Supplier Code of Conduct for Momentum Shipping Company LLC ("Moshipco")

Purpose of the Supplier Code of Conduct

The Supplier Code of Conduct outlines Moshipco’s expectations of its Suppliers and provides guidelines regarding responsible sourcing, including our commitments to human rights, the environment, health and safety, business ethics, and the development of a diverse and sustainable supply chain. All Suppliers and business partners must comply with our Supplier Code of Conduct. "Suppliers" refers to any third party that provides goods or services to Moshipco for compensation. Sub-contractors of Suppliers are also expected to comply with this Code. For the purposes of this document, a Supplier includes suppliers, vendors, distributors, fulfillment partners, channel partners, agents, contractors, and all other third parties and affiliates of Moshipco with whom Moshipco engages to provide the company any business goods, services, functions, or activities.

All Suppliers must communicate these expectations throughout their supply chain and comply with all applicable national, state, and local laws/regulations in the markets where they operate. However, where local laws or standards differ from this Supplier Code of Conduct, we expect our Suppliers to comply with the more stringent standards and principles.

In the spirit of continuous improvement, Moshipco is committed to working with and supporting our Suppliers to meet and exceed the requirements outlined in this Supplier Code of Conduct.

Introduction to Sustainable Procurement at Moshipco

The principles of sustainable procurement are integral to our business strategy, focusing on:

Value creation
Sustainable environmental performance
Corporate social responsibility (CSR)

Within Moshipco, we are committed to five core values: Be Mission Driven, Be a Creative Problem Solver, Be Humble, Be Safety Minded, and Be Resilient. These values underpin our approach to sustainable development.

Our approach to sustainable procurement includes how we work with our Suppliers; we integrate sustainable development into our procurement strategy, day-to-day operations, and relationships with Suppliers.

All Moshipco entities and its partners are required to identify, prevent, and manage risks pertaining to health and safety, social responsibility, and the environment in their supply chain, and we expect the same from our Suppliers.

Our Commitment to Suppliers

Moshipco seeks to engage Suppliers that are socially responsible, behave with integrity, and focus on sustainable development. Our goal is to partner with Suppliers to deliver value-for-cost procurement for Moshipco and our clients who will demonstrate the same principles to their Suppliers.

Moshipco has established methodologies to implement strategic procurement strategies and to guide relationships with Suppliers. These guidelines ensure a fair, competitive, and transparent negotiation process, according to our policies and values.

We act with integrity and demonstrate good citizenship in our business dealings – we expect the highest standards of conduct from our own people.

Our Expectations of Suppliers

Moshipco expects our Suppliers to meet high social, environmental, and health and safety standards. Suppliers must adhere to the following standards:

Business Integrity and Standards

Laws, Regulations, and Trade Control

We expect our Suppliers to comply with applicable laws, regulations, and industry standards. Our Suppliers must comply with trade sanctions and similar restrictions issued by recognized authorities, including the United Nations, the European Union, and the United States.

Competition and Antitrust Laws

Suppliers must comply with competition and antitrust laws in the countries where they operate or sell products. Suppliers must not coordinate market conduct with competitors or their own Suppliers in a way that improperly restricts competition.

Bribery and Corruption

Suppliers shall comply with all applicable anti-corruption laws and regulations and maintain a zero-tolerance policy towards any form of bribery, corruption, extortion, and embezzlement. Suppliers shall not pay bribes or make any other inducements (including kickbacks, facilitating payments, excessive gifts, and hospitality, grants, or donations) in relation to their business dealings with customers and public officials. Suppliers are expected to perform all business dealings transparently, and these dealings shall be accurately reflected in their business books and records.

As a minimum, we expect our Suppliers to:

Comply with the Foreign Corrupt Practices Act of 1977, the UK Bribery Act 2010, and locally applicable laws and regulations.
Never offer or accept anything of value where there is an intention of improperly influencing a business decision, or where the person may not be permitted by their employer or local law to receive it.
Disclose to Moshipco where they or their associates may have connections with government officials and never bribe government officials of any kind.

Conflicts of Interest

Our Suppliers should not cause any conflicts of interest for Moshipco employees and should avoid situations where a conflict of interest may occur. We expect Suppliers to disclose in full any potential conflicts of interest they may have as soon as they are identified, so that they can be properly considered, and the right action taken.

