PennEngineering®
Supplier Code of Conduct
and Sustainability Agreement

1Table of Contents
Forward................................................................................................................................ 3
Environmental Commitments..................................................................................... 4
Greenhouse Gases .................................................................................................... 4
Energy Use / Clean Energy %............................................................................... 4
Product Compliance, Materials and Chemical Usage.................................. 4
Water Use..................................................................................................................... 4
Pollution and Waste Management...................................................................... 5
Product End of Life................................................................................................... 5
ISO 14001 Certification............................................................................................ 5Social.................................................................................................................................... 6Safety............................................................................................................................. 6
Human Trafficking...................................................................................................... 6
Human Rights, Fair Labor....................................................................................... 6
ISO 45001 Certification........................................................................................... 6
Governance........................................................................................................................ 7
Anti-Bribery & Anti-Corruption............................................................................ 7
International Trade & Local Laws......................................................................... 7
Conflict of Interest..................................................................................................... 7
Intellectual Property (IP)......................................................................................... 7Fraud, Price Setting.................................................................................................. 7
Anit-Retaliation & Whistleblower Policies........................................................ 7Asset & Data Protection.......................................................................................... 7Summary............................................................................................................................. 8Supplier Code of Conduct & Sustainability Reporting.................................... 102

FowardPennEngineering® has made a commitment to be caretakers of our planet: to protect thenatural resources of the world, ensure the fair and equitable treatment of all its people,and to support the development and growth of our communities. We ask that our suppliers
help us achieve these goals by reviewing and agreeing to follow the guidelines set forth in
this document.
Product Compliance is a necessary first step, but it is not the last. Our choice of suppliers
is made not only by their products and pricing, but also by their stewardship and adherence
to the values outlined in this document.
Together, along with our suppliers, we must strive to continually do better to reduce ourgreenhouse gas emissions, reduce pollutants, reduce our energy use, reduce our water
consumption, and leave the world better than we found it. We need to be mindful of how wetreat our fellow people, both as individuals and in how we come together as communities.
We must be respectful of each other, celebrating our differences and similarities both.
Together the difference we make will be incredible.

Supplier Compliance
All suppliers of products and services to PennEngineering and all its divisions (PEM®, Profil®,
Sherex®, Haeger®, PennAuto®, and PennTool®) shall comply with the requirements in thisdocument.
All suppliers providing: raw materials, product (work-in-progress or finished-goods), products
and materials used to process product, services used to process product, or labor supplied
will be referred to as “Reporting Suppliers”. Reporting Suppliers:
1. S
 hall annually update and sign the agreement to this document (last page of document).
This should be submitted through the vendor EQMS portal (if you need additional
information regarding the EQMS portal, please contact your purchasing representative).
2. W
 ill have their compliance to this document reflected on their Supplier Scorecards byPennEngineering.
PennEngineering reserves the right to audit a supplier for compliance to this document, orrequest documentation of compliance from a self-audit or third-party auditor.

Quality Requirements and Organization
Quality Compliance and standards are not set forth in this document but are covered in a
separate document.

This document is organized to support ESG Goals: Environmental, Social and Governance.
They are not put in a priority order but organized to hopefully aid in clarity and organization.
All hard requirements specified shall or will have been highlighted for convenience.

Back to Table of Contents3Environmental Commitments
PennEngineering takes seriously its responsibility to be stewards of the earth and weask our suppliers to support our efforts in this. This section of the Supplier Sustainability
Agreement outlines requirements that we ask our suppliers to comply with to help keep
this commitment.

Greenhouse Gases
Each supplier should report annually their Carbon Footprint (in accordance with Greenhouse
Gas (GHG) Protocol) in a Sustainability Report. This should be broken down by traditional
Scopes (Scope 1 – Direct, Scope 2 – purchased energy, and Scope 3 – Indirect up and downstream). Reporting Suppliers shall report these numbers annually for their entire businessand the portion associated with business to PennEngineering on the signed agreement(last page of document).
We are also driving to product level Carbon Footprint reporting and ask that you startdriving your enterprise that way as well so that in the future you will be able to report partnumber specific carbon emission values.

