Standards of the Supplier Code of Conduct

Health and Safety

Safety is our first priority.  Suppliers must share Mesco’s commitment to providing a safe and healthy workplace by exercising good judgment in work decisions and applying safe work practices (including regulatory and contract-specific requirements) to all activities. Suppliers must ensure that employees working on Mesco property adhere too general and site-specific safety requirements, including prohibitions on the use and possession of illegal drugs and alcohol, restrictions on the possession of weapons, and support for a violence-free environment.

Environmental Protection and Sustainability

Mesco aspires to be an industry leader in protecting our environment. We are committed to meeting or surpassing all applicable regulatory requirements and enhancing the communities we serve. We actively seek suppliers who share our commitment to protecting the environment.  Suppliers must abide by the letter and the spirit of all federal, state, and local environmental laws, as well as applicable Mesco policies and procedures.

Legal and Regulatory Compliance

Suppliers must comply with the letter and spirit of applicable legal requirements including those prohibiting bribery, kickbacks, corruption, and other unethical business practices intended for the purpose of obtaining an improper advantage. Suppliers must comply with antitrust and fair trade practices laws including the Foreign Corrupt Practices Act.  Federal and state commissions have specific codes and standards of conduct that address discrimination and preferential treatment between companies and their affiliates. Mesco and its suppliers must ensure compliance with these codes and standards.

Business Gifts and Courtesies

Whenever a gift or entertainment is offered in the context of a business relationship, there is a risk that it may influence, or appear to influence, a business decision. Exchanging modest gifts and courtesies may be acceptable under certain conditions; however, it is never required for doing business with Mesco. Suppliers must never offer or provide personal incentives or rewards to Mesco employees in an effort to influence a business decision such as a procurement award. Providing cash or a cash equivalent of any kind to a Mesco employee is strictly prohibited.

Conflict of Interest

A conflict of interest exists when a supplier faces a choice between what is in its best interests (financial or otherwise) and what is in the interest of Mesco. A conflict may arise if a supplier:

• Employs a Mesco employee or someone with a close personal relationship with a Mesco employee

• Is partially or fully owned or controlled by a Mesco employee or family member

• Has access to Mesco’s proprietary information while providing goods and services to Mesco’s competitors

• Is involved in developing a Request for Proposal (RFP) and seeks to bid on the work covered by the RFP

Suppliers must promptly disclose any potential conflict of interest to Mesco for review prior to entering into any business transaction. If a potential conflict arises during the business relationship, it must be disclosed promptly after it becomes known.

Child and Forced Labor

• All work must be voluntary and workers shall have the freedom to terminate their employment at any time without penalty, given notice of reasonable length. Workers shall not be subject to any form of slavery or practices similar to slavery, such as the sale and trafficking of children or adults, debt bondage and serfdom, and forced or compulsory labor. Please review Mesco’s Child Labor Policy on the company website https://mescomfg.com

Migrant Worker Contract of Employment

Written contracts of employment shall be provided to migrant workers in a language they understand, clearly indicating their rights and responsibilities with regard to wages, working hours, and other working and employment conditions. Migrant workers shall be provided with their employment contract prior to deployment. The use of supplemental agreements and the practice of contract substitution (the replacement of an original contract or any of its provisions with those that are less favorable) are strictly prohibited.

Business Records

Accurate, reliable information and records are critical to meeting Mesco’s financial, legal, and management obligations. Suppliers must comply with generally accepted accounting principles including a system of internal controls to promptly, completely, and accurately prepare required reports, vouchers, reimbursement requests, and invoices. Suppliers must follow all applicable laws and contractual requirements in creating, maintaining, and disposing of records reflecting their business dealings with Mesco.

Fair Treatment

Suppliers must conduct their operations in a socially responsible and nondiscriminatory manner. Suppliers must ensure that their workers who represent Mesco, are assigned to Mesco facilities and interact with Mesco employees do not engage in behavior that intimidates or harasses others. All Mesco suppliers must comply with the letter and spirit of the applicable

U.S. and international labor and employment laws including those associated with equal opportunity, immigration, child labor, forced or compulsory labor, working hours, wages and benefits, freedom of association and a harassment-free work environment.

Company Resources

Suppliers must use Mesco resources responsibly and only for legitimate business purposes. Mesco resources include company facilities, equipment, systems, technology assets, information, and office and field supplies. Suppliers cannot use Mesco’s name or logo, trademarks, or other intellectual property without the express written consent of the company.

The intellectual property rights of third parties will always be honored. Suppliers and their employees also are prohibited from using Mesco resources or facilities to solicit or distribute information or materials not connected with regular Mesco work.

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Any information provided to suppliers by Mesco, including employee and customer information, must be managed in compliance with Mesco’s policies and requirements, particularly privacy and IT security requirements, as well as applicable laws and regulations.  Confidential information can only be shared within your company on a need-to-know basis. Suppliers cannot share Mesco’s confidential information with third parties without express written permission.

Supplier Selection and Diversity

Mesco is committed to fair and ethical dealings in bid evaluation, negotiation, award decisions, and the administration of purchasing and sourcing activities. The company recognizes that a strong, diverse supplier community is essential to economic vitality and proactively seeks opportunities to conduct business with competitive, diverse suppliers. We expect our business partners to seek, use, and develop diverse suppliers while performing work on our behalf.

Compliance with this code is mandatory for suppliers, their subcontractors, and all non-employee workers providing services for or on behalf of Mesco.

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We reserve the right to conduct investigations and audits, including supplier site visits, to verify that a supplier’s business operations meet the expectations outlined in this code. Suppliers and their employees must cooperate in the event of an audit or investigation. Deficiencies may result in a request to remove a worker from a Mesco site, a remediation plan, or termination of the business relationship.

Reporting Concerns

Suppliers, their employees, or their subcontractors must report actual or suspected noncompliance with this code by Mesco employees or suppliers. Reports may be made by:

• Notifying your Mesco representative

• Sending a letter to Mesco Manufacturing, 900 Randall Street, Greensburg, IN 47240

• Sending an email to Mesco’s Ethics Office at ethicsofficer@mescomfg.com

• Mesco’s Whistleblower reporting at http://mescomfg.com/whistleblower.html

• We encourage open discussion regarding any questions or concerns about this code or in our business relationship. Suppliers may direct any questions or concerns to the contacts listed above.