Supplier Code of Conduct

BRC, Inc. expects its suppliers and business partners to maintain responsible practices throughout every stage of the supply chain. The Supplier Code of Conduct establishes fundamental expectations for companies that manufacture, distribute, provide, or otherwise support products and services connected with the business. These expectations cover ethical conduct, labor conditions, worker health and safety, environmental protection, product standards, and responsible sourcing. Suppliers may also be subject to additional requirements depending on the materials, products, services, or operational risks involved in their relationship with the Company.

Suppliers are expected to make these requirements understandable and accessible to their workers. Appropriate steps should be taken to communicate the standards through workplace postings, employee education, training sessions, or other suitable methods. Any expenses associated with translating, preparing, distributing, or displaying the required information are generally the responsibility of the Supplier. The standards extend beyond direct employees and may apply to temporary personnel, migrant workers, contractors, agency workers, subcontractors, and other individuals involved in the Supplier’s operations.

Responsibility for compliance also extends to the Supplier’s own business partners. Suppliers should take reasonable measures to ensure that subcontractors and other parties within their supply networks follow comparable standards. Compliance expectations may involve manufacturing, packaging, distribution, marketing, sales, certifications, immigration practices, intellectual property, environmental controls, workplace safety, and product quality. Suppliers should maintain sufficient records to demonstrate that these requirements are being followed and should cooperate with reasonable reviews, assessments, facility visits, or other verification activities conducted by the Company or its representatives.

Employees and other individuals should have appropriate channels for reporting suspected misconduct or violations. Concerns raised honestly and in good faith should be handled without retaliation. Suppliers must not punish, threaten, intimidate, discriminate against, or otherwise disadvantage individuals because they have reported a legitimate concern. Effective grievance systems should allow workers to communicate problems and receive appropriate follow-up.

All suppliers are expected to comply with laws and regulations applicable to their activities. This includes requirements related to labor, environmental protection, workplace safety, trade, sanctions, export controls, competition, antitrust matters, privacy, and other areas governed by local or international rules. When different standards apply, Suppliers should follow the legally permissible requirement that offers stronger protection when the Code calls for a higher level of protection.

Ethical business conduct is a core expectation. Bribery, corruption, kickbacks, extortion, embezzlement, and similar improper conduct are not acceptable. Suppliers should establish appropriate internal controls and provide personnel with sufficient guidance to recognize and prevent prohibited behavior. Gifts, entertainment, hospitality, or other benefits involving Company personnel must remain appropriate and reasonable and must never be provided for the purpose of improperly influencing a business decision. Cash or comparable benefits intended to secure an unfair commercial advantage are prohibited.

Suppliers must also maintain practices designed to prevent money laundering and other unlawful financial activity. Business transactions should have legitimate commercial purposes and involve lawful sources of funds. Internal controls should be sufficient to identify suspicious activity and reduce the possibility of prohibited transactions. Suppliers must not knowingly participate in activities involving criminal proceeds or the financing of terrorism.

Trade sanctions and export-control rules must be respected in all applicable transactions. Suppliers should maintain appropriate screening procedures to identify restricted individuals, organizations, countries, or other prohibited parties. Company resources must not be used to benefit sanctioned parties, and Suppliers should take reasonable steps to prevent their business activities from creating violations of applicable restrictions.

Potential conflicts of interest should be identified and disclosed. Suppliers and their representatives are expected to avoid relationships or circumstances that could interfere with impartial business judgment or create a reasonable appearance of improper influence. Ownership interests, personal relationships, or other connections involving Company personnel should be disclosed when they could affect the business relationship. Where required, contracts or Company arrangements may not be assigned or subcontracted without prior written approval.

Confidential information and intellectual property must be protected. Suppliers may only use Company trademarks, designs, trade names, confidential materials, and other intellectual property for authorized business purposes. Sensitive information must not be disclosed to unauthorized parties. Suppliers may also be required to maintain traceability for key materials, including information concerning their country of origin, production facilities, regulated substances, or other supply-chain details requested by the Company.

Insider trading is prohibited when a Supplier or its personnel possess material nonpublic information obtained through their business relationship. Such information must not be used to trade securities or communicated to unauthorized individuals. Suppliers should ensure that employees and relevant family members understand the restrictions surrounding confidential corporate information.

Employment practices must respect fundamental worker rights. Forced labor in any form is prohibited, including bonded labor, debt-based work, involuntary prison labor, slavery, human trafficking, and other forms of compulsory employment. Workers should be free to leave their jobs without unlawful threats, penalties, financial obligations, retaliation, or unreasonable restrictions. Suppliers are responsible for monitoring their operations and supply networks to reduce the risk of forced labor.

Child labor is also prohibited. Suppliers must follow applicable minimum-age requirements and take measures to protect younger workers. Individuals below eighteen should not be assigned dangerous duties or prohibited work schedules where applicable laws or recognized standards restrict such employment. Employment practices should not interfere with a young person’s education, health, development, or general welfare.

