Governance Policies and Statements

Last Updated: June 26, 2023

Code of Ethical Conduct

Inolex is committed to engaging in ethical and socially responsible conduct and expects all its employees to share in that commitment. Accordingly, Inolex has adopted standards for ensuring the safety, quality and integrity of its products and processes, and for protecting the environment.

Inolex encourages supply chain transparency and accountability. Inolex selects its partners in an effort to develop long term relationships with people and organizations that are equally committed to high ethical and socially responsible standards, including the working conditions under which materials are sourced and products are made. Accordingly, suppliers, vendors, and other external partners of Inolex are expected to comply with local laws and regulations and uphold the code of ethical conduct.

In the absence of law in a particular location relating to product safety, labor, employment, environment or working conditions, the spirit and intent of these policies shall be met by Inolex employees and Inolex partners. Any concerns, violations, and perceived violations should be escalated to the Vice President of Global Supply Chain, the Human Resources Department, or the Chief Financial Officer.

A. Child labor is strictly prohibited. Inolex has a strict policy against any form of child labor. Inolex only employs persons 18 years of age and older on a full-time basis. Should the company ever decide to change this policy and begin to employ persons younger than 18 years of age, it will follow all the local, state, and federal laws and regulations regarding employing youth in the United States, including the prohibitions against minors working in any job or occupation declared hazardous by the United States Secretary of Labor. Additionally, if Inolex ever decided to employ minors it would follow any and all restrictions on hours of work, as well as break and meal period requirements. Under no circumstances does Inolex hire or cause anyone to work who is under the age of 16. The company verifies date of birth at the time of hire to ensure this code of conduct is upheld.

B. Compensation Practices. The company complies with all federal, state, and local wage and hour laws including, but not limited to, minimum wage, overtime, piece rates, and hiring, and provides legally mandated benefits.

C. Health and Safety in the Workplace. Inolex provides its workers with a safe, healthy, and secure workplace and complies with all applicable federal OSHA standards and federally approved OSHA state plans. Inolex provides, for example, access to clean drinking water, proper sanitation, adequate lighting and ventilation, safety training, fire extinguishers and fire evacuation escape routes.

D. Coercion and Harassment is Prohibited. Inolex treats each associate with dignity and respect. Inolex does not use, and does not tolerate the use of, physical or bodily punishment, threats of violence or other forms of physical, sexual, psychological, or verbal harassment or abuse.

E. Prison Labor/Reform Labor is Prohibited. Inolex does not use any prison or reform labor of any kind in its operations.

F. Forced Labor is Prohibited. Employment with Inolex is at will. Accordingly, unless there is a contract for employment, any employee of Inolex may terminate employment with the Company for any reason, at any time, with or without notice.

G. Human Trafficking and Slavery Prohibited. Inolex prohibits slavery and human trafficking of any kind in its operations.

H. Freedom of Association Allowed. Inolex allows associates all the protections afforded by law to associate, organize, and bargain collectively in a lawful and peaceful manner without interference or punishment.

I. Product Safety. Inolex complies with all applicable laws and regulations regarding the safety of our products. We make every effort to meet applicable recognized voluntary industry standards for our products and processes.

J. Environment. Inolex abides by all applicable environmental laws and regulations. Inolex manages its environmental footprint to minimize the adverse impact on the environment. Inolex strives to manage our energy, water and waste systems for maximum efficiency and minimal adverse impact on the environment.

K. Subcontractors and Sources. Inolex requires all businesses that support our business as subcontractors, manufacturers, or sources of goods to comply with the same policies as stated in our Code of Ethical Conduct and Social Accountability Policy. All subcontractors and suppliers are also required to comply with all applicable federal, state, and local laws.

L. SA 8000. Likewise, Inolex is committed to complying with SA 8000 Standards for our own workers’ rights and those of our suppliers. These standards reinforce and strengthen our commitment to the rights of our associates, workers in our supply chain, and workers in the global community.

