This Supplier Code of Conduct sets out Johnston Equipment’s principles and expectations as to how organizations who supply goods and services to Johnston Equipment (“Suppliers”), including their representatives and employees, are to conduct business with and deal with us.  If Johnston Equipment believes that a Supplier has violated this Code of Conduct, Johnston Equipment reserves the right to terminate its business relationship with the Supplier. The Supplier shall not retaliate against any person reporting contraventions of this Supplier Code.

1. Compliance with Laws

   In all their activities, the Supplier must ensure it conducts business in compliance with the applicable laws, rules, and regulations of the jurisdictions in which it operates.

    

2. Conflicts of Interest

   The Supplier shall not engage in any activity or provide services to Johnston Equipment where such activity or the provision of such services creates a conflict of interest or perceived conflict of interest.  In their relationship with our employees, the Supplier must not try to gain improper advantage or preferential treatment for other relationships they may have with us (for example, as a client).  The Supplier shall disclose to Johnston Equipment without delay any actual or potential situation that may be reasonably interpreted as either a conflict of interest or a potential conflict of interest.

    

3. Gifts and Entertainment

   Johnston Equipment prohibits giving or accepting gifts or entertainment exceeding nominal value to or from any of its Suppliers unless applicable law prohibits the giving or accepting of gifts or entertainment of nominal value.  This applies to Johnston Equipment employees, agents, contractors and each of their immediate family members.  The following types of gifts and entertainment may never be offered regardless of the value: cash or cash equivalent ( i.e. gift cards, loans or guarantees of any kind) , personal services, hospitality such as free hotel rooms or borrowed assets, any gifts that could be illegal, any gift or entertainment offered to gain improper advantage or preferential treatment.  This policy does not change during traditional gift-giving seasons.

    

4. Anti-Corruption, International Trade and Anti-Trust

   The Supplier must not engage in any conduct that would put it, or Johnston Equipment, at risk of violating anti-bribery or anti-corruption laws. Suppliers must maintain integrity, transparency and accuracy in all records. The Supplier must also comply with all applicable economic sanctions and embargo laws, as well as export controls and customs laws. The Supplier shall not engage in predatory pricing or price-fixing and shall not threaten retaliatory action against a competitor, and shall abide by all relevant antitrust and competition laws.

    

5. Employment Practices

   The Supplier must abide by applicable employment standards, labour, non-discrimination and human rights legislation.  

   Suppliers must be able to demonstrate that, in their workplaces and in their supply chains:

   • Child labour and forced labour is not used, including work or services not voluntarily performed or performed by employees below the applicable minimum age of work in the jurisdiction of operation, and that work is provided with pay and benefits in a timely manner and with minimum wage and overtime pay requirements.
   • All workers have clear and understandable employment documentation, outlining worker terms and conditions and their rights and responsibilities.
   • Discrimination and harassment are prohibited, including discrimination or harassment based on any characteristic protected by law.
   • Employees are free to raise concerns and speak up without fear of reprisal.
   • Appropriate and reasonable background screenings, including investigations for prior criminal activity, have been done to ensure the integrity and good character of the Supplier’s Employees.
   • Clear and uniformly applied employment standards are used that meet or exceed legal and regulatory requirements.

    

6. Supply Chain Transparency

   Johnston Equipment expects the Supplier to respect and support internationally recognized human rights movements and to contribute to minimizing social/economic and environmental risks. When sourcing materials, including minerals, the Supplier must not benefit from or facilitate, directly or indirectly, any human rights violations or abuses.

    

7. Environmental, Sustainability, Governance, Equity and Diversity

   The Supplier shall maintain industry best practices with regards to environmental, sustainability and governance, and incorporate industry best practices in respect of equity and diversity initiatives, including by:

   • integrating diverse suppliers into their supply chain so their own supplier base reflects the diversity of society.
   • maintaining a safe, clean, and healthy workplace, complying with all occupational health and safety laws.
   • continuously improving its safety performance by regularly reviewing and updating their safety programs to remain compliant with legal and industry standards.
   • supporting the right to free association and collective bargaining, in line with relevant laws.
   • minimizing environmental impact, comply with environmental laws, and adopt necessary practices, including by providing environmental training to employees.
   • undertaking actions to prevent pollution and lower greenhouse gas emissions and managing, reducing, recycling or disposing of waste in accordance with applicable laws and standards.
   • engaging in rational resource use, and material conservation, recycling, or reuse initiatives.
   • Protecting its information and data and that of Johnston Equipment and maintaining industry best practices for the protection of personal information and for the respect of individual privacy.

    

8. Application to Upstream Suppliers

The Supplier shall hold its own suppliers to the same high standards it holds itself.

This Supplier Code of Conduct has been acknowledged and accepted.

Name:                   ______________________

Company Name: ______________________

Title:                      _______________________

Signature:            _______________________