Introduction:

At Rhoback, Inc (“Rhoback”) we are committed to conducting our business in accordance with the highest ethical standards and to using business practices which seek to promote fairness, safety, and compliance with applicable laws. Through Rhoback’s Supplier Code of Conduct, we require our business partners to operate in accordance with such ethical standards and business practices. This Supplier Code of Conduct applies to all companies and entities which provide any goods or services to Rhoback, including our suppliers and subcontractors (collectively, “Suppliers”).

Compliance with Laws and Regulations:

Suppliers must comply with all applicable federal, state and international laws. Suppliers are responsible to ensure that any employees, distributors, subcontractors, agents, affiliates, or other representatives of Suppliers who provide any services or products to Rhoback read and comply with this Supplier Code of Conduct.

Ethical Behavior:

Suppliers must comply with the following requirements:

• No Discrimination: Rhoback expects all its Suppliers to treat their employees and workers with dignity and respect and to refrain from any unlawful harassment. No person employed by a Supplier shall be subject to any discrimination in employment, including hiring, compensation, or advancement on the basis of gender identity, race, religion, age, sex, disability, sexual orientation, color, nationality, veteran status, genetic information, social group or ethnic origin.

• Child Labor: Suppliers shall not directly or indirectly employ workers that are younger than the applicable required minimum age.

• Freedom Of Association & Collective Bargaining: Employers shall recognize and respect the right of employees to freedom of association and collective bargaining.

• Forced Labor: Suppliers shall not use any form of forced labor. Suppliers will not knowingly use or acquire materials from supply chains associated with human trafficking and will use reasonable efforts to ensure that their suppliers do not use any form of forced labor.

• Working Hours and Compensation: Suppliers shall comply with all applicable wage and hour laws, including those relating to minimum wage, overtime and the maximum number of hours that employees may work. Suppliers shall provide their employees with all benefits that they are legally entitled to.

• Health, Safety and Environmental: Suppliers shall provide their workers with a safe and healthy workplace and shall comply with all applicable health and safety laws. Rhoback is proud to be a Climate Neutral certified company. In addition to complying with all applicable environmental laws, Rhoback expects its Suppliers to proactively seek to reduce negative impacts on the environment through reduced energy consumption, using recycledalternatives throughout the supply chain when reasonably possible, and conserving natural resources.

• Improper Payments: Suppliers shall comply with all applicable anti-bribery and anti-corruption laws, including the U.S. Foreign Corrupt Practices Act and the UK Anti-Bribery Act. Suppliers shall not offer bribes, kickbacks or similar inducements to any person or entity, including any government official, and shall not make any payments to gifts to any such person for any improper purpose.

Compliance and Monitoring: 

Suppliers must implement and maintain a process to ensure their compliance with Rhoback’s Supplier Code of Conduct. Suppliers shall inform its employees, contractors, subcontractors, affiliates and agents about the requirements of this Code. Suppliers shall prepare and maintain such documentation as is necessary to establish their compliance with this Supplier Code of Conduct. Upon Rhoback’s request, Suppliers shall provide Rhoback with access to or copies of such documentation.

Updates:

Rhoback reserves the right to update its Supplier Code of Conduct from time to time to reflect changes in applicable laws and generally-accepted standards and practices relating to working conditions and ethical and fair business conduct. If Rhoback updates its Supplier Code of Conduct, Suppliers will be required to confirm their compliance with each updated version of the Rhoback Supplier Code of Conduct.

Violations: 

Reports of violations of Rhoback’s Supplier Code of Conduct may be reported by email to Rhoback’s attorney, Patrick Asplin, at pca@fplegal.com. In the event that a Supplier violates this Supplier Code of Conduct, Rhoback may immediately terminate such Supplier’s relationship with Rhoback