Gifts and Entertainment

We expect our Suppliers to respect that Moshipco employees must not provide or accept excessive or inappropriate entertainment and may only offer or accept non-cash gifts of modest value occasionally. Gifts and entertainment should never create a feeling of obligation or the impression of an obligation because this could be perceived as a bribe. We expect Suppliers to ensure they have appropriate controls in place so that gifts, sponsorship, or entertainment are not bribes or perceived as such, especially if the recipient is a government official.

Business Records and Confidential Information

We expect Suppliers to keep accurate and up-to-date records of matters related to their business with Moshipco, and to demonstrate compliance with applicable laws and regulations. We expect our Suppliers to ensure appropriate technical and organizational security measures to safeguard Moshipco’s confidential and personal information and to meet the requirements of applicable data privacy laws and regulations to ensure there is no disclosure of our confidential information to third parties without our prior authorization. We also expect our Suppliers to inform Moshipco immediately in the event of a potential or actual data breach, or if our information is released without authorization.

Human Rights and Labor Standards

We want to make a positive contribution to human rights and society. We are committed to promoting and respecting human rights throughout our supply chain and expect the same from our Suppliers. We expect our Suppliers to act in accordance with these principles and commitments, and we have minimum standards in the following areas:

Child Labor

Suppliers shall not use child labor. The term ‘child’ means any person employed under the age of 15 (or 14 where the law of the country permits) or under the local legal minimum working age, whichever is greater. Suppliers employing young workers (above the minimum age of employment but under the age of 18) must comply with applicable laws and regulations regarding hours, compensation, and must avoid conditions or restrictions that could be harmful to their morals, health, safety, and development. Suppliers may use legitimate workplace apprenticeship programs for the educational benefit of younger people.

Forced Labor

Suppliers shall not use or benefit from any form of human trafficking, or forced, compulsory, bonded, indentured, or prison labor in its operations under any circumstances. Suppliers must ensure that every employee is a voluntary worker with the freedom to leave the workplace outside of work hours and terminate employment at any time without penalty after notice of reasonable length. No employee shall be subject to any form of harsh or inhumane treatment, corporal punishment, threats of physical or sexual violence, or other forms of psychological or physical harassment, intimidation, abuse, coercion, or sanctions that result in wage deductions, reductions in benefits, or compulsory labor. No part of an employee’s salary, benefits, property, or documents shall be withheld to force such personnel to continue working.

Non-discrimination

Suppliers must make employment-related decisions based on relevant and objective criteria and not on personal characteristics such as age, race, religion, color, ethnicity, national origin, disability, sexual orientation, gender, gender identity or expression, marital status, or any other characteristic protected by local law. Employment-related decisions include, but are not limited to, hiring, promotion, lay-off and relocation of workers, training, and skills development, health and safety, and any policy related to working conditions like working hours and remuneration.

Wages and Benefits

Suppliers shall ensure employees are paid a fair wage according to at least the legal minimum standards or appropriate industry standards, whichever is higher.

Abuse and Harassment of Labor

Suppliers must strictly prohibit any kind of harassment, intimidation, bullying, or abuse of any employee, including through the threat of physical punishment or disciplinary action, or physically, sexually, racially, psychologically, or verbally.

Working Hours

We expect our Suppliers to ensure employees do not work excessive hours, in accordance with national laws, collective agreements, and the provisions of the relevant local standards on working time.

Health and Safety Standards

Moshipco is committed to maintaining safe and secure working conditions for employees and contract workers. We expect our Suppliers to have the same approach. For our Suppliers, we have minimum standards in the following areas:

Laws and Regulations

Suppliers shall meet applicable local and national health and safety laws and regulations, including those related to the construction and maintenance of facilities for employees and contract workers.

Health and Safety Policy

Suppliers shall have a clear, publicly-available health and safety policy statement in place, be committed to developing and applying appropriate health and safety management systems (including clear assignment of management responsibility for health and safety), and monitor and report corrective actions against incidents (accidents, near misses, etc.).

