INMAR SUPPLIER CODE OF CONDUCT

JANUARY 2026

INTRODUCTION

Inmar, Inc. and its subsidiaries (collectively, “Inmar”) are committed to conducting business in a lawful and ethical manner, including engaging with suppliers that are committed to the same principles to ensure a long-term, sustainable, and successful relationship for all parties.

This Supplier Code of Conduct (this “Code”) applies to Inmar’s suppliers and their subsidiaries, affiliates, and subcontractors (each a "supplier") providing goods or services to Inmar or its subsidiaries, or for use in or with one or more of its subsidiaries’ products, as determined by the Inmar Procurement Team.

Certain laws, often termed Fair Access Laws, including but not limited to the Idaho Transparency in Financial Services Act (§ 26-3801 et seq.) and Florida Statute § 560.1115, prohibit financial institutions and covered entities from conditioning access to financial services or engaging in discriminatory practices based on non-financial criteria, including environmental, social and governance or diversity, equity and inclusion benchmarks. Accordingly, to the extent that Inmar or any parent or subsidiary is subject to such laws, compliance with the policies or standards in this Code shall not be required where doing so would contravene applicable state or federal law. Nothing in this Code shall be construed to require conduct that violates any applicable state or federal law governing fair access to financial services or the use of non-risk-based criteria.

Inmar will assess its suppliers’ alignment with this Code from time to time, as it deems appropriate. This Code, and the level of adherence to it, will be considered in conjunction with the evaluation of any ongoing supplier relationship.

To further the implementation of this Code, the supplier will use reasonable, risk-based efforts to promote compliance by its direct subcontractors involved in providing services to Inmar. Upon written request, the supplier will provide information on material non-compliance identified in that direct tier.

SECTION 1: CONDUCTING BUSINESS

Inmar expects the highest standards of ethical conduct from all its suppliers and third-party providers. Suppliers are required to comply with all laws, rules, regulations, and treaties applicable to the products and/or services provided to Inmar in all locations in which business operations are conducted. If there is a direct conflict between anything in this Code and a signed agreement between the parties, the signed agreement controls.

  1. Compliance: The supplier must comply with all applicable international, federal, state, and local laws and regulations. This includes, but is not limited to, laws relating to human rights, labor practices, environmental protection, data privacy, anti-corruption, export controls, and sanctions.
  2. Bribery: All forms of bribery, corruption, extortion, or embezzlement are prohibited, and the supplier should maintain appropriate measures designed to prevent bribery in all commercial dealings and in dealings with public officials.
  3. Protection of Intellectual Property and Data Security: The supplier shall respect intellectual property rights and safeguard customer information. The supplier shall manage technology and know-how in a manner that protects intellectual property rights. Suppliers must maintain cybersecurity protocols and data protection measures to protect against unauthorized access or disclosure, and notify Inmar without undue delay no later than 72 hours after confirming a Security Incident involving Inmar Confidential Information (as defined in the applicable non-disclosure agreement between Inmar and the supplier) or personally identifiable information. “Security Incident” means unauthorized access, acquisition, or disclosure of Inmar Confidential Information, regulated data, personally identifiable information or Inmar customer information, excluding unsuccessful attempts. The supplier shall ensure compliance with applicable data protection and privacy regulations (1) in its jurisdictions of operation, and (2) where such data is located or resides (e.g., data centers, cloud service providers, sub-processors, disaster recovery locations, etc.).
  4. Artificial Intelligence: If the supplier makes use of artificial intelligence, the supplier must use artificial intelligence (AI) responsibly and in compliance with applicable laws and contracts. At a minimum, the supplier should:
    1. ensure that any AI systems are safe and secure;
    2. take responsible steps to prevent discrimination, bias, or misuse of Inmar or customer data;
    3. be transparent about AI systems, where relevant;
    4. ensure the explainability, auditability, and traceability of AI systems used or developed by the supplier;
    5. establish and maintain appropriate governance practices that promote the ethical use of AI systems.
  5. Gifts and Hospitality: Gifts and hospitality must be reasonable and entirely for maintaining good business relations, not intended to influence the outcome of decision-making (see also Section 1.2). Inmar expressly prohibits the expenditure of funds for any purpose that may violate any applicable law or regulation.
  6. Financial Management and Disclosure: The supplier must record all commercial dealings accurately and transparently in its record-keeping systems. The supplier shall not conduct any money-laundering activities. Confidential information of Inmar (or its customers) must not be used inappropriately or to support insider trading activity.
  7. Conflict of Interest: All conflicts of interest must be disclosed to Inmar, including any ownership or financial interest involving Inmar associates, Board members, government officials, or political parties, prior to and during the business relationship.
  8. Whistleblower Protections: The supplier must protect whistleblower confidentiality and prohibit retaliation against workers who report workplace grievances. The supplier should maintain a mechanism for workers to submit their grievances anonymously. The supplier must maintain compliance with all federal, state, and local laws pertaining to whistleblower protections.
  9. Reviews and Assessments: Inmar may request information or conduct reviews to confirm a supplier’s alignment with this Code. Any such requests or reviews will be made with reasonable notice. If concerns are identified, the supplier is expected to work in good faith with Inmar to address them. Inmar is not obligated to conduct reviews.