M. Anti-Corruption, Anti-Bribery and Free Competition. Corruption or attempted acts of corruption of any kind are prohibited. This includes, but is not limited to, bribery, kickbacks, illegal gratuities, and money laundering. Inolex supports fair competition. Therefore, team members and Inolex partners must comply with all anti-trust and free competition legislation. Inolex members must not collude or enter into any anti-competitive agreements with competitors, suppliers, or customers to obtain an unfair advantage in the marketplace. Gift offerings, including entertainment, must not be of significant value, defined as under $100 or as otherwise limited by local laws, and Inolex employees must not accept anything that could compromise or appear to compromise a business decision or arrangement with external partners, suppliers, or vendors.

N. Whistleblower Protections. Inolex is committed to complying with public policy and as a United States Federal Government subcontractor, abides by the United States Government’s guidelines and regulations regarding Whistleblower Protections. Please refer to Inolex’s Whistleblower Policy below.

Conflict of Interest Policy

Inolex expects its employees to conduct business according to the highest ethical standards. Employees are expected to make their best efforts in the interest of Inolex. A conflict of interest is defined as a situation whereby an employee has a personal business interest in an enterprise separate from Inolex, and where that business interest could compromise the employee’s loyalty to Inolex or whenever an employee is in a position to influence a decision that may result in a personal gain for the employee or an immediate family member (i.e. spouse or significant other, children, parents, siblings) as a result of Inolex’s business dealings. Business dealings that appear to create a business or personal conflict between the interests of Inolex and an employee or any other entity are unacceptable. An employee must disclose any potential, actual, or perceived conflicts of interest to Inolex so that Inolex may assess and prevent potential conflicts of interest from arising or continuing.

Employees should refrain from conflicts of interest that could adversely influence their judgment, objectivity, or loyalty to the company in conducting business activities and assignments. Inolex recognizes that employees may take part in legitimate financial, business, and other activities outside of their employment with Inolex, but any potential conflict of interest raised by those activities must be promptly disclosed, in writing, to management and/or the Human Resources Department. Employees are expected to request approval prior to engaging in outside activities, financial interests, or relationships that may pose a potential, actual, or perceived conflict of interest.

If an employee has any questions about whether an action or proposed course of conduct would create a conflict of interest, the employee should immediately contact the Human Resources Department to obtain advice on the issue. An actual or potential conflict of interest will not be permitted to continue/proceed unless an affirmative determination has been made that the relationship will not interfere with the employee’s duties and will not otherwise interfere with Inolex business and/or relationships.

Potential, actual or perceived conflicts of interest include, but are not limited to:

A. Having a direct or indirect financial interest in, or a financial relationship with, an Inolex competitor, supplier, or customer (except for insignificant stock interests in publicly-held companies).

B. Having a second job where your other employer is a direct or indirect competitor, distributor, supplier, or customer of Inolex.

C. Having a second job or consulting relationship that affects your ability to satisfactorily perform your assignments for Inolex.

D. Having a second job or consulting relationship that causes you to disclose or utilize any Confidential Information (defined below) belonging to Inolex.

E. Disclosing to Inolex or using for the benefit of Inolex any confidential information belonging to a third-party that has not authorized the use of such information.

F. Investing in an outside business opportunity in which Inolex has an interest, except for having an insignificant stock interest in publicly-held companies.

ESG / Sustainability Oversight

Organization Structure

The Chief Executive Officer, President, and members of the Senior Leadership Team are responsible for the direction and oversight of economic, environmental, and social topics. The Senior Leadership Team reports directly to the CEO and/or President with managers and directors working directly under the CFO or each Vice President. A corporate sustainability manager reports to the Vice President of Marketing and works cross-functionally to provide direction, manage day-to-day activities, and oversee corporate communications and reporting on ESG / sustainability topics. Any concerns should be escalated to the Vice President of Marketing, the Human Resources Department, or the Chief Financial Officer.