Spiber Group

Sustainable Sourcing Policy
Version 1.0 | January 2022

Introduction
MissionSpiberʼs reason for being is to contribute to the sustainable well-being of humankind,both now and for generations to come. This defines Spiberʼs existence and what wehope to achieve throughout our time as a company. Although the development of

Brewed Protein™ materials represents the primary means by which we strive to makethis contribution, the principle of sustainable well-being permeates every aspect of

how we conduct business. Given this purpose, sustainable supply chains in particular
are key to the realization of Spiberʼs vision.

Objective
We have developed this Sustainable Sourcing Policy ( ʻPolicyʼ ) in order to ensure that

we act in alignment with our mission when it comes to sourcing activities. Spiber

commits to adhere to the requirements written within this Policy, and we apply thisPolicy to guide our sourcing decisions and ensure long-term sustainable procurementof the products and services involved in the creation of our materials and products.
We intend readers of this Policy to understand these terms as a promise to society
concerning the procurement standards we commit to uphold and implement.

1Spiberʼs Policy focuses on the three pillars of sustainability: Environment, Social, andGovernance (ESG) principles. It builds on and contributes to the implementation of

widely-applicable and internationally-recognized standards for ethically, socially, andenvironmentally responsible conduct, including the International Labor Organizationʼs

conventions, the OECD Guidelines for Multinational Enterprises, the United Nations

Guiding Principles on Business and Human Rights, and the United Nations Sustainable
Development Goals (SDGs).

Maintaining transparency within business activities is essential to achieving Spiberʼsmission, while also being a crucial tool for understanding sustainability risks andopportunities throughout the different regions in which we conduct business. As theserisks and opportunities are dependent on factors such as geography, socioeconomic
conditions, and stakeholder perception, building collaborative relationships with our
suppliers and partners and promoting transparency allows us to create a cycle offeedback that helps better identify what society and our stakeholders deem assustainable.

This is why we aim to maintain high traceability within our supply chains, so that we
can identify our relationships and stakeholders.

Note that if the standards outlined in our Policy differ from the laws and regulations
that govern the countries or regions in which our suppliers operate, we follow thehigher standard. Where national or regional laws and regulation and Spiberʼs standards

are in conflict, we respect laws and regulations while striving to honor the higher
standard. This means we anticipate cooperation between Spiber and suppliers todesign and implement a parallel means to achieving the spirit of the higher standard

while striving to create positive change within the respective supply chains or regions
when the conflict creates unacceptable conditions within our supply chain.

Scope
This Policy applies to any supplier or manufacturer involved in the creation of Spiberʼs

Brewed Protein™ polymer and Spiberʼs end products. This includes suppliers of goods

and services used in Spiberʼs polymer and materials production, as well as manufacturers
contracted to make end products (collectively referred to as “Suppliers” below).

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At this stage, direct suppliers of Spiber are asked to commit to this Policy. For supply

chains and materials with higher impact, we intend to implement dedicated policies
and/or guidelines as well as initiatives to trace suppliers and address material issues,
with the intent of reaching compliance with this Policy to point of origin. In suchcases, we may seek the cooperation of suppliers or stakeholders with significant

leverage within a supply chain to engage their upstream suppliers to implement the
principles of this policy.

We welcome feedback on our sustainable sourcing efforts from all stakeholders of
our supply chain.

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Introduction

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Mission

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Scope

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Objective

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Human Rights & Labor

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1.1 Human Rights

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1.3 Remediation

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1.2 Land Rights
1.4 Child Labor

1.5 Forced Labor

1.6 Remuneration

1.7 Freedom of Association

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1.8 Health and Safety

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1.10 Working Hours & Contracts

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1.9 Respect and Dignity

Environment
2.1 Environmental Management and Conservation

2.2 Protection of Legally Protected and High Conservation Value Land
2.3 Environmental Transparency
2.4 Environmental Permits

Governance
3.1 Anti-Competition

3.2 Business Integrity

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3.3 Gifts and Hospitality

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3.5 Complaint Mechanism & Protection

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3.4 Transparency and Traceability

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4Compliance with this Policy

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4.1 Signing and Agreement

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4.3 Reporting Grievances

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4.2 Evaluations and Assessments

Appendix A – Definitions

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A-1 Human Rights Due Diligence

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A-3 Free, Prior and Informed Consent

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A-2 Environmental and Social Impact Assessment
A-4 Family Farm Work – Parental Exception
A-5 High Conservation Value Land

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Policy for Suppliers
The following chapters list requirements which all Suppliers must comply with in orderto enter or maintain business relationships with Spiber.

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Human Rights & Labor
1.1 Human Rights
Human rights are respected at all times, which means infringement on the humanrights of others is avoided and adverse human rights impacts are addressed in theunlikely event of occurrence. Even if an adverse human rights impact was not caused
or contributed to through the Supplierʼs own activities, ways to prevent or mitigate

adverse human rights impacts that are linked to a Supplierʼs business operations must
be sought.

Adopting a human rights due diligence process for prevention and mitigation ofadverse impacts (see Appendix A-1), and a grievance mechanism or reporting channel toaddress such occurrences are standardized procedures that are strongly

recommended. In cases where such processes and/or mechanisms are not yet in place
and are deemed necessary by Spiber, the Supplier will cooperate in good faith to set,
disclose, and execute roadmaps for implementation.

1.2 Land Rights
Clear title to land and water in accordance with national practice and law isdemonstrated for greenfield expansions. Transparent, consultative, and participatory
processes with all relevant stakeholders that anticipate and address all relevant

cumulative and induced effects of the proposed land use is further ensured via apublicly available Environmental and Social Impact Assessment (see Appendix A-2 fordefinitions).

Customary land ownership of local communities are to be respected and activities
related to greenfield expansions on local peopleʼs land are to be subject to theprinciple of Free, Prior, and Informed Consent (FPIC, appendix A-3) of the affected local

communities, including indigenous peoples.

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1.3 Remediation
In case of direct or indirect causation or contribution to adverse human rights

impacts, remediation and cooperation through legitimate processes is proactively

provided. This includes constructive dialogue with those affected. For those that arevulnerable or subject to human rights infringements, refer to “4.3: Reporting
Grievances” .

1.4 Child Labor
Employed individuals are over the age of 15, the local legal minimum age for work, or
are over the required age for compulsory education, whichever is highest. Legitimate
workplace apprenticeship programs for educational benefit may be provided toyounger individuals, given that they are consistent with Article 6 of ILO Minimum Age
Convention No. 138, and light work may be engaged in given adherence to Article 7
of ILO Minimum Age Convention No. 138.

For cultural and socio-economic reasons, children under the minimum working age

by national laws may further help their parents on farms as long as the corresponding
standards by the ILO have been met. In short, it will be ensured that they are notforced to work, do not work long hours, and are not exposed to hazardous or heavy

work. Work shall not prevent children from attending school or accessing other formsof education. Further details are outlined in Appendix A-4.

1.5 Forced Labor
No form of forced or compulsory labor is used. This includes any possible slave,forced, bonded, indentured, or compulsory prison labor, including services extracted
from individuals under threat or without remuneration. Any contracts between our
Suppliers and their employees clearly convey the conditions of employment in alanguage that is understood by the employee. In addition, there is no confiscation ofworkersʼ personal documents such as IDs, passports, or financial documents andcards as a condition of employment.

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1.6 Remuneration
All workers are provided with appropriate wages as guided by the principles of equalityof opportunity and non-discrimination against workers with respect to nationality, race,
religion, gender, age, sexual orientation, disability, marital status, political affiliation, or
any other status protected by applicable law.

All workers are provided with at least minimum wages based on national, regional, or

local requirements at all times. In locations where the estimated living wage ̶ which

can be calculated by standardized methods such as the Anker method ̶ is deemed by

Spiber to have a significant gap with the legal minimum wage, the Supplier will cooperate
in good faith to ensure that all workers are provided with at least a living wage.

In addition, wages will be paid in a timely manner and will not be deducted as a formof disciplinary measure, and all other deductions must have written consent from theworker. Deductions must not take place if the implication leads to a workerʼs salary
going under minimum wage.

1.7 Freedom of Association
The rights of all workers to associate with others and to establish or join trade unions
and representative organizations of their own choosing are respected. Workers may

join any organization and engage in collective bargaining without fear or retaliation,
intimidation or harassment. Where the right to freedom of association or collective
bargaining is restricted or scrutinized under law, we require the supplier to adopt aparallel means for workers to effectively promote and defend their labor rights andinterests.

