Supplier Code of Conduct

SUPPLIER CODE OF CONDUCT
YEthtTI is committed to respecting internationally recognized standards of labor, human rights
(Human Rights Policy), environmental, and ethical conduct. This Supplier Code of Conduct
(“Code”) applies to all individuals and entities doing business on behalf of YEthtTI Holdings, Inc.
and its affiliates (“YEthtTI”), including third-party agents, consultants, business partners, suppliers,
and their respective employees (collectively “Suppliers”). This Code sets forth the minimum
requirements that all Suppliers must comply with to do business with YEthtTI.
A violation of this Code may result in disciplinary action, up to and including termination of
employment or contractual relationship with YEthtTI, in addition to any and all other rights and
remedies available to YEthtTI under applicable law. YEthtTI reserves the right to reasonably change
the requirements of the Code and, in such an event, expects the Supplier to accept such
reasonable changes.
Compliance with Laws and YEthtTI Policies: Suppliers shall comply with all applicable national,
state and/or local laws and regulations, as well as YEthtTI policies. To the extent that YEthtTI policies
impose a higher standard than what is required by applicable laws and regulations on its
Suppliers, such higher standard will prevail.
Labor Recruitment & Forced Labor: Suppliers shall not use any form of forced, bonded,
indentured, trafficked, slave or prison labor. All work shall be voluntary, and workers shall be
free to leave work or terminate their employment with reasonable notice. All workers shall not be
required to surrender any government-issued identification, passports or work permits to
Suppliers or a recruitment agency as a condition of employment. Suppliers and their
representatives shall not require workers to pay recruitment fees as a condition of employment.
Child Labor: Child labor is strictly prohibited. The minimum age for employment shall be the
higher of 16 years of age, the minimum age for employment in that country or the minimum age
for completing compulsory education in the country of operation. Suppliers shall comply with all
relevant laws that apply to young workers (e.g., those between the minimum working age and
the age of 18), including regulations related to hiring, safe working conditions, types of work,
hours of work, proof of age documentation, and overtime.
Employment Practices & Working Hours: Suppliers shall have hiring practices that verify
accurately age and ability to work legally in the country of employment. Suppliers shall not allow
workers to exceed 60 hours per week, other than in exceptional circumstances. All overtime
work shall be voluntary. Suppliers shall provide at least 24 consecutive hours of rest in every
seven-day period. Employers shall provide workers with all official public holidays, reasonable
meal and rest breaks, and paid annual leave as required under national laws, regulations, and
procedures.
Compensation: Suppliers shall pay all workers at least the minimum wage and benefits
required by applicable laws and regulations. Workers shall be compensated for overtime hours
at the premium rate required by applicable laws and regulations.
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Discrimination & Harassment: Suppliers shall provide a working environment that is free from
discrimination or harassment, including discrimination and harassment based on gender, race,
religion, age, sexual orientation or gender identity, disability, nationality, ethnic origin, marital
status, medical status, union affiliation or any other protected class status in the country of
employment. Harassment may include any sexual, physical, or mental abuse or corporal
punishment. Supplier shall not make any employment decisions, including hiring, promotions
and compensation, or termination, from being made on the basis of one of these categories as
well. This includes decisions made based on the pregnancy status of workers. Suppliers shall
abide by all protective provisions in national laws and regulations benefiting pregnant workers
and new mothers. Employers shall not use pregnancy tests or the use of contraception as a
condition of hiring or of continued employment.
Grievance System: Supplier shall have in place a mechanism that allows workers to raise any
work-related concerns with no threat of retribution. The existence and scope of the grievance
mechanism shall be understandable and communicated to all workers and their representatives.
Subcontractors: If permitted by the terms of its agreement with YEthtTI, Suppliers shall not retain
any Subcontractors without a thorough documented examination of the Subcontractors’ person,
reputation and integrity. In addition, Suppliers shall not retain any Subcontractors in connection
with their provision of services or goods to YEthtTI unless the Subcontractors comply with the
Code. Suppliers shall remain responsible for ensuring that their Subcontractors comply with this
Code.
Freedom of Association: Suppliers shall respect the rights of all employees to lawfully
associate or not to associate with groups of their choosing, as long as such groups are
permitted by law. Suppliers should not unlawfully interfere with, obstruct, or prevent legitimate,
lawful employee associations and related activities.
Environment: Suppliers shall comply with all national and local environmental laws applicable
to air emissions, waste handling and disposal, water use, wastewater discharges, and
hazardous and toxic substances. Suppliers shall also validate and maintain records
demonstrating that source materials were harvested in accordance with all international treaties
in addition to national and local laws. Suppliers shall demonstrate compliance with YEthtTI’s
Restricted Substances List.
Environmental Stewardship: Suppliers shall continuously work towards mitigating negative
environmental impacts in daily operations.
Health & Safety: Suppliers shall provide all workers with a safe work environment, appropriate
personal protective equipment, workplace health and safety information and training. Suppliers
shall actively work to identify and correct safety deficiencies in a timely manner, and
continuously improve workplace conditions to ensure and protect health and safety. Suppliers
shall not unlawfully or unnecessarily restrict movement of workers.