Safe Working Environment

Suppliers will maintain a safe, healthy, clean, and well-lit work environment including appropriate and adequate facilities and protection from hazardous materials or conditions. We expect our Suppliers to maintain the same standards in their fulfillment centers. If housing is provided for employees, all housing must be maintained in a clean, safe fashion. Moshipco strictly forbids the use of cruel and unusual disciplinary practices in the workplace.

Risk Assessment

We expect our Suppliers to conduct routine risk assessments, reflecting existing and emerging issues and good practice; to understand health

and safety issues both generally and specifically for their sector; and to take appropriate action to mitigate identified risks.

Continuous Improvement

We expect Suppliers to progressively improve health and safety standards to prevent accidents and injuries. Similarly, we encourage the adoption of health and safety management systems that can be externally verified and certified.

Data Security, Confidentiality, and Accuracy

Suppliers will handle and process data only for the purposes for which it was collected or otherwise made available. Suppliers shall demonstrate appropriate industry-standard and best practices data security controls to ensure that all information is protected and secure from damage and unauthorized use. In addition to the above minimum requirements, Suppliers shall also follow any data security policies and requirements specified in contractual agreements with Moshipco. Suppliers must respect and maintain the confidentiality of all non-public information about Moshipco or its activities and all non-public information obtained in the performance of the Supplier’s duties about Moshipco’s customers, clients, or applicable third parties. Subject to any contractual requirements, Suppliers will notify Moshipco without undue delay of any known or suspected data security breaches and will work with Moshipco and, if applicable, law enforcement to contain the breach and determine a root cause.

Supplier Diversity, Equity, and Inclusion

Moshipco is committed to dealing with all Suppliers with integrity and in an ethical manner and to supporting and encouraging the aspirations of diverse groups. Moshipco’s Supplier Diversity Program is an expression of that commitment. Moshipco’s policy is to provide opportunities for diverse Supplier groups. The Supplier Diversity Program seeks to expand the number of firms, including, but not limited to, minority and women-owned businesses that can furnish the services and commodities we need for our business. As defined by the United States Federal Government, a minority Supplier is a business enterprise that is 51% or more owned and controlled by minority group members, including, but not limited to:

An ethnic or racial minority group (e.g., Asian, African American, Hispanic)
LGBTQ community
Women (of any race or ethnicity)
Veterans or Service-Disabled Veterans
Persons with Disabilities
A small business, as indicated by the local country’s definition

Specifically, Moshipco’s program calls for:

Identifying qualified diverse business enterprises that are financially stable and capable of supplying products/services that can meet Moshipco’s specifications, service requirements, and competitive pricing levels.
Utilizing qualified minority and women-owned firms as regular Suppliers of Moshipco that offer the most competitive bids in areas of price, quality, service, and financial stability.

Environmental Impact

Moshipco is committed to making our brands and business more sustainable by significantly reducing our environmental impact along our entire supply chain and by considering the environmental implications of every major business decision that we make. We also work with our business partners, suppliers, contractors, customers, and consumers to reduce impacts along the whole supply chain.

For our Suppliers, we have minimum standards in the following areas:

Environmental Policy and Regulations

Our Suppliers shall have a clear and publicly available environmental policy statement that addresses the key impacts from their operations and commits to improvement. Suppliers will manage their environmental impact responsibly in line with applicable laws and regulations.

Reduce Environmental Impacts

Suppliers shall continually strive to reduce their environmental impacts and manage their natural resources efficiently. This includes implementing measures to prevent pollution, minimize the use of energy and production of waste, and manage water responsibly.

Demonstrating Compliance

Moshipco is entitled to request information from our Suppliers to confirm their compliance with these standards and, where we consider it necessary, may require a supplier to provide evidence of compliance through a third-party audit. We reserve the right to undertake unannounced audits where we determine it is necessary.

Raising a Concern

We believe knowing about potential breaches early means we can deal with them quickly and appropriately. We take every report seriously and we will not tolerate any reprisal by a Moshipco employee against a Supplier who has reported a concern in good faith or assisted us with an investigation.

We expect our Suppliers to raise any concerns about our business conduct or a potential breach of this Supplier Code or our Moshipco Code of Conduct directly with their contact in Moshipco.