Workers should be able to exercise legally protected freedom of association and collective bargaining rights. Suppliers must not interfere with employees who choose to organize, join worker associations, participate in collective bargaining, or lawfully decline such participation. Discrimination, punishment, intimidation, or retaliation related to these activities is not acceptable.

Compensation must meet applicable legal requirements. Employees should receive wages and benefits accurately and on a regular schedule, with understandable information explaining how compensation is calculated. Improper deductions are prohibited unless specifically permitted by law. Requirements concerning wages should also be observed during legally covered apprenticeship, training, probation, or similar employment periods.

Working hours must remain within applicable limits. Suppliers should maintain dependable systems for recording working time, overtime, breaks, and rest periods. Employees should receive legally required meal and rest opportunities, and working schedules should be monitored to ensure that excessive or unlawful hours do not become routine.

Every worker should be treated with dignity. Physical punishment, threats, intimidation, sexual harassment, sexual abuse, verbal mistreatment, psychological abuse, and other forms of workplace harassment are prohibited. Suppliers should take preventive measures and ensure that comparable expectations apply to relevant contractors, subcontractors, and other business partners.

Employment decisions should be based on legitimate qualifications and job requirements rather than unlawful discrimination. Recruitment, compensation, promotion, training, discipline, termination, retirement, and other employment decisions should comply with applicable equality and anti-discrimination laws. Suppliers must also maintain responsible recruitment practices and comply with requirements concerning worker movement, trafficking, and employment eligibility.

Workers should have reasonable freedom to leave the workplace when their shift ends and when legitimate health, safety, personal, or family circumstances require it. Suppliers must not use threats, unlawful financial penalties, retaliation, or unreasonable controls to restrict this freedom.

Safe and sanitary workplaces are another essential requirement. Facilities should provide suitable emergency exits, fire protection, first-aid supplies, lighting, ventilation, sanitation, drinking water, protective equipment, and appropriate safety procedures. Employees should receive training regarding hazards associated with their duties and should have accessible methods for reporting unsafe conditions. Where legally protected, workers should also be able to refuse tasks presenting an immediate and legitimate safety danger.

Supplier-provided housing must meet appropriate safety and sanitation standards. Where accommodation is offered, workers should have access to clean water, suitable restrooms, safe food preparation and storage areas, and appropriate spaces for eating. Buildings and operational facilities should satisfy applicable construction, zoning, fire, occupancy, and safety requirements. Emergency routes must remain accessible and clearly identified, while evacuation procedures, fire systems, emergency lighting, first-aid resources, and required safety documentation should be properly maintained.

Environmental responsibility is also incorporated into responsible sourcing expectations. Suppliers should work to reduce unnecessary energy and water consumption, control waste, prevent pollution, and limit harmful effects associated with their activities. Applicable requirements concerning emissions, wastewater, hazardous materials, waste disposal, and environmental protection must be followed. Chemicals and other dangerous substances should be properly identified, stored, transported, used, and disposed of, with appropriate worker training.

Products, packaging, components, and materials supplied to the Company should meet applicable environmental, safety, and quality requirements. Suppliers are encouraged to evaluate the environmental effects of their operations and pursue reasonable improvements in resource efficiency. Reducing harmful impacts can help protect workers, surrounding communities, and the ecosystems affected by production activities.

Suppliers should maintain effective systems for receiving and resolving worker complaints. Reporting mechanisms may include confidential or anonymous options where appropriate, and employees should understand how these channels can be accessed. Complaints should be reviewed fairly and addressed within a reasonable timeframe.

The Company may conduct inspections, audits, assessments, monitoring activities, or other reviews to evaluate compliance. When shortcomings are identified, Suppliers may be required to implement corrective measures such as additional training, improved documentation, operational changes, or other remediation. Serious or unresolved violations may affect the continuation of the commercial relationship and could result in the termination of applicable contracts or purchasing arrangements.

Suppliers should maintain accurate records concerning matters such as worker age, employment eligibility, status, and other required compliance information. Employees should retain possession of their original identity and immigration documents. Suppliers must not require workers to surrender passports, birth certificates, work authorization papers, or similar original documents as a condition of employment.

Workers should not be burdened with unlawful recruitment costs. Suppliers must not impose prohibited recruitment fees, financial guarantees, unlawful debts, or similar obligations on employees or their families as a condition of obtaining or maintaining employment.

The Supplier Code operates together with contractual obligations, applicable laws, and other policies governing the business relationship. Meeting the Code does not eliminate any additional responsibilities established through contracts or legal requirements. Suppliers are expected to monitor their operations continuously, identify emerging risks, address deficiencies promptly, and maintain responsible practices throughout their supply chains.