Supplier Code of Conduct

Hydrite Chemical Co.

October 6, 2026

Purpose and Scope

Hydrite Chemical Co. (“Hydrite”) is committed to conducting business responsibly, ethically, and in a manner that supports the success of our customers, employees, partners, and communities. This Supplier Code of Conduct (the “Code”) establishes the minimum standards expected of every individual or entity that provides goods or services to Hydrite, including its employees, agents, subcontractors, and other representatives (collectively, “Suppliers”).

Suppliers must comply with this Code and all applicable laws, regulations, permits, and binding legal requirements in each jurisdiction where they operate (“Applicable Law”). When this Code establishes a higher standard than Applicable Law, Suppliers are expected to follow this Code to the extent legally permitted. If this Code conflicts with a written agreement between Hydrite and a Supplier, the written agreement will control as to that conflict.

Suppliers are expected to communicate these requirements to personnel and subcontractors supporting Hydrite and to maintain policies and controls appropriate to the nature and risk of their operations.

1. Legal Compliance and Business Integrity

Suppliers must conduct business lawfully, fairly, honestly, and with integrity. Suppliers must not engage in fraud, misrepresentation, theft, embezzlement, money laundering, or other improper conduct.

Anti-Bribery and Corruption. Suppliers must comply with applicable anti-bribery and anti-corruption laws, including the U.S. Foreign Corrupt Practices Act, and must not offer, promise, authorize, request, or accept bribes, kickbacks, facilitation payments, or anything of value intended to improperly influence a business or governmental decision.

Fair Competition. Suppliers must comply with applicable antitrust and competition laws and must not participate in price fixing, bid rigging, market allocation, improper information sharing, or other anticompetitive conduct.

Conflicts of Interest. Suppliers must avoid actual or apparent conflicts of interest and promptly disclose to Hydrite any circumstance that could improperly influence, or appear to influence, decisions relating to Hydrite.

2. Trade Compliance and Responsible Sourcing

Suppliers must comply with applicable import, export control, customs, antiboycott, and economic sanctions laws. Suppliers must not knowingly provide Hydrite with goods, services, software, technology, or materials sourced from prohibited persons, entities, countries, or regions.

Suppliers should exercise risk-based due diligence over their supply chains and take reasonable steps to identify and address risks involving unlawful sourcing, human-rights abuses, environmental harm, counterfeit materials, and conflict minerals where applicable.

3. Quality, Product Safety, and Regulatory Compliance

Suppliers must provide goods and services that conform to agreed specifications, quality requirements, safety standards, and Applicable Law. Suppliers must maintain appropriate quality controls and complete and accurate records supporting product identity, traceability, testing, composition, and compliance.

Suppliers must promptly notify Hydrite of any actual or suspected quality, safety, regulatory, counterfeit, contamination, adulteration, or nonconformance issue that could affect goods or services provided to Hydrite, and must cooperate with reasonable containment, investigation, corrective-action, and recall efforts.

4. Human Rights and Labor Practices

Suppliers must respect internationally recognized human rights and comply with applicable labor, wage, hour, immigration, and employment laws, including applicable laws addressing transparency in supply chains and modern slavery.

Suppliers must:

Prohibit forced, bonded, indentured, involuntary prison, trafficked, or child labor;
Ensure employment is voluntary and workers may leave employment in accordance with applicable notice requirements;
Provide lawful wages, benefits, working hours, rest periods, and overtime compensation;
Maintain a workplace free from unlawful discrimination, harassment, retaliation, abuse, and inhumane treatment;
Respect lawful rights of workers to associate, organize, and bargain collectively, or to refrain from doing so; and
Use responsible recruitment practices and not require workers to pay improper recruitment fees or surrender identity or travel documents.

5. Health and Safety

Suppliers must provide a safe and healthy workplace and comply with applicable occupational health and safety requirements. Suppliers must identify and control workplace hazards, provide appropriate training and personal protective equipment, prepare for emergencies, investigate incidents, and take corrective action to prevent recurrence.

Suppliers performing work at a Hydrite location must comply with Hydrite site-access, security, environmental, health, and safety requirements.

6. Environmental Stewardship and Sustainability

Suppliers must comply with applicable environmental laws, permits, reporting requirements, and restrictions governing air emissions, wastewater, waste, hazardous materials, chemicals, and transportation.

Suppliers are expected to use natural resources responsibly; prevent pollution; reduce waste, emissions, and unnecessary energy and water consumption where practicable; and pursue continuous improvement appropriate to their operations. Suppliers should provide reasonable support for Hydrite’s sustainability and responsible-sourcing initiatives, including accurate information reasonably requested about materials, operations, and environmental impacts.

7. Confidentiality, Intellectual Property, Data Privacy, and Cybersecurity

Suppliers must protect Hydrite’s confidential information, personal data, systems, and intellectual property and use them only for authorized purposes and Hydrite’s benefit. Suppliers must comply with applicable privacy and data-protection laws and any contractual information-security requirements.

Suppliers must maintain reasonable administrative, technical, and physical safeguards appropriate to the sensitivity of the information and the nature of the services provided. Suppliers must promptly notify Hydrite of any actual or suspected unauthorized access, use, disclosure, loss, alteration, or destruction involving Hydrite information, data, or systems and cooperate with Hydrite’s response and remediation efforts.

8. Gifts, Entertainment, and Business Courtesies

Suppliers must not offer or provide gifts, entertainment, travel, meals, employment opportunities, or other business courtesies to Hydrite personnel if doing so would violate Applicable Law, create or appear to create an obligation, improperly influence a decision, or exceed nominal and customary value. Cash and cash equivalents are prohibited.

9. Accurate Records and Cooperation

Suppliers must maintain accurate, complete, and timely books, records, invoices, certifications, and supporting documentation relating to business conducted with Hydrite. Suppliers must not falsify records or conceal the true nature of a transaction.

Upon reasonable request, Suppliers must provide information or documentation reasonably necessary for Hydrite to evaluate compliance with this Code. Where warranted by the nature and severity of a concern, Hydrite may request a corrective-action plan or other reasonable verification, subject to appropriate confidentiality protections and any applicable contractual terms.

10. Reporting Concerns and Non-Retaliation

Suppliers must promptly report known or suspected violations of this Code, Applicable Law, or improper conduct connected to Hydrite by contacting legal@hydrite.com. Suppliers are expected to investigate concerns within their operations and cooperate in good faith with reasonable Hydrite inquiries.

Suppliers must prohibit retaliation against any person who raises a concern in good faith or participates in an investigation.

Nothing in this Code or any Hydrite agreement or policy is intended to prohibit or restrict a Supplier or its personnel from reporting possible violations of law to, communicating with, or providing information to a governmental, regulatory, law-enforcement, or self-regulatory agency, including communications protected by Section 21F of the Securities Exchange Act of 1934, as amended, and applicable rules.

11. Compliance, Corrective Action, and Consequences

Hydrite may consider a Supplier’s compliance with this Code when selecting, retaining, or evaluating Suppliers. If Hydrite identifies a concern, the Supplier must timely investigate, address the issue, and implement reasonable corrective action.

Failure to comply with this Code may result in suspension of work, rejection of goods or services, required corrective action, termination of the business relationship or applicable agreement, or other remedies available under contract or law. Hydrite reserves the right to interpret, apply, enforce, and modify this Code in its discretion, subject to Applicable Law and any controlling written agreement.