1.8 Health and Safety
All workers are provided with safe and healthy working environments that comply

with all applicable legally mandated standards for workplace health and safety in the
countries and communities in which the Supplier operates. Adequate steps are taken

to prevent work-related injuries, accidents, and illnesses, including regular assessmentand management of key risks.

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1.9 Respect and Dignity
All workers are treated with respect and dignity. No form of psychological, physical,
sexual, or verbal abuse, intimidation, or harassment is tolerated. There shall be nodiscrimination based on nationality, race, religion, gender, age, sexual orientation,
disability, marital status, political affiliation, or any other status protected byapplicable law.

1.10 Working Hours & Contracts
All workers are provided with contracts and reasonable working hours according toapplicable laws and regulations. Workers are not required to work more than theregular and overtime hours allowed by the laws and regulations of the country or

region where the workers are employed. Welfare is also provided according to theapplicable laws and regulations for all workers.

The Supplier will not take advantage of irregular employment schemes to avoid

obligations around employment contracts and social security laws and regulations.
Such schemes or programs include labor-intensive or labor-only sub-contracting,forced or unmanaged remote or home working, and internships or apprenticeships

with no actual intent of providing long-term value (such as technical skills, well-being, or
regular employment) for the employee.

Environment
2.1 Environmental Management and Conservation
All relevant laws and regulations relating to environmental protection are complied
with, including the preservation of biodiversity on and around the Supplierʼs site.

Based on ISO 14001:2015 or that of an equivalent standard, continuous improvements
are made in environmental performance, and policies and procedures are in place tosystematically identify, manage, reduce, and responsibly control, dispose of, or

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recycle hazardous and non-hazardous waste, wastewater, stormwater, water
consumption, air emissions, and energy consumption, where applicable.

If Spiber has proposals for ways our Suppliers can improve the environmental impactof their processes, the Supplier will consider them in good faith and engage
constructively.

2.2 Protection of Legally Protected and High Conservation Value Land
Land is not exploited if it is internationally or nationally legally protected or classified
as land of High Conservation Value (HCV, categories 1-6), and plans are in place toprevent future occurrences of doing so. If no HCV maps or databases are available,credible independently-derived evidence will be provided to demonstrate no HCV

land is converted. Specifications for the six included HCV categories are described inAppendix A-5.

2.3 Environmental Transparency
Transparency is provided to Spiber, Spiberʼs customers and other relevant stakeholders

concerning the environmental impacts of products and production processes, taking

into account concerns about confidentiality and the protection of intellectual property
rights. Such transparency could involve reporting on progress in improving

environmental performance, as well as timely and adequate communication andconsultation with the communities that are directly affected by the environmental
policies of the Supplier.

To provide transparency on the environmental performance mentioned above, westrongly recommend implementing ESG or sustainability related commitments

and/or KPIs, and disclosing a roadmap to showcase these potential improvements.
Existing Information regarding environmental impacts of products and services(including Life Cycle Assessment data of raw materials and production processes from upstream
supply chains when available) will be provided to Spiber on request.

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In cases where such information requested by Spiber is not readily available for the

Supplier to provide, the Supplier will cooperate in good faith with Spiber to identify
and measure environmental impacts and to set, disclose, and implement

commitments and/or KPIs with roadmaps to make such information available.

2.4 Environmental Permits
All applicable requirements for environmental licenses and permits are met, and thereporting requirements of said permits are complied with.

Governance
3.1 Anti-Competition
Suppliers will refrain from entering into or carrying out anti-competitive agreements
among competitors. This includes agreements to fix prices, make rigged bids,

establish output restrictions or quotas, and share or divide markets by allocating
customers, suppliers, or territories or lines of commerce.

3.2 Business Integrity
All forms of bribery to obtain or retain business are prohibited. This extends to any
and all forms of corruption, extortion, or embezzlement, including illegal

contributions to candidates for public office or to political parties or other politicalorganizations. All applicable anti-corruption laws and regulations of relevant countries
are abided by, including the Foreign Corrupt Practices Act (FCPA) and applicableinternational anti-corruption conventions. Adequate procedures are in place toprevent bribery in all its forms in all commercial dealings.

