APR Energy Supplier Code of Conduct

To be considered as a supply partner to APR Energy you must first read and acknowledge the following statement.

Introduction

APR Energy is an internationally-recognized energy services company which is publicly listed on the London Stock Exchange. APR Energy operates with integrity, fairness, objectivity and candor and it expects the same of its supplier network.

As part of our ongoing effort to develop and strengthen our relationships with suppliers, we are introducing the Supplier Code of Conduct. The Supplier Code of Conduct is based on the belief that good corporate citizenship is essential to our long-term business success and must be reflected in our relationships and actions in the marketplace, the workplace, the environment and the community.

Recognizing there are differences in laws, customs and economic conditions that affect business practices in various parts of the world, we believe that shared values must serve as the foundation for relationships between APR Energy and our suppliers. This Supplier Code of Conduct sets forth our requirements and emphasizes good workplace policies that are designed to comply with applicable environmental laws and with local labor laws and regulations.

We look forward to working with our suppliers to ensure understanding of, and compliance with, the requirements set forth in this Supplier Code of Conduct.

Workplace Standards and Practices: Overview

Suppliers of products or services produced in or provided from the United States shall comply with all applicable federal, state and/or local laws and regulations. Suppliers of products or services produced or provided from outside the United States shall comply with applicable laws and regulations of relevant countries. However, regardless of applicable laws and regulations, suppliers must always uphold the human rights of workers by treating them with dignity and respect.

Suppliers retained by APR Energy and their agents and permitted subcontractors, are fully responsible for the quality, performance, behavior, supervision and protection of their personnel. APR Energy retains the right in its absolute discretion to require the removal of any personnel of a contractor or subcontractor from a job site in appropriate circumstances, for example: (a) if there is reasonable cause to believe a person is under the influence of alcohol, drugs, or other substances that adversely affect that person's work or create a safety risk, (b) for commission of an illegal act, (c) for threatening or harassing the public or any person, or otherwise engaging in abusive or disruptive conduct, (d) for violation of an APR Energy policy, or (e) for performing an unsafe act.

Non-Discrimination

Suppliers may not discriminate against any worker in any manner which violates any applicable laws or regulations or otherwise act in a discriminatory way except where required by applicable law or regulation or prudent for workplace safety.

No Harassment

Suppliers shall treat every employee with respect and dignity and shall not subject any employee to physical, sexual, psychological, or verbal harassment or abuse.

No Forced Labor

Suppliers may not use any form of forced, bonded, indentured, or prison labor. All work must be voluntary and workers should be free to leave work or terminate their employment with reasonable notice. Workers must not be required to surrender any government-issued identification, passports, or work permits as a condition of employment.

Wages and Benefits

We expect our suppliers to compensate their employees fairly in full compliance with applicable local and national wage and hour laws, and to offer opportunities for employees to develop their skills and capabilities.

Freedom of Association

In the event their employees have lawfully chosen to be represented by third parties, we expect our suppliers to bargain in good faith and not to retaliate against employees for their lawful participation in labor organization activities.

Health and Safety Practices: Overview

Safety is always our first consideration. It is not optional. Suppliers must apply safe work practices (including regulatory and contract specific requirements) to all activities and exercise good judgment in work decisions. Suppliers performing work on our property or on our behalf must instill safety in every aspect of their work processes and in the attitude and behavior of all their employees. Suppliers must plan for and apply safe work practices (including regulatory and contract specific requirements) to all in every aspect of their equipment, job assessment, work processes, PPE, training and in the attitude and behavior of all their employees.

Occupational Safety

Suppliers must establish a safety program which incorporates legal, regulatory and industry recommended practice, including procedures and systems to manage, track, and report occupational injury and illness. Such procedures and systems should encourage worker reporting, classify, and record injury and illness cases, investigate cases and implement corrective actions to eliminate their causes, provide necessary medical treatment, and facilitate the workers' return to work.