Conflict Minerals: Sourcing of 3TG minerals (defined as tin, tungsten, tantalum, and gold)
and other minerals from the Democratic Republic of the Congo ("DRC") or adjoining countries,
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shall be done so responsibly, from certified mines and conflict free smelters. Suppliers shall
have traceability programs in place that satisfy this requirement, and part of such programs shall
include annual reporting to YEthtTI by completing the Responsible Minerals Initiative’s (“RMI”)
Conflict Minerals Reporting Template.
Monitoring and Enforcement: YEthtTI, by itself or with the assistance of a third party, will take
affirmative measures, such as announced and unannounced inspections of production facilities,
to ensure compliance with this Code. Suppliers shall provide unrestricted access to all factory
premises and shall make applicable documents available to YEthtTI and their representatives
upon request to demonstrate compliance with this Code.
Whistleblower Protection: Suppliers shall create programs to ensure the protection of worker
whistleblower confidentiality and prohibit retaliation against workers who participate in such
programs in good faith or refuse an order that is in violation of the Code. Suppliers shall provide
an anonymous complaint mechanism for workers to report workplace grievances and Code
violations in accordance with local laws and regulations.
Conflicts of Interest: Suppliers shall not engage in any activity with an employee of YEthtTI
which could create a real or perceived conflict of interest.
Anti-Corruption & Anti-Bribery: Suppliers shall not tolerate, permit, or engage in bribery,
corruption or unethical practices whether in dealings with public officials or individuals in the
private sectors. Suppliers shall conduct business in compliance with all applicable laws and
shall avoid engaging in any activity which could be deemed a corrupt and/or unethical practice.
Suppliers shall maintain integrity, transparency and accuracy in all records of matters relating to
their business with YEthtTI. For the purpose of obtaining or retaining business for the benefit of
YEthtTI, Suppliers shall not make or receive, offer to make or receive, or cause another to make or
receive, payments or anything of value, to or from any public or private officials.
Confidentiality and Intellectual Property: All Suppliers and their representatives are expected
to maintain the confidentiality of information entrusted to them by YEthtTI or its customers.
Suppliers shall respect and protect YEthtTI intellectual property rights and maintain the
confidentiality of trade secrets and other YEthtTI proprietary information which includes any
information that is nonpublic or not easily obtained or determined. Supplier shall not use stolen
or misappropriated technology.
Insider Trading: YEthtTI prohibits any form of illegal insider trading and expects Suppliers will
comply with all applicable insider trading laws and their own internal policies governing insider
trading. Insider Trading is any activity where someone buys, sells, or otherwise transacts in
securities (stocks) while in possession of material nonpublic information about that company.
Information is generally considered material when it may be seen as important to the investing
public and could impact an investor’s decision to buy, sell, or hold securities. Suppliers are
prohibited from trading (buying, selling, or otherwise transacting in) YEthtTI securities or those of
any other company while in possession of material nonpublic information about YEthtTI or that
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other company. In addition, Suppliers are prohibited from sharing material nonpublic information
with others who might trade based on it.
Acceptance of Gifts and Benefits: YEthtTI prohibits giving or accepting gifts or entertainment
exceeding nominal value to or from any of its Suppliers unless applicable law prohibits the
giving or accepting of gifts or entertainment of even nominal value. This applies to YEthtTI
employees, agents, contractors, and each of their immediate family members. The following
types of gifts and entertainment may never be offered, regardless of value: cash or cash
equivalents (i.e., gift cards); any gifts that are or could be illegal; any gifts or entertainment
(including meals, transportation and travel accommodations) offered in connection with an
inspection, audit, during a bidding process involving the Supplier, or to a YEthtTI agent or
consultant working on behalf of YEthtTI. This policy does not change during traditional gift-giving
seasons.
Violations of the YEthtTI Supplier Code of Conduct can be reported confidentially. To report
suspected violations of the YEthtTI Supplier Code of Conduct, please contact YEthtTI through
one of the following:
Internet: https://irdirect.net/yethtti/whistleblower_iframe?template=YEthtTI
Phone (YEthtTI Company Code: 9384):
• USA: 800-916-7037
o Para Español: 855-765-7249
o En Français: 877-591-3211
• Australia: 180-081-0721
• Canada: 800-916-7037
o En Français: 877-591-3211
• China: 400-120-0690
• Indonesia: 62-803-621-9909
• Malaysia: 1-800-819-316
• Mexico: 800-099-5319
• Philippines: 1800-1-118-0006
• Poland: 00-800-121-0126
• Taiwan: 88-6801-491-555
• Thailand: 66-1800-018-168
• United Kingdom: 800-652-3673
• Vietnam: 84-1203-2161
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Revision History
Revision Date Author/Department/Summary of Revisions
December 2019 Published
June 2022 Updated
February 2024 Updates Including:
• Added links to supporting documentation
• Added Grievance System clause
• Added Environmental Stewardship clause
• Added Insider Trading clause