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3.3 Gifts and Hospitality
Any business entertainment or hospitality conducted by the Supplier is kept

reasonable in nature, is performed solely for the purpose of maintaining good

relationships, and is not intended to influence decisions regarding the awarding ofcontracts in any way. The exchange of gifts beyond gifts of incidental value, including
cash or cash equivalents, is similarly prohibited. Any violations regarding thisstandard must be made known or duly recorded if they do take place.

3.4 Transparency and Traceability
Spiber intends to disclose as much information about its supply chain as possible, as itgets built. Suppliers will cooperate in good faith based on Spiberʼs requests toprovide as much information and support as possible in order to allow effective

tracing of materials and processes further down the chain. For this purpose, we ask
for our suppliers to proactively manage and identify suppliers further upstream.

3.5 Complaint Mechanism & Protection
All workers are provided with a complaint mechanism where they can anonymously
and safely voice concerns. The confidentiality of whistleblowers is protected andretaliation is prohibited.

Compliance with this Policy
4.1 Signing and Agreement
All suppliers under the scope of this Policy will commit to this Policy or will

demonstrate commitment through compliance with their internal codes of conduct
or company policies that align with the standards described herein. Suppliers will

provide documents attesting to compliance with this Policy if requested by Spiber.

Suppliers are not only required to comply with this Policy, but are highly encouraged
to share, extend, and communicate the contents of this document with their own

suppliers, with the intent of applying the standards in this policy back to the point oforigin of raw materials.

124.2 Evaluations and Assessments
Suppliers will perform periodic evaluations of facilities and operations that provide
goods or services to Spiber to ensure compliance with this Policy and the law.

Suppliers will also permit Spiber and/or third parties designated by Spiber to evaluate
Supplierʼs facilities and operations and assess Supplierʼs compliance with theapplicable principles and requirements of the Policy when deemed necessary.

4.3 Reporting Grievances
Any breach of this Policy of which Suppliers are aware of must be reported
immediately to allow for appropriate resolution.

Suppliers, their employees, workers, contractors, or stakeholders in relevant

communities may report actual or suspected breaches of this Policy directly to Spiber
or anonymously through our Grievance System:
https://spiber.speakup.report/raiseyourconcern

Spiber encourages our suppliers to foster a culture of transparency and support for

their workers to speak up. There will be no retaliation against those who report actualor suspected breaches.

In the case of reported grievances, Spiber will investigate relevant issues and discuss
its findings with the Supplier. The Supplier shall cooperate with such investigations
and provide access to any information when requested and within reason.

In the event of a confirmed breach of any item of this Policy at one or more facilities
belonging to the Supplier, the Supplier may be requested to present a remediation
plan with defined milestones to be signed by both parties. If the Supplier does notpresent this plan or does not demonstrate steps towards resolution and improvement
according to an agreed-upon timeline, Spiber will take action towards termination ofits business relations with the Supplier.

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Appendix A – Definitions
A-1 Human Rights Due Diligence
Human Rights Due Diligence (HRDD) is a process that was referred to by the United
Nations Guiding Principles (UNGPs) as a standard action to respect human rights.
According to the OHCHR (Office of the United Nations High Commissioner for Human

Rights), HRDD is an ongoing management process that a sizable and/or respected

enterprise shall take on to ensure the respect of human rights within their business.
A common HRDD process will look like the following:

1. Identify and assess impacts within business activities to understand the extent
and severity of human rights risks;

2. Act to prevent and mitigate the identified human rights risks, especially throughthe integration of human rights in existing internal resources and processes;

3. Monitor and track the effectiveness of the actions taken;

4. Appropriately communicate and report on how human rights impacts wereaddressed and the results/performance of such actions.

In reality, the gravity and scale of the HRDD process will change according to factors

such as the size, industry, organizational structure, and timeline/circumstances of theenterprise. The positioning of the enterprise within a given context such as industry,
supply chain, and financial stability may also determine how the 4 steps above are
implemented.

A-2 Environmental and Social Impact Assessment
Environmental and Social Impact Assessment (ESIA) is a tool to provide environmental

and social information for decision-makers who authorize/manage land expansion

projects. It enables local socio-economic and environmental issues to be taken into
account during all phases of project design and implementation.

