ENVIRONMENTAL LIGHTS
VENDOR CODE OF CONDUCT

Advanced Lighting Concepts, LLC d/b/a Environmental Lights, is committed to safeguarding the wellbeing of its own employees and all individuals involved in the supply chains for its products, as well as the wellbeing of communities and the environment in all places where Environmental Lights does business, and to conducting its business with high ethical standards.

Accordingly, Environmental Lights expects that its manufacturers, copackers, suppliers, contractors, subcontractors, agents, and any other person or entity involved in the manufacture and supply of Environmental Lights’ products (“Business Partners”) will share and actively support this commitment. This includes compliance with all applicable laws, rules, and regulations and with and the standards set forth in this Code of Conduct.

I. HUMAN RIGHTS

Business Partners shall not use forced labor, including child labor, prison labor, indentured labor, bonded labor, or any other form of forced labor. In addition to prohibiting all forced labor in their own workplaces, Business Partners must exercise due diligence to eradicate forced labor from all tiers of their supply chains.

Business Partners must ensure individuals work voluntarily, are not asked to pay for their employment, are paid at least the minimum wage required by local law, and are informed in a language they understand of the basic terms of their employment.

Business Partners must review documents confirming each worker’s eligibility to work, must employ only workers of the minimum age required by applicable law, and must comply with all hours-based and age-related restrictions imposed by law or regulation.

Business Partners must not expose individuals to unreasonably hazardous or unhealthy working environments. Business Partners must provide workplaces that are free from harassment, abuse, or the threat of violence, including any sexually coercive, threatening, or disrespectful conduct or speech, any form of physical or verbal abuse, or any harassment based on race, color, religion, gender, age, maternity, marital status, national origin, ethnic identity, indigenous status, language, disability, sexual orientation, or political affiliation. Business Partners must also respect the rights of free association and collective bargaining.

II. ENVIRONMENTAL PROTECTION

Business Partners must comply with all applicable environmental laws and regulations and must have all required environmental and safety permits.

Business Partners must endeavor to mitigate any adverse effects of their operations on the environment.

III. ETHICAL STANDARDS

Business Partners must conduct all operations with honesty and integrity, and in conformance withal laws and high ethical standards.

Business Partners must comply with all applicable laws and regulations regarding anti-bribery and anti-corruption or U.S. sanctions and export control laws, and, further, must not engage in any activity that would cause Environmental Lights to violate such laws and regulations. Business Partners must have and enforce policies to ensure such ethical operation.

Business Partners must not make, offer to make, or accept any illegal payments, gifts, kickbacks, or bribes, including facilitating payments, to gain an improper business advantage.

Business Partners must comply with all applicable sanctions laws or regulations and must conduct “know your vendor” diligence to ensure that sanctioned persons are not involved in fulfilling orders for Environmental Lights.

IV. SHARED RESPONSIBILITY

Business Partners must make this Code of Conduct available to all employees and members of their supply chains and must confirm these persons’ awareness and understanding of the Code of Conduct’s requirements.

Business Partners must notify Environmental Lights promptly if they learn of any event or condition in violation of this Code of Conduct. Business Partners must ensure that their employees have access to reporting channels and can make reports without fear of retaliation.

Business Partners must keep records necessary to confirm compliance with this Code of Conduct and make those records available to Environmental Lights upon request.

If Environmental Lights determines that a Business Partner is not in compliance with this Code of Conduct, Environmental Lights, in its sole discretion, may take appropriate corrective action, which could include termination of the relationship with Business Partner.