Supplier Code of Conduct

HYDRITE CHEMICAL CO.
SUPPLIER CODE OF CONDUCT

Hydrite Chemical Co. (“Hydrite”) is focused on achieving success while working to improve the communities in which we operate. A key piece of this success is our record of building strong relationships with our suppliers, who play an important role in our ability to live out our mission of providing sustainable ideas and solutions that ensure Customer, Employee and Partner success.. We hold ourselves to exacting standards, and we expect the same from our suppliers, whose actions may reflect upon (or be seen as the actions of) Hydrite.

We provide this Supplier Code of Conduct (the “Code”) to provide guidance of our expectations to all individuals and firms providing any goods or services to Hydrite (“Suppliers”). Because no code of conduct can contemplate every possible set of circumstances, we reserve discretion in the interpretation, application, and enforcement of the Code, and noncompliance with Code may result in Hydrite terminating its business relationship with a Supplier or other legal action. We reserve the right to modify the Code at any time in our discretion.

1. Compliance with Laws and Doing the Right Thing. As a baseline, our Suppliers must conduct their business in compliance with all applicable legal authority in all applicable jurisdictions (“Laws”). We expect that, in addition to rigorously maintaining compliance with Laws, Suppliers will conduct their business in a fair and honest manner and in all situations do the “right thing.”
2. Quality. Our success is largely driven by our exacting quality standards, so in addition to complying with all Laws, we expect our suppliers to meet or exceed our quality standards, specifications, and procedures.
3. Environmental Stewardship and Sustainability. We expect Suppliers to comply with Laws governing or relating to environmental protection. We further expect that our Suppliers will work to reduce the impact of their work on the environment and provide support to Hydrite’s sustainability program.
4. Human Rights and Labor Practices. Suppliers must maintain compliance with all Laws (including, without limitation, the California Transparency in Supply Chains act of 2010, and labor, wage, and work laws) pertaining to how they treat their employees and contractors. We further expect Suppliers to maintain both a safe workplace and policies, programs, and practices that: demonstrate the Supplier’s respect for its employees and contractors, and prohibit harassment, discrimination, compulsory labor, or child labor.
5. Fair Competition and Corrupt Business Practices. Suppliers must at all times maintain compliance with all applicable antitrust/competition Laws and the U.S. Foreign Corrupt Practices Act. Beyond this, Suppliers must strive to avoid any mere appearance of impropriety in its actions.
6. Hydrite’s Intellectual Property. Suppliers must protect all of Hydrite’s confidential information and intellectual property (“Hydrite’s Information”) and only use Hydrite Information for Hydrite’s benefit.
7. Gifts. Suppliers must not offer or provide gifts to Hydrite employees that are above nominal value, would be illegal under applicable local law, or would be in any way inappropriate under the circumstances.
8. Reporting of Concerns relating to this Code of Conduct. Suppliers must report violations of this Code or improper behavior of either Supplier or Hydrite’s employees by writing to legal@hydrite.com immediately or as soon as practically possible.

Nothing contained in this Code or any other Hydrite agreement or policy is intended to prohibit or restrict Supplier from disclosing confidential information to any government, regulatory or self-regulatory agency, including under Section 21F of the Securities and Exchange Act of 1934, as amended, and the rules thereunder.