16, or, in the case of hazardous work, the age of 18. If the legal age for employment is higher than 16, then the higher age shall apply.

Wages and Benefits: Our business partners, at a minimum, will pay employees wages and benefits that meet applicable laws for all regular hours worked. For overtime hours, employees must receive compensation at premium rates. Employment practices such as training or apprenticeship wages, pre-employment fees, deposits, or other practices that effectively lower an employee's pay below the legal minimum wage are not permitted.

Hours of Work: Our business partners will comply with legally mandated work hours; use overtime only when each employee is fully compensated according to applicable law and informs each employee at the time of hiring if mandatory overtime is a condition of employment. Except in extraordinary business circumstances, employees are provided one day off in seven, and will work no more than 60 hours per week, or in compliance with legal limits if they are lower.

Non-discrimination: Employment decisions shall be made solely on the person's ability to do the job. No person shall be subject to discrimination in employment, including hiring, salary, benefits, advancement, discipline, termination or retirement on the basis of gender, race, religion, age, disability, sexual orientation, marital status, pregnancy, nationality, political opinion, social or ethnic origin.

Harassment or abuse:Our business partners shall treat their employees with respect and dignity. Work environments must be free of intolerance, retribution for grievances, and corporal punishment. No employee shall be subject to any physical, sexual, psychological or verbal harassment or abuse.

Freedom of association/collective bargaining: Our business partners shall recognize and respect the right of employees to freedom of association and collective bargaining. Where these rights are restricted under law, parallel means for the representation of workers are encouraged.

Health and Safety: Our business partners shall ensure a safe and healthy workplace. Business partners shall provide written safety and health policies and procedures that minimize negative impacts on the workplace environment, reduce work related injury and illness, and promote the general health of employees. Employers must provide training and adequate equipment to ensure workplace safety practices. This also applies to residential facilities if provided.

Environment: We require a continuous effort to improve environmental performance along a defined path towards clean production. We expect our business partners to: 1) adopt environmental management systems that address key business impacts and advance sustainable environmental practices; 2) disclose environmental impacts and activities through regular reporting; 3) reduce or eliminate toxic and hazardous substances from operations and products; 4) increase efficiency and thereby minimize pollution and waste; 5) reduce the use of natural resources including raw materials, energy and water; and 6) take responsibility for proper waste management.

Assessments and Monitoring: To measure progress against these Guidelines, we may conduct ongoing assessments and reviews of facilities. We require full and open access to the facilities, operations and employees involved in our business. Business partners are further required to maintain sufficient records to demonstrate and verify compliance with these Guidelines.