Energy Use / Clean Energy %We ask that each supplier take actions to drive down their energy use and to find ways touse more clean energy in their operations. The transition from energy derived from fossil
fuels to clean energy is a different journey for each of us dependent on many factors outof our control. But we ask that you look to support clean energy initiatives and whenpossible, make business decisions that reduce energy consumption and drive towards
clean energy.

Product Compliance, Materials and Chemical Usage
Product provided to PennEngineering shall be compliant with all requested certifications
unless an exception is explicitly provided. At a minimum this will include the current
REACH SVHCs, and RoHS. The CMRT (Conflict Minerals Reporting Template) shall also
be used in accordance with the Responsible Minerals Initiative (RMI).

Water Use
We ask each supplier to reduce their use of water, particularly in water stressed
environments. Access to clean water is a key component of a community and arequirement not just for human life but all life on earth.

Back to Table of Contents4Pollution and Waste Management
Suppliers of PennEngineering are expected to reduce and eliminate sources of pollution fromtheir process. This includes air, water, waste, chemical, and noise pollution. Where the sourcecannot be entirely eliminated, efforts should be made to control and reduce as much as
possible the hazardous wastes.
Suppliers should look to embrace the teachings of a circular economy reducing waste
products as much as possible and looking for ways to reuse or recycle the waste materials
that are generated.

Product End of Life
Product design should consider not only its production and use, but final disposal as well.
In all cases, best practice of design includes consideration of how best to dispose of a
product after its useful life has come to an end. We expect that our suppliers give thisconsideration to not only new products but in any redesigns of existing products.

ISO 14001 Certification
While not required, it is recommended that you consider getting certified for ISO 14001 for
an Environmental Management System.

Back to Table of Contents55SocialMaintaining the connections between people and our communities is an important facet ofPennEngineering’s ESG goals. To enable this we want to ensure that our supplier are treating
all people with respect and ensuring their wholistic safety and security. Treating each otherwith dignity and respect is a core value to PennEngineering.

SafetyThe safety of our own employees is a priority. We believe this should be reflected by oursuppliers, and that you look to safeguard your own employees. We ask that you take action
to prevent accidents and occupational illnesses in the workplace. Suppliers must haveprocedures in place for handling emergencies such as fire, spills, and natural disasters.
In a similar way we ask that you consider your products and ensure that they reflect highlevels of safety. This should be designed in from the beginning to ensure that production,distribution, use, and disposal are all properly thought out to minimize risks and optimize
safety.

Human Trafficking
Human trafficking is a gross violation of another person and is not tolerated. We expect thatour vendors and suppliers be vigilant in seeing the signs of human trafficking, report any
such activities (or suspicions), and in no case participate.

Human Rights, Fair Labor
Dignity and mutual respect are at the heart of our interactions with each other, business
partners and anyone we encounter in a business setting. The Supplier shall not allow
harassing behavior, corporal punishment, threats of violence, or other forms of harassment
or discrimination based on personal characteristics like gender, age, nationality, ethnicity,
skin color, political views, sexual orientation, religious beliefs, social background, orphysical ability.
We expect that our vendors and suppliers respect internationally recognized human rights.
In no case will we work with a vendor who employs forced labor, compulsory labor, childlabor (defined by a person younger than 16 or younger than the minimum age required forthe employment under applicable law), prison labor, bonded labor, indentured labor, orillegal discrimination. Supplier will ensure that proper controls are in place to prevent theintroduction of forced labor into any upstream portion of the supply chain.
There shall be no unreasonable restrictions on workers’ freedom of movement in addition
to unreasonable restriction on entering or exiting the company provided facilities.

ISO 45001 Certification
While not required, it is recommended that you consider getting certified for ISO 45001
for an occupational health and safety (OH&S) management system.