SECTION 2: HUMAN RIGHTS AND LABOR PRACTICE

Workers must be treated with dignity and respect, and Inmar’s suppliers shall uphold human rights standards. At a minimum, suppliers are required to comply with all applicable laws and regulations regarding working conditions and labor standards.

  1. No Forced Labor: The supplier shall ensure that all work is voluntary. The supplier shall not use any enslaved, involuntary, forced, prison, or debt bondage labor of any kind. The supplier will not be involved in human trafficking activity or any activity that promotes modern slavery. The supplier shall not use any corporal punishment, physical or psychological abuse, or threats of violence or coercion to secure or retain its employees. No employee identification documents (passports or identity papers) will be withheld or retained by the supplier. There should not be any unreasonable restrictions on the ability of employees to leave the workplace and/or find alternative employment.
  2. Modern Slavery Due Diligence Requirements: Suppliers must implement due diligence processes to prevent, identify and remediate forced labor and human trafficking throughout their operations. Suppliers must provide immediate notification to Inmar of any identified instances of forced labor or human trafficking in their operations or supply chain and must fully cooperate with any subsequent investigation or audit.
  3. No Child Labor: The supplier shall comply with all laws preventing child labor. Workers must meet the minimum legal age requirements. At a minimum, workers should be at least 15 years old and have completed compulsory education. If there is any doubt about the minimum age of employment, the ILO’s Minimum Age Convention, 1973 (No. 138) should be applied. The supplier shall not allow workers under the age of 18 to work night shifts or be involved in any hazardous work, as specified in the ILO’s Worst Forms of Child Labour Convention, 1999 (No. 182).
  4. Wages, Benefits and Working Hours: The supplier shall adhere to all applicable laws regarding working hours, wages, social security payments and overtime payments. Workers shall be paid at least the minimum legal wage. Where there is no legislated minimum wage, the supplier must be able to demonstrate that an employee’s wages meet industry norms. Wages shall be paid promptly and in full. The supplier will limit working hours and overtime to levels that are humane and safe. Overtime will comply with law, be compensated accordingly and avoid coercion. Workers shall receive annual leave and public holidays in accordance with applicable law.
  5. Employment Contracts: All employees shall be provided with written and understandable information in their local language about their employment conditions in respect of wage, benefits and working hours.
  6. Deductions: Using deductions from basic wages as a disciplinary measure is prohibited. Disciplinary measures must be based on documented disciplinary procedures that are communicated to all staff.
  7. Freedom of Association: The supplier will respect workers’ rights to lawful worker representation. Where unions are legally restricted, the supplier will permit alternative worker engagement mechanisms. The supplier shall ensure that representatives of trade unions and their associated activities are not subject to discrimination and are able to undertake their representative functions in the workplace.
  8. Discrimination and Harassment: The supplier will comply with all applicable laws and regulations regarding unlawful discrimination and harassment. The supplier will maintain a professional and respectful workplace and have measures in place to prevent and address abusive, threatening or disrespectful conduct.
  9. Data Privacy: The supplier shall comply with all applicable federal, state and local data privacy laws regarding employee data privacy.
  10. Immigration Compliance: The supplier may only engage workers who have a legal right to work. If the supplier engages foreign or migrant workers, such workers must be engaged in full compliance with the immigration and labor laws of the host country.
  11. Grievance Processes: Suppliers shall have a formal grievance mechanism. All grievances should be investigated and appropriate action taken to address the issues raised and to prevent any further occurrence.

