1. INTRODUCTION

Neshuns Corporation Inc (“Neshuns” “Company” “We” or “Our”) is committed to the highest standards of integrity and fairness, and Neshuns expects all Suppliers engaged in providing products and services to Neshuns to have, or to make a similar commitment. The Neshuns Supplier Code of Conduct (“Code”) describes Neshuns' expectations for how its Suppliers conduct business. Neshuns requires Suppliers to act per the Code and with all applicable laws and regulations within the geographies in which they operate and to be open and cooperative with regulators that enforce such laws.

2. SCOPE OF THIS CODE

This Code requires all bidders, suppliers, agents, intermediaries, consultants, and contractors, including all their affiliates, officers, employees, subcontractors, agents, and intermediaries (collectively “Supplier Partners”) to observe the highest standard of ethics in all activities regarding the supply of goods and/or services to Neshuns. The Company’s officers, employees, contractors, agents, consultants, contractors, representatives, partners, and Board Directors (collectively “Personnel”) must ensure that this Code is communicated to and complied with by all of the Company Supplier Partners. Supplier Partners must in turn impose substantially similar obligations to those set forth herein on their suppliers, subcontractors, and agents.

3. OUR GUIDING PRINCIPLES

Neshuns’ seven Guiding Principles apply to all our employees; they provide the foundation for our operations globally. Our Supplier Code of Conduct enlists our Supplier Partners in upholding these same principles. We believe this joint commitment to ethical conduct and integrity is a strong foundation for trusted business relationships that create shared value. This Supplier Code of Conduct is incorporated, by reference, into all supplier contracts.

3.1. Obey the law

As a responsible company, we expect our Supplier Partners to share our commitment to following the law.

We expect our Supplier Partners to:

• Know and follow the laws that apply to them and their business.
• Treat legal requirements as a minimum standard.
• Alert the Company to any material issues with the goods and services they supply. This helps the Company to comply with global regulations.
• Ensure that the Company resources received by them are not used to support, finance, or promote violence, aid terrorists or terrorist-related activity or fund organizations known to support terrorism.
• Never engage in money-laundering activities. This includes any kind of activity which hides or is intended to hide the fact that funds have been obtained illegally or relate to the proceeds of crime, e.g. through fraud bribery or other illegal activity.

3.2. Conduct business with integrity

We seek business relationships based on trust, transparency, and mutual accountability.

We expect our Supplier Partners to:

• Compete fairly and ethically for the Company’s business.
• Never offer or accept bribes, kickbacks, inappropriate gifts or hospitality, or other improper incentives in connection with the Company’s business.
• Disclose, before entering into a contract or at any time during the performance of the contract, whether they or any of their representatives are subject to any sanction or temporary suspension imposed by any relevant authority.
• Disclose actual, perceived, or potential conflicts of interest involving the Supplier or any of their representative (“Conflict of Interest”). The Company considers a Conflict of Interest to be a situation in which a party has interests that could improperly influence that party's performance of official duties or responsibilities, contractual obligations, or compliance with applicable laws and regulations, and that such Conflict of Interest may contribute to or constitute a prohibited practice under this Code or has compromised, or risks compromising the integrity of any procurement process of the Company.
• Avoid any conflict of interest relating to financial interests or other arrangements with our employees that may be considered inappropriate.
• Avoid applying undue influence on the decision-making processes of the Company and not engage in any conduct that breaches or facilitates the breach of this Code.
• Notify the Company as soon as they know of any integrity concern involving or affecting the Company, whether or not it involves them.
• Work with their suppliers to promote business conduct consistent with the principles in this Code and compliance with applicable laws.

3.3. Keep accurate and honest records

We expect our Supplier Partners to maintain accurate and honest records. This helps us make responsible business decisions and disclose truthful and timely information to our stakeholders.

We expect our Supplier Partners to:

• Maintain accurate and complete records in appropriate books of account that reflect all financial and business transactions under the Company’s contracts in an accurate, honest, and timely way.
• Employ appropriate quality audit and compliance processes for the products and services they supply to the Company.
• Disclose, on request, the location of facilities and known origins of products and services they supply to the Company to enable traceability.
• Cooperate with the Company and comply with any reasonable request, in the opinion of the Company, to allow access to relevant staff and to inspect any relevant accounts and records and other documents relating to bidding for and performing the Company’s contracts.
• Always provide any assistance requested by the Company to enable the Company to comply with any legal, regulatory, or statutory requirement applying to it.
• Take timely and appropriate action in situations where the Supplier Partner becomes aware that any of its representatives has engaged or is suspected of engaging in corrupt, fraudulent, collusive, anti-competitive or coercive practices in connection with the procurement or performance of a Company contract.

3.4. Honor business obligations

We work with Supplier Partners who share our desire to build productive business relationships. This requires honest communication, mutual respect, and delivering on commitments.