Back to Table of Contents

6

GovernanceAnti-Bribery & Anti-Corruption
We take a strong stance against bribery and corruption. It is important that our suppliers
understand that we will not accept bribes and attempts to influence our purchasing decisions
using them may result in discontinuing our relationship.
As a supplier you shall not offer or make a personal payment or gift to a PennEngineering
employee or family member in return for favorable treatment or to gain a businessadvantage. You must not allow anybody else to do so on your behalf. This applies even
where local custom would otherwise allow such actions or payments.

International Trade & Local Laws
Local and International Laws take precedence over this document. When there is a conflictto this document, all laws affecting it supersede anything written herein.
Supplier must conform to all applicable wage and hour laws and regulations, including
those related to minimum wage, overtime, and other elements of compensation – and will
provide all legally mandated benefits.

Conflict of Interest
You shall disclose any possible conflict between your private interests and those ofPennEngineering. This includes familial relationships with PennEngineering employees.
Clearly communicating any possible conflicts can help ensure that there is no actual orperceived influence on business decisions as a result of such collaboration. Favoritism offriends or family will not be tolerated, all business partners or potential business partners
will be treated on equal grounds. As a vendor you shall not use these relationships to seek
preferential treatment.
If you think you have a conflict of interest, you shall disclose it by talking to your purchasingteam or contacts within PennEngineering. Most conflicts can be addressed and resolved
without serious issue.

Intellectual Property (IP)You shall take care to protect any IP provided or witnessed, be that of PennEngineering ora partner (customer or other vendor). This includes but is not limited to our trade secrets
or other product or process information. This means that you must protect documents andavoid working on confidential matters in public, and do not discuss details where you might
be overheard.

Fraud, Price Setting
Each supplier shall have policies in place to prevent Fraud, Price Setting and other concerns
regarding fair trade. Quotes should be clear without hidden fees and transactions. Billingshould be prompt and clearly linked to products or services. Additional charges beyond
what was originally negotiated must be clearly and openly communicated.

Anit-Retaliation & Whistleblower Policies
We ask that all vendors have policies in place to support speaking out and prevent retaliation,
protecting a whistleblower; complaints raised should be documented and investigated.

Asset & Data Protection
PennEngineering may of necessity share confidential or sensitive information and or assets
with our vendor partners. We expect that our partners take this trust and treat it responsibly.
Actions should be taken to protect this information or assets and avoid it being lost, stolen intentionally or accidentally. We ask that our partners have policies in place to ensure this.
In addition, our partners shall comply with the General Data Protection Regulation (GDPR)
and all other applicable data privacy laws and regulations when processing personal data of
our customers, employees, or other individuals on our behalf.
Back to Table of Contents7SummaryPennEngineering’s suppliers shall report any non-compliance to these guidelines to thePennEngineering Speak Up program. This can be done anonymously by submitting anemail to speakup@pemnet.com or to a hotline (215) 766-1000. We will discretely workwith you to resolve the issues.
Thank you for your continued partnership. We look forward to a strong relationship as
partners committed to sustainable business. All of us in our parts will make a difference
together.
Thank you,

Brian G Bentrim, P.E.
Global VP of Sustainability
PennEngineeringwww.pemnet.com

8www.pemnet.com

9PennEngineering®
Supplier Code of Conduct andSustainability Reporting
Supplier / Vendor Name:
Reporting Period:
We agree to the PennEngineering® Supplier Code of Conduct and Sustainability Agreement:
Check here for agreement

Contacts
Name

EmailPhone

Primary
Backup				

Carbon Footprint (in accordance with GHG Protocol)
Units tCO2e

Scope 1

Scope 2

Scope 3Company Total
In Support ofPennEngineering

Signature
The below signatory confirms that PennEngineering’s Supplier Code of Conduct, andSustainability Agreement has been reviewed and agreed to by the Vendor named above.

Printed Name:							Signature:

www.pemnet.com

Date: