Code of Conduct

1. Purpose and Scope

Second Nature Brands is committed to operating responsibly, ethically, and sustainably across our supply chain. We recognize that our Suppliers play a critical role in delivering safe, high-quality products while upholding the values expected by our customers, consumers, and stakeholders. 
This Supplier Code of Conduct (“Code”) establishes the minimum standards required of all suppliers, vendors, contractors, and business partners (“Suppliers”) providing goods or services to Second Nature Brands.

This Code applies to:

• All Supplier facilities and operations
• All workers, including permanent, temporary, contract, and migrant labor
• All subcontractors and upstream supply chain partners contributing to goods or services provided to Second Nature Brands

Suppliers are expected to:

• Comply with all applicable laws and regulations
• Meet or exceed the standards outlined in this Code
• Establish processes to ensure these expectations are upheld within their own supply chains 

Where local law and this Code differ, Suppliers must adhere to the more stringent requirement.

2. Responsible Employment and Human Rights

Second Nature Brands expects Suppliers to respect and uphold internationally recognized human rights and provide working conditions that are safe, fair, and respectful. Suppliers shall proactively identify and address risks related to labor practices and worker well-being within their operations and supply chains.

2.1 Non-Discrimination and Fair Treatment

Suppliers shall provide a workplace where individuals are treated with dignity and respect. Employment decisions, including hiring, compensation, promotion, discipline, and termination, must be based on merit and not on personal characteristics protected by law.

Suppliers shall:

• Prohibit discrimination, harassment, and retaliation
• Foster an inclusive and respectful workplace
• Maintain clear policies and training to prevent inappropriate conduct

2.2 Forced Labor and Human Trafficking

Second Nature Brands has zero tolerance for forced labor or human trafficking in any form.

Suppliers shall ensure:

• All employment is voluntary and free from coercion 
• Workers retain control of their identity and travel documents 
• Workers are not required to pay recruitment or employment fees 
• Workers are free to leave employment with reasonable notice 

Suppliers are expected to implement responsible recruitment practices and monitor labor agencies where used.

2.3 Child Labor

Suppliers must prevent child labor in all operations and supply chains.

Suppliers shall:

• Employ only workers who meet legal minimum age requirements
• Prohibit hazardous work for individuals under 18
• Maintain reliable age verification processes

Where child labor risks exist, Suppliers are expected to implement monitoring and remediation processes.

2.4 Wages, Benefits, and Working Hours

Suppliers must compensate workers fairly and transparently in accordance with applicable laws.

Suppliers shall:

• Pay wages on time, in full, and with clear documentation
• Provide legally required benefits
• Compensate overtime appropriately
• Ensure working hours do not exceed legal limits and allow for adequate rest

Suppliers shall take measurable steps toward providing living wages, including conducting wage assessments, developing improvement plans, and demonstrating progress toward closing any identified gaps within timeframes established by Second Nature Brands in a written corrective action plan.

2.5 Freedom of Association

Suppliers shall respect workers’ rights to freely associate, organize, and collectively bargain in accordance with local laws.

Where such rights are restricted by law, Suppliers shall establish and support alternative means of worker representation and engagement, including formal worker committees or equivalent channels through which workers may raise workplace concerns and participate in dialogue with management.

2.6 Grievance Mechanisms

Suppliers shall maintain effective grievance mechanisms that allow workers to raise concerns safely and without fear of retaliation.

These mechanisms should:

• Be accessible and confidential
• Support anonymous reporting where possible
• Provide timely investigation and resolution, including acknowledgment of receipt within five (5) business days and completion of investigation and resolution within thirty (30) to sixty (60) days timely investigation and resolution

3. Health, Safety, and Working Conditions

Second Nature Brands expects Suppliers to provide safe, healthy, and hygienic working environments. Suppliers must actively manage risks and continuously improve workplace safety performance.

3.1 Occupational Health & Safety

Suppliers shall:

• Identify, assess, and mitigate workplace hazards
• Provide appropriate training and PPE at no cost to workers
• Maintain safe equipment and processes
• Encourage reporting of unsafe conditions without retaliation

Suppliers shall implement and maintain structured safety management systems appropriate to their operations, including regular risk assessments and incident tracking.

3.2 Facilities and Worker Welfare

Suppliers shall provide working conditions that support employee well-being, including:

• Clean and safe facilities
• Access to potable drinking water
• Adequate sanitation and hygiene facilities
• Safe and compliant worker housing where applicable

3.3 Emergency Preparedness

Suppliers shall:

• Maintain emergency response plans
• Conduct periodic drills
• Ensure emergency exits, alarms, and fire protection systems are operational and accessible

4. Product Safety and Quality

Second Nature Brands is committed to delivering safe, high-quality products. Suppliers play a critical role in meeting this commitment.

Suppliers shall:

• Comply with all applicable food safety and product safety regulations
• Maintain documented food safety and quality systems (e.g., HACCP, GMPs)
• Ensure traceability of raw materials and finished goods
• Promptly notify Second Nature Brands of any product safety or quality concerns

Suppliers shall support and fully cooperate with audits, testing, inspections, and continuous improvement initiatives related to product safety and quality, including providing access to facilities, records, and personnel.

5. Environmental Responsibility

Second Nature Brands expects Suppliers to operate in a manner that minimizes environmental impact and supports long-term sustainability.

