ACA Group Supplier Code of Conduct

SUPPLIER CODE OF CONDUCT
Effective April 1, 2022

ACA Group (“ACA”) is committed to maintaining the highest level of integrity and ethical standards, and to operating its business in compliance with all applicable laws, rules, and regulations. ACA works with third-party suppliers who provide goods and/or services to assist ACA in its day-to-day business operations and the achievement of ACA’s business objectives (“Suppliers”). ACA desires to work with Suppliers who reflect its commitment to integrity, lawfulness, ethics, and the high standards that ACA has for its business. This Supplier Code of Conduct (“Supplier Code”) sets ACA’s expectations for how Suppliers conduct their business. All Suppliers and Supplier personnel involved with providing goods and/or services to ACA must adhere to all applicable practices of this Supplier Code.

Ethical Business Practices

Suppliers are expected to operate their business ethically in compliance with all applicable laws, rules, and regulations.

Conflicts of Interest. Suppliers are encouraged to proactively identify and address situations that present or may present actual or potential conflicts of interest with respect to their provision of goods and/or services to ACA. Any identified conflicts should be disclosed to ACA as soon as Supplier becomes aware of such conflict.

Insider Trading. Over the course of its relationship with ACA, Suppliers may become aware of material non-public information (“MNPI”) or “inside information”. Suppliers who possess MNPI or inside information are prohibited from trading based on the MNPI, encouraging others to trade based on the MNPI, and sharing that information outside of ACA. Insider trading will not be tolerated in any form. All Suppliers must maintain compliance with applicable insider trading laws and avoid the appearance of impropriety.

Anti-Bribery. Suppliers shall not engage in bribery, whether direct or indirect. Suppliers must prohibit improper or unethical payments to any person or business.

Anti-Money Laundering. Suppliers must comply with all applicable anti-money laundering laws and regulations. Suppliers are expected to take reasonable steps to ensure that the parties it does business with conduct legitimate business activities with money derived from lawful sources.

Economic and Trade Sanctions. ACA expects its Suppliers to comply with applicable economic and trade sanctions and not conduct business with entities that are on any current U.S. Department of the Treasury Office of Foreign Assets Control (OFAC) sanctions list.

Diversity and Inclusion

ACA is committed to creating, fostering, and promoting a workplace environment that supports diversity, equity, and inclusion in all forms. Discrimination and harassment are not tolerated by ACA. Suppliers are encouraged to similarly commit to operating a diverse, equitable and inclusive workplace, including not tolerating any form of discrimination and ensuring employees complete any required positive workplace/anti-harassment training.

Workplace Safety and Human Rights

Providing a safe, respectful and secure workplace environment, and further, the protection of human rights, is of the utmost importance to ACA. Suppliers shall similarly commit to providing a safe workplace environment and the preservation of human rights.

Workplace Safety. Supplier shall prohibit and have zero-tolerance for violence or harassment in the workplace. Supplier shall meet or exceed applicable laws and regulations on occupational health and safety.

Human Rights. ACA is committed to combating modern slavery and human trafficking by identifying areas of potential risk in our business and supply chains, and implementing risk mitigation controls accordingly. ACA expects its Suppliers to also address modern slavery and human rights risks in its supply chain through its policies and business practices and comply with all applicable modern slavery laws and regulations.

Environmental Sustainability

ACA maintains a Corporate Environmental Sustainability Policy, which includes guidelines for sustainable workplaces. This policy emphasizes practices such as recycling, turning off lights, and proper disposal of equipment, among other items. ACA expects Suppliers to take reasonable measures to contribute to reducing its impact on the environment. Suppliers shall also obtain, keep current, and comply with all required environmental permits.

Oversight

ACA expects Suppliers to adopt and maintain policies and procedures that are in accordance with the spirit of this Supplier Code and take reasonable steps to ensure compliance with such policies and procedures.