SECTION 3: HEALTH AND SAFETY

Suppliers shall maintain a safe workplace and integrate health and safety management practices into their businesses. Workers shall have the right to refuse unsafe work and to report unhealthy working conditions. For suppliers operating in the United States, these expectations include compliance with applicable occupational health and safety laws, including the Occupational Safety and Health Act of 1970 (29 U.S.C. §§ 651–678), as applicable. When visiting Inmar sites, suppliers are expected to comply with applicable Inmar health and safety requirements.

  1. Health and Safety Permits: The supplier shall comply with all required permits and laws regarding health, safety, hygiene, sanitation, fire safety, electrical, mechanical and structural safety. The supplier shall have a health and safety management system in place.
  2. Management Commitment: The supplier shall establish adequate policies and objectives for health and safety and abide by them.
  3. Investigation: The supplier shall investigate accidents, near misses and first-aid events. The supplier is prohibited from taking unreasonable punitive measures against its employees for reporting or having accidents, near misses or first-aid events, unless the employee is shown to be willfully negligent.
  4. Safe Working Environment: The supplier shall assess its work environment for health and safety hazards and eliminate, control or mitigate identified risks. The supplier shall provide workers with appropriate workplace health and safety training in their primary language. Health and safety-related information shall be accessible at the point of work. The supplier shall issue to its employees all necessary personal protective equipment, at no cost, to protect their health, safety and welfare.
  5. Emergency Response: The supplier must, as applicable, plan for emergency situations, implement emergency response systems and train its workers on how to use them, and maintain reasonable measures to support continuity of operations.
  6. Subcontractor Management: The supplier shall implement health and safety processes and require compliance with such processes by subcontractors to ensure that any subcontractors performing work on the supplier’s behalf for Inmar comply with applicable health and safety requirements.
  7. Housing Conditions: Worker housing must be clean and safe and provide reasonable living space. The supplier shall provide workers with reasonably accessible and clean toilet facilities and potable water. Supplier-provided dining shall be sanitary.

SECTION 4: ENVIRONMENTAL STANDARDS

Suppliers shall comply with applicable environmental laws, regulations, permits and standards in relation to their business and operations, including but not limited to those mandated by the U.S. Environmental Protection Agency, Department of Transportation, and Mine Safety and Health Administration.

  1. Environmental Permits and Reporting: The supplier must obtain, maintain and keep current all required federal, state and local environmental permits.
  2. Hazardous Waste Management: The supplier shall properly identify, handle, store, transport, and dispose of hazardous waste in compliance with all applicable federal, state, and local environmental laws and regulations.
  3. Management of Environmental Impact: The supplier shall use reasonable efforts to reduce environmental impact and operate in an environmentally responsible manner, consistent with applicable environmental laws and regulations and recognized industry practices.
  4. Environmental Metrics and Greenhouse Gas Emissions: Suppliers are encouraged to develop capabilities for measuring and reporting greenhouse gas emissions across their operations, including Scope 1, 2, and material Scope 3 emissions. This may include tracking environmental metrics such as energy consumption, water usage and waste generation. Suppliers may be requested to share relevant Scope 1, 2, and 3 emissions data. Suppliers are encouraged to establish science-based emissions reduction targets.

Governance

This document is managed by the Inmar Sustainability Procurement Manager in coordination with the Inmar ESG Committee and Procurement Team. These groups are responsible for implementing the Supplier Code of Conduct, promoting alignment with applicable laws, regulations and company policies, and reviewing and updating the Code to reflect evolving sustainability standards, regulatory requirements or business needs.

Revision Protocol

The Supplier Code of Conduct will be reviewed annually by the Sustainability Procurement Manager and the ESG Committee. Revisions may be made whenever there are material changes to Inmar’s business operations, supplier expectations, or applicable legal and regulatory obligations.

Communication and Distribution of Updates

When material changes are made to this Supplier Code of Conduct, suppliers who have previously reviewed and acknowledged the Code will be provided with the revised version. The revised Supplier Code of Conduct will be distributed through customary communication channels, such as email, and will include a summary of the changes and the new effective date. Suppliers will have ninety (90) days from the date of notification to review and acknowledge the revised Supplier Code of Conduct. The Supplier will notify Inmar within ten (10) business days of material enforcement actions related to services provided to Inmar that reasonably could impact performance or legal compliance.

Revised Date Revised By Revision Summary Version Number
1/16/26 Inmar Procurement Team Initial Release 1