Supplier Code of Conduct

Last Updated: December 18, 2023

POLICY STATEMENT

CarbonCure Technologies Inc. and its affiliates’ (collectively, “CarbonCure”) mission is to, together with its concrete producer and carbon credit partners, reduce and remove CO2 in the concrete industry through its various technologies. We strive to build environmental, social, and governance (ESG) performance across all our operations to help build sustainable, equitable, healthy, and diverse communities.

The provisions of this Code of Conduct are derived from globally recognized standards such as the Universal Declaration of Human Rights, the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work, the United Nations Global Compact Principles, and the OECD Guidelines for Multinational Enterprises among others. Through this Code of Conduct, CarbonCure seeks to ensure that internationally recognized principles and standards are respected along our value chain.

APPLICABILITY

This Code of Conduct establishes the guiding policies for all current and future Suppliers and, unless otherwise stated, applies with respect to business between such Suppliers and CarbonCure.

The term “Supplier(s)” covers any natural person or legal entity (excluding employees of CarbonCure) that supplies goods or services to or on behalf of CarbonCure, represents CarbonCure or who or which otherwise agrees to comply with this Code of Conduct. To the extent that the employees, personnel, agents, subcontractors, and sub-tier suppliers of a Supplier participate in business to which this Code of Conduct applies, such Supplier shall require and be responsible for their compliance with this Code of Conduct as if such persons were the “Supplier” under this Code of Conduct.

Under this Code of Conduct, Suppliers commit to comply with all “applicable law and standards”. Unless otherwise stated, such applicable law and standards includes all applicable local, national, and international laws, rules and regulations, international and local industry standards, and environmental, social and governance (ESG) standards including those referenced above. Our Code of Conduct policies are as follows:

HUMAN RIGHTS

CarbonCure is committed to preserving and promoting the protection of human rights within our own business activities.

Prohibition of slavery, human trafficking & forced labor practices:

Suppliers shall not compel anyone to work or enter into an employment relationship by force, duress, or intimidation. Suppliers shall not force anyone to continue to work by withholding pay, employee benefits, property, or documents such as passports. Suppliers shall not traffic persons or use any form of bonded, slave or prison labour.

Prohibition of child labour practices:

Supplier shall ensure that Child labour is strictly prohibited in all its operations and supply chain. “Child” refers to a person younger than the minimum age for employment as specified under applicable law and standards. In the event there is no statutory minimum age, the employee shall not be younger than the minimum age defined by the International Labour Organization (ILO).

Working Conditions:

Suppliers shall treat all employees fairly with respect, dignity, and integrity. Suppliers shall not discriminate based on sex, race, color, gender identity, disability, gender orientation, or any other status protected by law, ordinance, or regulation. 2 Working Hours and Adequate Compensation: Suppliers shall adhere to wage and hour laws applicable in the jurisdiction in which they operate and where their employees reside, including, but not limited to, laws related to ensure that working hours do not exceed the maximum hours worked, overtime, paid leave, and other benefits number prescribed by applicable law and standards.

Freedom of Association:

Suppliers shall grant their employees the right of association to protect or represent their interests collectively in accordance with the applicable law and standards. Suppliers shall encourage direct communication about employee working conditions without harassment, fear of intimidation, or reprisal.

HEALTH & SAFETY

Suppliers shall provide a safe and healthy working environment and comply with applicable health and safety laws and standards as well as maintain operations, training, procedures, and programs, as required by applicable law and standards.

Safe handling of materials: Suppliers shall abide by applicable law and standards in minimizing the risk of injury to employees and persons when engaged in business activities related to CarbonCure. This includes employee training to prevent accidents and health damage and the provision of appropriate protective gear.

Emergency response protocol: Suppliers shall also ensure that emergency response protocols are in place in the event of an incident.

ENVIRONMENT

We are committed to minimizing our impact on the environment through all our business operations as we work to promote sustainability along our value chain.

Emissions Control Policy: CarbonCure encourages its Suppliers to be sensitive to their impact on the environment by complying with applicable law and standards, such as the Greenhouse Protocol (GHG) standards, pertaining to the accounting and reduction of greenhouse gases and other harmful emissions.

Anti-Pollution and Wastage: Suppliers are encouraged to minimize the wastage of water, energy and other natural resources and prevent release of any form of toxic and hazardous pollutants that could have an adverse impact on the environment.

BUSINESS ETHICS

Anti-Corruption: Suppliers shall comply with anti-corruption provisions under applicable law and standards in all business dealings. Suppliers shall make every effort to ensure that they do not, nor appear to, make improper payments or gifts to government or political officials involved in the oversight of, or having influence over, the business activities of CarbonCure.

Conflict of Interest: Suppliers shall ensure that they are not involved in any activity that creates a conflict of interest, or the appearance of a conflict of interest, that brings into question their relationship with CarbonCure.

Fair Competition: Suppliers shall comply with applicable law and standards pertaining to fair competition and competitive practices.

Privacy & Confidentiality: Suppliers shall comply with applicable privacy, data protection, and information security laws and standards.

Suppliers shall comply with confidential information covenants made to CarbonCure. Suppliers are expected to adhere to this Code of Conduct. If CarbonCure determines the Supplier violated these principles, CarbonCure may demand corrective action or terminate its relationship with the Supplier.

CONCERNS/INQUIRIES

Questions or concerns regarding this Code of Conduct may be directed to legal@carboncure.com.