No Alcohol or Drug Use

Suppliers must not report to work or engage in any work for or on behalf of APR Energy, or in any fashion represent, or make any representations on behalf of APR Energy, while under the influence of illegal drugs or alcohol. In addition, suppliers may not possess illegal drugs or controlled substances while on APR Energy premises or while conducting business with or for APR Energy. This prohibition does not include legally obtained medications used as directed by a licensed medical practitioner that do not create a safety risk (e.g., impairment while operating machinery).

Environmental Practices: Overview

Adverse effects on the community, environment, and natural resources are to be minimized while safeguarding the health and safety of the public. Suppliers must comply with all applicable health, safety, and environmental laws and regulations for materials management, environment protection and worker safety when conducting business with APR Energy. By way of example and not limitation, APR Energy's suppliers must:

  1. Obtain and keep current all required environmental permits and registrations;
  2. Create a plan to reduce, control and/or eliminate wastewater, hazardous materials waste and pollution at the source;
  3. Reduce, control and/or eliminate air emissions of volatile chemicals, corrosives, particulates, aerosols, and combustion products;
  4. Conform to applicable labeling and warning requirements; and
  5. Identify, manage, store, move and handle hazardous substances in accordance with law.

Hazardous Substance Management

To ensure safe handling, movement, storage, recycling, reuse, and disposal, suppliers must identify and manage substances that pose a hazard if released to the environment and comply with applicable labeling laws and regulations for recycling and disposal. Suppliers must post Material Safety Data Sheets in the primary language of its workers for any hazardous or toxic substances used in the workplace and train workers who will come into contact with such substances in the workplace.

Wastewater and Solid Waste Emissions

Wastewater and solid waste generated from operations, industrial processes, and sanitation facilities must be monitored, controlled, and treated as required by applicable laws and regulations before discharge or disposal.

Air Emissions

Air emissions of volatile organic chemicals, aerosols, corrosives, particulates, ozone depleting chemicals, and combustion by-products generated from operations must be characterized, monitored, controlled, and treated as required by applicable laws and regulations before discharge.

Permits and Reporting

Suppliers must obtain, maintain, and keep current all required environmental permits (e.g. discharge monitoring) and registrations and follow the operational and reporting requirements of such permits

Business Integrity and Compliance

Any and all forms of illegal or inappropriate activity, including, but not limited to, corruption, misrepresentation, extortion, embezzlement or bribery, are strictly prohibited and may result in termination of any or all supply agreements with APR Energy and possible legal action. Records prepared for APR Energy, including records of work time and expenses, shall be accurate, truthful and complete, and shall meet applicable standards and requirements. Suppliers must strictly adhere and certify to APR Energy’s Anti-Bribery Compliance Policy, as amended, a current copy of which will be provided upon request.

Conflicts of Interest

APR Energy values the good business relationships that we have with our suppliers and vendors of goods and services, and the substantial contributions made by them to our success. APR Energy will award business based on commercial and other considerations such as: service, competitive pricing, timely delivery, credit worthiness, timely payment, contract performance, quality of material, labor standards, environmental, health, and safety performance, etc.. Supplier financial, business or other related activities must be lawful and free of conflicts with supplier’s responsibilities to APR Energy. We expect our employees to avoid the direct or indirect receipt or solicitation of payments, gifts, entertainment, or other favors from individuals or firms that contradict our policies or present a potential conflict of interest. Further, we expect our employees and current or prospective suppliers to report all personal or family relationships prior to engaging in any business relationship.

Proper Use of Company Assets and Information

Suppliers shall protect and conserve any resources made available by APR Energy and shall use them only for purposes authorized by APR Energy. APR Energy resources include tangible items, such as vehicles, equipment, facilities, consumables, and computer and communication systems, as well as intangible items, such as APR Energy's good name and reputation, employee productivity, and sensitive information.

Suppliers shall respect and not infringe the intellectual property ownership rights of APR Energy and others, including, but not limited to, proprietary information, copyrights, patents, trademarks, and trade secrets.