5.1 Compliance and Environmental Management

Suppliers shall:

• Comply with all environmental laws and regulations
• Maintain required permits and documentation
• Implement processes to monitor environmental performance

5.2 Resource Efficiency and Waste Management

Suppliers shall:

• Use natural resources efficiently
• Reduce waste and emissions
• Properly manage and dispose of hazardous materials

5.3 Climate and Emissions

Suppliers shall:

• Measure greenhouse gas emissions
• Establish and report progress against greenhouse gas reduction targets 
• Support broader climate-related initiatives

5.4 Land Use and Biodiversity

Where applicable, Suppliers shall:

• Avoid illegal deforestation and land conversion
• Respect land rights of local and Indigenous communities
• Conduct appropriate due diligence on sourcing impacts

6. Animal Welfare (Where Applicable)

Suppliers providing animal-derived materials shall:

• Comply with applicable animal welfare laws and standards
• Promote humane treatment throughout the supply chain
• Align with recognized animal welfare principles

7. Business Integrity and Ethics

Second Nature Brands expects Suppliers to conduct business with integrity, transparency, and accountability.

7.1 Legal Compliance

Suppliers shall comply with all applicable laws and regulations in the jurisdictions in which they operate, including all applicable trade laws, sanctions, export controls, anti-money laundering laws, and import/customs regulations. Suppliers shall not engage in any transaction involving sanctioned countries, entities, or individuals prohibited under applicable law.

7.2 Anti-Bribery and Corruption

Suppliers shall not engage in any form of bribery, corruption, extortion, or embezzlement. Suppliers shall comply with all applicable anti-corruption laws, including but not limited to the U.S. Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act. Suppliers shall: 

• Prohibit bribery, kickbacks, and improper payments
• Avoid conflicts of interest
• Maintain fair and transparent business practices

7.3 Records, Transparency, and Traceability

Suppliers shall:

• Maintain accurate and complete records
• Provide information required for traceability and compliance
• Support audits and verification activities

7.4 Confidentiality and Data Protection

Suppliers shall:

• Protect confidential information
• Safeguard intellectual property, sensitive data, and personal information in compliance with applicable data privacy and cybersecurity laws (including, where applicable, GDPR and CCPA), implement and maintain reasonable administrative, technical, and physical safeguards to protect such information, and promptly notify Second Nature Brands of any data breach or security incident affecting Second Nature Brands' information 

8. Supply Chain Responsibility

Suppliers are expected to extend the principles of this Code throughout their own supply chains. Suppliers shall exercise due diligence with respect to the sourcing of conflict minerals (tin, tantalum, tungsten, and gold) and other high-risk raw materials and shall provide sourcing information to Second Nature Brands upon request.

Suppliers shall:

• Contractually require subcontractors and upstream suppliers to comply with standards equivalent to this Code through written agreements, and provide evidence of such flow-down provisions to Second Nature Brands upon request 
• Implement due diligence processes to identify and mitigate risks
• Take corrective action where non-compliance is identified

9. Compliance, Monitoring, and Enforcement

Second Nature Brands may assess Supplier compliance at any time, including without prior notice, through:

• Documentation reviews
• Supplier self-assessments
• On-site or remote audits, including by qualified third-party auditors 

Suppliers shall:

• Fully cooperate with all compliance assessments, audits, and requests for information, including providing access to facilities, records, and workers. Suppliers shall bear the costs of any audit or assessment necessitated by a finding of non-compliance with this Code 
• Implement corrective action plans within timeframes specified by Second Nature Brands, and provide evidence of remediation 

Failure to comply with this Code will result in consequences proportionate to the severity of the violation, as follows:

• Required remediation
• Suspension of business
• Immediate termination of the Supplier relationship, particularly for zero-tolerance violations including forced labor, child labor, human trafficking, or bribery 

10. Reporting Concerns

Suppliers shall promptly report any known or suspected violations of this Code, including violations by their subcontractors or sub-suppliers.

Reports may be made through:

• Second Nature Brands Procurement or Supply Chain contact
• Online Ethics & Compliance Hotline
• Phone: 844-487-4729, code 8025125

All reports will be handled confidentially. Second Nature Brands strictly prohibits retaliation against any individual who reports a concern in good faith. Any Supplier found to have engaged in retaliation will be subject to immediate remedial action, up to and including termination of the Supplier relationship.

11. Acknowledgment

Suppliers must acknowledge and agree to comply with this Supplier Code of Conduct as a condition of doing business with Second Nature Brands. Suppliers shall designate a responsible individual to oversee compliance with this Code, certify compliance upon request, and re-certify compliance annually or upon any material update to this Code. Second Nature Brands reserves the right to update this Code from time to time, and continued business with Second Nature Brands constitutes acceptance of such updates. This Code shall be governed by and construed in accordance with the laws of the State of Michigan without regard to conflict of laws principles. In the event of any conflict between this Code and any other agreement between a Supplier and Second Nature Brands, the more stringent requirement shall apply.

ACKNOWLEDGED AND AGREED:

Supplier Name: ___________________________
Authorized Signatory: ___________________________
Title: ___________________________
Date: ___________________________

Second Nature Brands
Authorized Signatory: ___________________________
Title: ___________________________
Date: ___________________________