Supplier code of conduct

Ethos ESG Investments, LLC (including its subsidiaries, “Ethos”) is committed to acting in accordance with its core values and expects its suppliers to exhibit a commitment to similar standards. As a socially and environmentally responsible corporate entity, Ethos recognizes the importance of working with its suppliers and their impact on Ethos' performance and success.

This Code of Conduct was last updated in February 2021 and:

Summarizes Ethos' principles for sourcing goods and services via third party suppliers or vendors (hereinafter “Suppliers”); and

Defines the conduct Ethos expects from its Suppliers.

The Code of Conduct sets out Ethos' values and expectations, including our sourcing principles, as well as the labor, human rights, environmental, and legal compliance principles we expect our Suppliers to uphold.

Ethos expects its Suppliers to live up to both the letter and the spirit of this Code of Conduct. Ethos may request, and Suppliers shall promptly furnish to Ethos, a self-assessment as to the Supplier's adherence to the standards and principles of this code. Supplier compliance with this Code of Conduct may also be subject to audit by Ethos.

Ethos conducts business worldwide, managing Ethos' Supplier relationships, including those involving financial market data, technology hardware, software applications, technology services, travel-related services, consultancy and other services. Ethos provides this Code of Conduct to new Suppliers, in connection with the contracting and onboarding process, as well as an updated version on an annual basis for each Supplier.

Legal compliance

This Code of Conduct must be read in conjunction with applicable law and relevant contractual arrangements. Suppliers must comply with all applicable laws, regulations and industry standards where each such Supplier is located and conducts business. In addition, Ethos expects its Suppliers to comply with applicable United Nations Conventions. Suppliers have a duty to protect and safeguard confidential (including personal) information and to take precautions before sharing with anyone. All Suppliers shall respect all intellectual property rights of Ethos and third parties. If compliance with any provision of this Code of Conduct would result in a legal or regulatory violation, Suppliers must follow the law or rule. Where the Code of Conduct and a Supplier agreement conflict, the Supplier agreement prevails.

General sourcing principles

Supplier evaluation and selection procedures include an assessment of Supplier’s business practices and corporate values, including the following reviews:

• Supplier Business Review – Best-fit products and services to meet our needs.
• Commercial Review – Best value vs. expenditure.
• Security Review – Security architecture review.
• Legal Review – Terms and conditions review.
• Financial Review – Economic value and funding review.

Where appropriate, Ethos may invite Suppliers to participate in a competitive bidding process. Ethos expects Suppliers to agree to Ethos’s form of standard contractual documentation but may elect in its sole discretion to adopt part or all of specific Suppliers’ agreements.

Labor, workplace and human rights

Ethos is committed to the protection of human rights globally and to providing a fair and ethical workplace. We respect the standards embodied in the United Nations Universal Declaration of Human Rights (“UDHR”) and the International Labor Organization conventions. Specifically, Ethos is strongly opposed to slavery and human trafficking and will not knowingly support or conduct business with any organization involved in such activities. Ethos expects its Suppliers to act in accordance with the following principles:

• All employment must be freely chosen – We will not tolerate the use of involuntary, trafficked or forced labor.
• Freedom of association for all employees – Suppliers must uphold this right.
• All employees must be of a specified age respecting all local laws at all times – Suppliers must comply with age employment standards. ¹
• Compliance with wage laws including working hours and salaries Ethos requires all Suppliers to provide a living wage to its employees – a wage which enables employees to enjoy acceptable living conditions. Employees must not be required to work more than the maximum hours allowed per local law. Any overtime must take place with the prior consent of the individual and must be compensated appropriately as established per local law.
• Humane treatment of all employees – All Suppliers must provide and maintain a safe work environment and integrate reliable health and safety policies for conducting its business. Suppliers’ premises and facilities must comply with relevant legal and regulatory requirements. Any unfair disciplinary practices or corporal punishment by any of its Suppliers will not be tolerated by Ethos.
• Appropriate emergency plan in place – Suppliers must ensure that their office and plant facilities have an appropriate emergency plan in place.
• Adequate ethical and human rights standards in place – Appropriate procedures must be in place and enforced to deal with any breaches of these standards.
• Protect the privacy of personal information – Suppliers must ensure that a rigorous security process is in place to protect employees’ personal information and any Ethos information from unauthorized use, access, or disclosure.
• Antidiscrimination – It is the policy of Ethos to ensure that equal employment opportunity exists for all persons, without discrimination or harassment and in strict accordance with applicable laws and regulations.
• Treat people with respect and dignity – Suppliers must act in accordance with the guiding principles of the UDHR.

1. The Minimum Age Convention, 1973 (No.138) set by International Labor Standards on Child Labor sets the general minimum age for admission to employment or work at 15 years (13 for light work) and the minimum age for hazardous work at 18 (16 under certain conditions). It provides for the possibility of initially setting the general minimum age at 14 (12 for light work) where the economy and educational facilities are insufficiently developed. Suppliers employing children of school age must offer the children compensating programs, including education and financial support in co-operation with the child and its family or next of kin.

Environment

Ethos is committed to protecting the environment and expects its Suppliers to implement appropriate standards to do likewise. Ethos reserves the right to actively engage with its Suppliers to improve their environmental and sustainability performance. Ethos expects Suppliers to meet or exceed the below set of principles:

• To develop, adopt, monitor and disclose climate and carbon-related policies and strategies – Suppliers are expected to take steps to understand their climate risks, to minimize their environmental impact and to implement policies to reduce Greenhouse Gas (GHG) emissions.
• Compliance with applicable environmental laws, regulations and standards – Suppliers must be aware of and adhere to the laws relevant to the Supplier’s activities for the entire sourcing and production cycle: material sourcing – manufacturing – logistics – disposal.
• SMART (e.g., specific, measurable, achievable, realistic, time-bound) environmental goals and reporting – Suppliers need to be able to identify, measure and report significant environmental impacts, including GHG emissions.
• Responsible stewardship of natural resources – Suppliers must actively implement processes to reduce, reuse and recycle materials throughout their production/service cycles.
• Waste management – Suppliers are expected to handle waste in a responsible way and maintain separate hazardous and non-hazardous waste management processes.

Ethics and anti-corruption

The highest standards of ethics and integrity are to be adhered to by its Suppliers in all dealings with Ethos. Ethos also expects its Suppliers to have zero-tolerance for corruption and comply with all United Nations Conventions and applicable laws against corruption. Suppliers may not:

• offer, promise, or give bribes or facilitation payments, or anything that could be construed or perceived as a bribe or facilitation payment; or
• request, agree to accept, or accept bribes or facilitation payments or anything that could be construed or perceived as a bribe or facilitation payment in connection with Ethos.

The terms “bribe” and “facilitation payment” are broadly defined and includes anything of value, such as a payment, gift or benefit of any kind, offered or given with the purpose of influencing a decision or action.

Standards and supplier's supply chain

This Code of Conduct is not and should not be interpreted to circumvent or undermine laws, rules or regulations. This Code of Conduct establishes minimum standards, which Ethos expects Suppliers to meet or exceed. Ethos will not accept any attempt to use this Code of Conduct's requirements to lower existing or future standards that apply to Ethos or that we have implemented. Failure to meet these principles and standards may be cause for termination of a relationship or agreement with a Supplier.