Arcadia Vendor Code of Conduct

Arcadia Power Inc. and its affiliates (“Arcadia”) seeks to foster a culture in which our vendors reinforce our values, and we expect our vendors to operate in compliance with the principles outlined in this Vendor Code of Conduct (this “Code”).

The term “Vendors” (individually, a “Vendor”), as used in this Code, means any affiliate, subsidiary, employee, agent, supplier, subcontractor or other representative of an entity that provides goods or services to, or on behalf of, Arcadia. The provisions of this Code are in addition to those specified in any agreement between a Vendor and Arcadia.

1. Employment and Labor Human Rights.

a. Vendors shall (i) treat all of their workers fairly and with dignity, (ii) adopt an approach to human rights consistent with the United Nations Universal Declaration of Human Rights, (iii) support and respect the protection of internationally proclaimed human rights, and (iv) ensure that they are not complicit in human rights abuses.

b. Freedom of Association. Where legally authorized, Vendors shall respect their employees’ rights to join or form trade unions and to bargain collectively, or to conduct similar activities.

c. Employment Practices. Vendors shall not (i) use any form of slave, forced, bonded, indentured or involuntary labor, and shall fully comply with all laws that prohibit the use thereof, as and when applicable, (ii) engage in human trafficking or exploitation, (iii) import goods tainted by slavery or human trafficking, or (iv) retain employees’ government-issued identification, passports or work permits as a condition of employment.

d. Anti-discrimination, Diversity. Vendors shall provide a workplace free of harassment and discrimination in which their employees are treated fairly and respectfully. In the United States, Vendors shall make good faith efforts to identify and, where available and appropriate, use suppliers certified as minority, women, disabled person, lesbian, gay, bi-sexual, transgender and/or U.S. veteran-owned.

e. Underage Labor. Vendors shall not use underage labor as defined by applicable law regulating minimum legal age to work. Workers below the age of 18 shall not be employed in jobs that are likely to jeopardize the health and safety of young workers.

f.  Employment Status. Vendors shall employ only workers who are legally authorized to work in their location. Vendors are responsible for validating employees’ work eligibility status.

g. Compensation and Working Hours. Vendors shall provide all workers with accurate information about their wages, mandated benefits and any other basis of their compensation. Vendors shall comply with applicable labor laws governing working hours and employee compensation in all locations in which they operate.

2. Business Integrity.

a. Anti-corruption.  Vendors shall exercise high standards of integrity in business interactions, and all of their business dealings shall be accurately reflected in their books and records in accordance with applicable laws. Vendors shall implement appropriate procedures designed to prevent bribery, corruption, kickbacks and embezzlement.

3. Data and IP.

a. Intellectual Property and Software. Vendors shall respect all intellectual property rights and software licensing obligations and use technology only in a manner that protects, and is in compliance with, the owner’s intellectual property rights.

b. Privacy. Vendors shall comply with privacy and information security laws and regulatory requirements relating to the collection, storage, processing, transfer and sharing of personal information. Vendors shall safeguard the privacy of the personal information of their customers and employees.

c. Whistleblower Protection and Anonymous Complaints. Vendors shall protect the confidentiality of their whistleblower employees, prohibit retaliation, and, where legally permitted, provide an anonymous complaint mechanism for their employees to report grievances.

4. Gifts, Meals and Entertainment. Vendors shall not provide any gift, meal or entertainment to an Arcadia employee in any situation which might improperly influence, or appear to improperly influence, such employee’s decision in relation to a Vendor.

5. Responsible Sourcing of Minerals. To the extent applicable, Vendors shall comply with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict Affected and High-Risk Areas and any domestic laws related to such guidance.

6. Health and Safety. Vendors shall: (i) provide their employees with a safe workplace, (ii) have reasonable procedures to detect, prevent and handle potential risks to the health, safety and security of employees, and (iii) follow all applicable laws relating to health and safety in the workplace.

7. Environment.  Vendors shall operate in an environmentally responsible manner, strive to minimize adverse impact on the environment and comply with all environmental laws in the countries in which they operate. 

8. Reporting.  If a Vendor becomes aware of or suspects misconduct relating to services rendered to or on behalf of Arcadia, or a violation of this Code, then Vendor will report it to the appropriate Arcadia procurement contract, or via webform at www.lighthouse-services.com/arcadia, or by telephone to one of the following numbers:

Toll-Free Telephone:

o   English speaking USA and Canada: 855-222-5172

o   Spanish speaking USA and Canada: 800-216-1288

o   Spanish speaking Mexico: 01-800-681-5340

o   French speaking Canada: 855-725-0002