INTERNATIONAL SOS PROVIDER
CODE OF CONDUCTInternational SOS takes pride in ourreputation for integrity and the businesssuccess that our reputation has enabled. This
reputation has taken years to build andmaintaining it is vital to our success.

Providers to comply with these and any other sanctions
rules which may be applicable to their activities in and fromthe territories in which they operate. When providing
services to International SOS or its customers, Providers
may not deal with any entities, organisations, persons orvessels which are under any applicable sanctions.

The Code has been developed to convey International
SOS’s expectation to all Providers to adhere to the highest
ethical standards when conducting business.

3. Confidential/Proprietary Information

Providers are required to take reasonable steps to ensurethat the Code is communicated throughout theirorganisations and to make the Code available to theiremployees.
International SOS values its business relationships with its
Providers and requires its Providers to share ourcommitment to, at a minimum, compliance with thefollowing standards:

1. Anti-corruption Compliance
Providers may not act in any way, in their businessrelationship with International SOS or otherwise, thatviolates the U.S. Foreign Corrupt Practices Act or any
otheranti-corruptionlawaroundtheworld.
International SOS entities use Providers that do not violate
our ethical standards through bribes, kickbacks, or othersimilar improper or unlawful payments.

Providers must respect International SOS’s intellectual
property, trade secrets and other confidential, proprietaryor sensitive information and may not use or disclose any
such information except in accordance with their contract
with International SOS and for the benefit ofInternational SOS. Any information or data regarding
International SOS’s operations shall always be treated byProviders as confidential unless that information enters thepublic domain through no fault of the Providers.

4. Data Protection and Privacy Laws
Providers will undertake necessary measures to ensurethat personal data it handles on behalf of International SOS
will be protected against unauthorised disclosure, access,use and modification and that it will be used only for
purposes of rendering the relevant services or as incompliance with applicable data privacy and dataprotection laws.

5. Ethical Dealings

Providers shall comply with all national and internationalanti-bribery regulations as well as applicable anticorruption laws, regulations and standards. Providers
shall not (either directly or indirectly) offer or promise toprovide anything of value to improperly influence an official
act or to secure an improper advantage in order to obtainor retain business.

Honest dealing with customers and Providers is essential
to sound business relationships. International SOS seeks
to give all Providers fair consideration. Decisions arebased on objective criteria such as price, quality, andservice capability as well as Providers’ reliability andintegrity. Invoices, financial settlements and reports should
correctly reflect the business transactions between us.

2. Compliance with Laws

Providers are required to demonstrate these same highethical standards and to conduct all business transactions
with integrity and fairness and shall encourage its own
suppliers to adhere to the Code as part of fulfilling theircontractual obligations.

Provider’s personnel and operations shall operate in fullcompliance with the laws of their respective countries andwith all other applicable laws, all statutory, regulatory andother legal requirements, including but not limited toantitrust, trade controls and sanction regimes. Additionally,Providers will ensure that products and services forInternational SOS adhere to all applicable international
trade compliance laws, all statutory, regulatory and otherlegal requirements.
International SOS has as its core policy a commitment tocomply with the sanctions regimes of the United Nations,the United States of America, the European Union,
Singapore and the Hong Kong SAR, and requires its

INTERNATIONAL SOS PROVIDER CODE OF CONDUCTProviders shall equally disclose any potential conflict ofinterests where individuals have private or personal
interests that could influence their decisions.

6. Money Laundering and Financial Records
Providers shall comply with applicable laws andregulations designed to combat money laundering
activities. Providers shall maintain financial records andreports according to international laws and regulations.

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INTERNATIONAL SOS PROVIDER
CODE OF CONDUCT
7. Health and Safety

11. Environmental Responsibility

Providers who do business with International SOS areencouraged to maintain a focus on health and safety thatis consistent with International SOS and must provide asafe and healthy work environment for all employees
working at their sites.

Providers shall comply with all applicable environmental
laws, regulations and standards as well as implement aneffective system to identify and eliminate potential hazards
to the environment.

In addition, any Provider representative providing on-site
services in an International SOS facility is required toadhere to International SOS safety standards.
It is our expectation that Providers have and enforce a
written policy on drugs, alcohol and other prohibited items.

8. Business Continuity Planning
Providers shall be prepared for potential disruptions of its
business through natural disasters, illness, pandemics,criminal acts, etc. This should include emergency plans toprotect both employees and their wellbeing as well as tominimize the effects of such events on the delivery of
products and services.

9. Diversity and Inclusion
Providers shall encourage an inclusive work environment,
valuing the diversity of its employees and contractors andavoiding discrimination with respect to gender, race,religion, age, disability, sexual orientation, origin or any
other differentiating characteristics.

10. Modern SlaveryProviders shall not use any form of forced, bonded or
involuntary labour. All labour must be voluntary. Workers
must be allowed to maintain control over their identification
documents (e.g. passports, work permits or any otherpersonal legal documents). Providers shall ensure thatworkers do not pay fees or make any payment connected
to obtaining employment throughout the hiring process andthe employment period. Providers shall pay workers in atimely manner and clearly convey the basis on which
workers are being paid.
Punishments, mental and/or physical coercion areprohibited. Disciplinary policies and procedures shall beclearly defined and communicated to the workers.
Providers shall also not employ children under the legal
age of employment in any country or local jurisdiction.

We expect our business partners to strive to support global
climate protection goals through the products and services
they deliver and to operate sustainably and conscious of
the environmental impact.

Adherence & Violations
Providers must immediately notify International SOS in
writing upon becoming aware of any negative or otheradverse publicity concerning the Providers or any productand services being provided to International SOS by theProvider, or any event or circumstance related to theProvider that could be expected to cause negative or otheradverse publicity concerning International SOS.
It is the responsibility of each Provider to ensure that its
employees and representatives understand and complywith the Code.
Failure to adhere to the Code may be grounds forterminating the Provider relationship depending on theseriousness of the violation and the circumstances.

Definitions“International SOS” means AEA International Holdings
Pte. Ltd. and its Affiliates. where “Affiliates” mean any
person or party that controls International SOS, iscontrolled by International SOS or is under common
control with International SOS, where “control” means
owning, directly or indirectly, more than 50% of the capitalstock (or other ownership interest, if not a corporation) of aperson or party ordinarily having voting rights or otherwise
having the right or ability, by contract or otherwise, to direct
the management and policies of such person or party.
“The Code” means International SOS Providers Code ofConduct.
“Providers” or “Provider” means current and futureindividuals and/or entities which are contracted withInternational SOS as Providers to which International SOS
refers their client’s workforce, their employees and others
who may subscribe to its services or who may be entitled
to Intl.SOS’ services under a specific program.
If you have any questions about the Code, you may contact
us at Compliance@internationalsos.com.
Version 3.0 dated 30 March 2021

INTERNATIONAL SOS PROVIDER CODE OF CONDUCT

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