We expect our Supplier Partners to:

• Share our commitment to conducting business honestly and transparently.
• Honor business obligations and manage unanticipated events in a proactive, timely, and open way.

3.5. Treat people with dignity and respect

We expect our Supplier Partners to uphold the principles and due diligence obligations outlined in The United Nations Global Compact for Responsible Corporate Citizenship (“UN Global Compact”) and to prioritize the safety, well-being, human rights, and dignity of all individuals whose talents and hard work help us deliver our products and services.

We expect our Supplier Partners to:

• Conduct their business activities in a manner that protects the health and safety of those whose lives they touch.
• Respect the right of workers to form or join a legally recognized labour organization, if they choose, without fear of reprisal, intimidation, or harassment.
• Treat all workers with dignity and respect and provide an emotionally and psychologically safe and inclusive working environment.
• Provide competitive, fair, and equitable pay.
• Comply with applicable working hours laws, including overtime hours.
• Act to eliminate any form of forced labour – and work to eradicate child labour – from their operations and supply chains.
• Respect land resources and tenure rights for everyone, especially for indigenous people, local communities, and ethnic or minority groups.
• Act against corruption in all its forms, including extortion and bribery.

3.6. Protect the Company’s information, assets, and interests

We expect our Supplier Partners to protect the Company’s reputation and any information or property we entrust to them.

We expect our Supplier Partners to:

• Protect any of the Company’s or its clients' confidential information to which they have access, including its intellectual property, trade secrets, or financial information.
• Protect any personal information to which they have access, in compliance with all applicable laws and regulations. Personal information provided by or on behalf of the Company must only be used, accessed, and disclosed as permitted by the Supplier agreement and in compliance with all applicable laws and regulations.
• Safeguard any property belonging to the Company or its clients while under their control.
• Information, data, know-how and documents obtained from participating in the Company’s procurement processes, or in the course of performing a Company contract, must under no circumstances be made available to any third parties to give existing or potential Supplier Partners a preferential position or advantage concerning tenders or any other procurement processes of the Company, without the prior written consent of the Company.
• Never, without the Company’s prior written consent, (i) use the Company’s name or logo in publicity or advertising; (ii) use their direct or indirect business relationship with the Company to imply an endorsement by the Company of their goods and services, and (iii) make any representation or statement for or on behalf of the Company.
• Avoid any situations that may adversely affect our business interests or reputation and maintain strict ethical standards in their dealings.

3.7. Be a responsible global citizen

We count on our Supplier Partners to help Us meet our strategic sustainability commitments.

We expect our Supplier Partners to:

• Commit to addressing and mitigating the impacts of their business on climate, land, water, soil, air, and biodiversity.
• Take guidance from international standards, conventions, and declarations, including the United Nations Guiding Principles on Business and Human Rights (UNGPs), the International Bill of Human Rights, the International Labor Organization Fundamental Principles and Rights at Work, and the OECD Guidelines for Multinational Enterprises.
• Provide their stakeholders access to grievance mechanisms for raising concerns confidentially without fear of retaliation.
• Upon request, provide evidence of their compliance with the requirements of our Supplier Code of Conduct.

4. COMPLIANCE WITH THIS SUPPLIER CODE OF CONDUCT:

4.1 Investigations and Corrective Actions

It is our goal to build trust-based relationships with ethical suppliers and business partners who comply with this Code. In furtherance of this goal, we take a risk-based approach to training our Supplier Partners and requiring evidence of compliance with the requirements of this Code. We expect our Supplier Partners to fully cooperate with our reasonable requests for data, information, certifications, and audit access to verify compliance, and to obtain assurances that their suppliers and partners uphold these principles.

When there is a concern, or we become aware of facts that indicate a Supplier Partner has breached this Code, our practice is to investigate these incidents and work with the Supplier Partner to develop an action plan to address the concern. However, during an investigation, we reserve the right to suspend all contractual and business operations with the Supplier Partner. If we determine that an issue cannot be corrected, or a Supplier Partner is unwilling to engage or reasonably cooperate, we further reserve the right to terminate our agreement(s) with that Supplier Partner.

This Code sets forth the minimum requirements that must be met to be a Neshuns Supplier Partner. We encourage our Supplier Partners to have due diligence and management systems in place to maintain these minimum requirements. By working closely with our Supplier Partners, we believe we can achieve mutual success while helping communities and the wider world thrive.

4.2 Reporting Violations

Supplier Partners are required to promptly report to the Company any legal violations or violations of this Code or other Company policy.

Suppliers must promptly forward to the Company if permitted by law, any subpoenas, regulatory requests, media inquiries, or other third-party requests concerning the Company.

The Got a Concern? webpage available on the Company’s website enables both the Company colleagues and external parties to confidentially raise concerns about potential misconduct or violations of laws, policies, values, or professional conduct. Details of this confidential process are available on the Got a Concern? webpage.