Suppliers shall protect APR Energy's confidential information and shall not divulge any APR Energy information that a prudent business person would consider sensitive or which is designated as sensitive, proprietary, or confidential. Such information includes, but is not limited to, strategic, personal, financial, or unpatented technology information. Suppliers shall not use or allow the use of such information for securities transactions or any improper private gain. It may be appropriate in some cases for APR Energy and suppliers to agree to additional specific nondisclosure provisions. Suppliers shall not purport to make any announcements or release any information about or on behalf of APR Energy to any member of the public, press, official body, business entity, or other person, or claim or imply any endorsement by APR Energy or APR Energy employees, without the express prior written consent of APR Energy

Accuracy of Business Records

Record and report facts accurately, honestly and objectively. Records must be accurate in all material respects. Do not hide, fail to record, or make false entries. All financial books and records must conform to generally accepted accounting principles.

Fair Competition and Antitrust

Suppliers representing APR Energy are expected to comply with all applicable laws and regulation regarding fair competition and antitrust.

Audits and Inspections

Verification of compliance is subject to audits by APR Energy or a third party designated by or otherwise acceptable to APR Energy. Failure to comply, or failure to work with APR Energy or a third party to correct non-complying situations, are grounds for cancellation of open orders, discontinued use of non-complying production sites, or termination of our business relationship.

Penalties for Non-Compliance

APR Energy reserves the right to terminate its business relationship with any supplier who violates this Supplier Code of Conduct or whose suppliers or subcontractors violate this Supplier Code of Conduct. APR Energy reserves the right to terminate its business relationship with suppliers who fail to provide written confirmation to APR Energy that they have a program in place to monitor their suppliers and subcontractors for compliance with this Supplier Code of Conduct.

It is the responsibility of the supplier to ensure that its representatives understand and comply with this Supplier Code of Conduct and to inform its APR Energy business contact (or a member of APR Energy management) if and when any situation develops that causes the supplier to operate in violation of the code set forth in this document. APR Energy suppliers are expected to self-monitor their compliance with this Supplier Code of Conduct. In addition to any other rights APR Energy may have under its agreement with any supplier, APR Energy may request the immediate removal of any supplier (or employee, agent or subcontractor thereof) who behaves in a manner that is unlawful or inconsistent with this Supplier Code of Conduct or any APR Energy policy.

If you wish to report a questionable behavior or possible violation of this Supplier Code of Conduct, APR Energy has a variety of resources available to assist you. You are encouraged to work with your primary APR Energy contact in resolving a business practice or compliance concern. However, APR Energy recognizes that there may be times when this is not possible or appropriate. In such instances, please contact APR Energy’s compliance hotline at 1 877-237-4362 or, if you are outside the U.S., please dial 904-404-4540. APR Energy will not tolerate any retribution or retaliation taken against any individual who has, in good faith, sought out advice or has reported questionable behavior and/or a possible violation.

Subcontractors

APR Energy expects that its suppliers encourage and work with their own suppliers and subcontractors to ensure that they also strive to meet the principles of this Supplier Code of Conduct or equivalent set of principles.

Conclusion

Supplier warrants that it has read and understands and will comply with the requirements set forth in this Supplier Code of Conduct, as may be reasonably amended from time to time by APR Energy. If the supplier is not able to view this Supplier Code of Conduct online they may request a current copy from purchasing@aprenergy.com. APR Energy reserves the right to cancel any outstanding order, refuse any shipments and otherwise cease to do business with the supplier if the supplier fails to comply with any terms of this Supplier Code of Conduct or if APR Energy reasonably believes supplier has failed to do so. APR Energy exclusively reserves the right to enforce any provisions of this Supplier Code of Conduct or pursue any action that may arise in connection with such enforcement. Supplier retains the sole responsibility to know, understand, and comply with the applicable statutes and regulations necessary to conduct its business. APR Energy is not responsible for providing legal requirements to suppliers.