Although the details of an ESIA vary based on the nature and scale of the operations,an ESIA should include at least the following stages:

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1. Screening and scoping to identify areas and community potentially affected by
the potential impacts;

2. Identify the potential impacts;
3. Consider alternatives;

4. Identify appropriate mitigation measures (to avoid, minimize, or compensate risk);
5. Monitor and evaluate the measures and their actions.

In the absence of relevant national legislation regarding the carrying out of an ESIA, it
is recommended to follow the guidelines from IFC or the WBCSD.

A-3 Free, Prior, and Informed Consent
The definition of Free, Prior, and Informed Consent (FPIC) can be given as follows:
Free: Implies no coercion, intimidation, or manipulation;
Prior: Implies consent has been sought sufficiently in advance of any commencementof activities and with respect for the time-based requirements of the consultation
processes;

Informed: Implies that information is provided that covers the following:• Nature, size, duration, reversibility, and scope of any projects;• Reason or purpose of the project;• Location of areas that will be affected;• A preliminary assessment of the possible economic, social, cultural, andenvironmental impacts (positive and negative), including potential risks and benefits;• Personnel likely to be involved in the implementation of the project.

Consent: Parties must establish a dialogue allowing them to identify appropriate andworkable solutions in an atmosphere of mutual respect and full and equitableparticipation with ample time to reach decisions. This process may include the optionof withholding consent. Potentially affected people must be able to participate

through their own freely chosen representatives and customary and other institutions.
The participation of women, youth, and children are preferable where appropriate.

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A-4 Family Farm Work – Parental Exception
In accordance with international labor standards, a minor between the age of 12 and15 may work, in parallel with studying, on a farm owned or operated by their parent
or person standing in place of their parents [a guardian] as long as the following
conditions are met:

• The minor freely reports their wish to help and learn at the family farm if
interviewed outside the farm;• Work takes place outside of schooling;• Work is supervised at all times by a parent or guardian;• Work does not take place at night and does not consist of heavy lifting duties or
hazardous work conditions, defined as:◦ Operating or assisting to technically operate any type of machine, including

tractors and power engines;◦ Felling, bucking, skidding, loading, or unloading timber;◦ Working from a ladder or scaffold (painting, repairing, or building structures,
pruning trees, picking fruit, etc.) at a height of over 2 meters;◦ Working in a confined space (such as a silo or a storage space designed to containan oxygen deficient or toxic atmosphere);◦ Handling or applying any type of agricultural chemicals;• The above requirements apply as well to apprentices and students that can bepresent on farms in the context of agricultural schools.

A-5 High Conservation Value Land
High Conservation Values (HCVs) are biological, ecological, social, or cultural values

which are considered outstandingly significant or critically important, at the national,
regional, or global level. Land that could be defined as HCV land according to any of
the following HCV values (as defined by the HCV Resource Network) is excluded from
exploitation and development.

• HC V 1 – Species diversity: Concentrations of biological diversity including
endemic species, and rare, threatened, or endangered species, that are
significant at global, regional, or national levels.

16• HC V 2 – Landscape-level ecosystems and mosaics: Large landscape-levelecosystems and ecosystem mosaics that are significant at global, regional, or

national levels, and that contain viable populations of the great majority of thenaturally occurring species in natural patterns of distribution and abundance.

• HC V 3 – Ecosystems and habitats: Rare, threatened, or endangered ecosystems,
habitats, or refugia.

• HC V 4 – Ecosystem services: Basic ecosystem services in critical situations,

including protection of water catchments and control of erosion of vulnerable
soils and slopes.

• HC V 5 – Community needs: Sites and resources fundamental for satisfying thebasic necessities of local communities or indigenous peoples (for livelihoods,
health, nutrition, water, etc.), identified through engagement with thesecommunities or indigenous peoples.

• HC V 6 – Cultural values: Sites, resources, habitats, and landscapes of global or
national cultural, archeological, or historical significance, and/or of criticalcultural, ecological, economic, or religious/sacred importance for the traditional
cultures of local communities or indigenous peoples, identified throughengagement with these local communities or indigenous peoples.

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