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Supplier Code of Conduct

Since 1928, Michael Lewis Company (MLCo) has been focused on operating a responsible, progressive, and sustainable business for our employees, customers, community, and environment. This Code establishes the ethical, social, and environmental standards MLCo expects of all vendors, suppliers, contractors, and service providers ("Suppliers").

Partner Code Recognition

For suppliers who are contracted directly through a customer of MLCo, MLCo defaults to that partner Code of Conduct as the governing standard for the relevant requirements of this code. MLCo will not require duplicative compliance where a recognized agreement already exists.

The following requirements are of particular importance:

  1. Legal Compliance

Suppliers must comply with all applicable laws in every jurisdiction where they operate, including:

  • Anti-Corruption & Bribery: Full compliance with the U.S. Foreign Corrupt Practices Act (FCPA), U.K. Bribery Act, and local equivalents. No bribes or improper payments to any party.
  • Antitrust: No price-fixing, market allocation, or bid-rigging with competitors.
  1. Labor & Human Rights

Suppliers must uphold the rights and dignity of all workers and:

  • Ensure no use of child, forced, or trafficked labor. Workers must be free to resign.
  • Comply with legal limits on minimum wage and maximum working hours.
  • Maintain a workplace free from discrimination, harassment, and violence based on race, gender, religion, national origin, disability, or any other protected characteristic.
  • Respect workers’ rights to organize and bargain collectively.
  1. Health & Safety

Suppliers must foster a safe work environment and:

  • Comply with all occupational health and safety laws and regulations.
  • Identify and mitigate workplace hazards; provide appropriate PPE at no cost to workers.
  • Maintain emergency preparedness plans and ensure workers are trained.
  • Prohibit workplace violence, threats, weapons, and drug or alcohol use on premises.
  1. Environmental Responsibility

As part of MLCo’s commitment to environmental responsibility, we expect our partners to meet applicable environmental laws as a baseline and pursue continuous improvement:

  • Comply with all environmental laws and regulations.
  • Manage waste responsibly and prioritize recycling.
  • Reduce pollution and greenhouse gas emissions wherever feasible.
  • Use natural resources efficiently and minimize the use of hazardous materials.
  1. Ethics & Business Integrity

Suppliers must conduct all business handlings with integrity related to the following:

  • Conflicts of Interest: Disclose any actual or potential conflicts involving MLCo personnel.
  • Gifts & Entertainment: No gifts or hospitality intended to influence MLCo decisions.
  • Money Laundering & Fraud: Zero tolerance for engaging in or facilitating money laundering, fraud, or any related financial misconduct.
  • Data Privacy: Maintain appropriate safeguards for all confidential and personal data shared by or on behalf of MLCo.
  • Inside Information: Material non-public MLCo information must be kept confidential.

Acknowledgement & Signature

Suppliers must confirm they have read, understood and agreed to comply with this Supplier Code of Conduct by signing the New Vendor Form.