RITE-HITE HOLDING CORPORATION COMPLIANCE STANDARDS

Introduction

Rite-Hite Holding Corporation and its subsidiaries, affiliates and employees are committed to the highest standards of integrity, ethics and performance relating to social responsibility and compliance. Below is a list of standards that outlines Rite-Hite’s expectations of its Suppliers and Business Partners. This policy is not a comprehensive document intended to address every issue that Suppliers and Business Partners may encounter nor is it a summary of all laws and policies that apply to Rite-Hite’s business.

1. Compliance with Laws

Suppliers and Business Partners and their designated manufacturing facilities and subcontractors must at a minimum fully comply with all applicable national and/or local laws and regulations in the countries where the Suppliers and Business Partners operate, including but not limited to those related to labor, immigration, health and safety, and the environment. In addition to laws and regulations pertaining to labor, immigration, health and safety, and the environment, compliance with laws and regulations extends to other matters such as intellectual property rights, documentation and certifications. Suppliers and Business Partners shall also comply with all U.S. laws applicable to nations or parties on denied party lists or debarment lists and compliance with any applicable U.S.-imposed sanctions.

2. Voluntary Labor

All labor must be voluntary. Child (workers under the age of 14 regardless of local and national regulations), underage, forced, bonded, slave or indentured labor will not be tolerated. Suppliers and Business Partners must ensure that they provide workers with rest days and must ensure that working hours are consistent with regulation and not excessive. Rite-Hite will refrain from purchasing products from or otherwise do business with companies whose products are made utilizing underage, forced, bonded, indentured, trafficked or slave labor. On an ad hoc basis, or in response to an allegation, Rite-Hite will (or, if the circumstances dictate, retain an independent third party) to audit Suppliers and Business Partners to evaluate and address such risks. On an ad hoc basis, or in response to an allegation Rite-Hite may require its Suppliers or Business Partners to certify that materials incorporated in its products complies with applicable law regarding voluntary labor. Rite-Hite shall cease conducting business with Suppliers and/or Business Partners who are found to provide product or materials that fail to comply with the laws of the country or countries in which they are doing business. Additionally, as needed, Rite-Hite will provide company employees and management, who have direct responsibility for supply chain management, training on human trafficking and slavery, particularly with respect to mitigating risks within the supply chains of our products.

3. Employment Practices

Suppliers and Business Partners must implement employment practices that provide an equal opportunity for all workers including but not limited to recruiting, hiring, training, job assignment, pay, benefits, promotion, discipline, termination or retirement. Discrimination based on gender, age, religion, marital status, race, social background, diseases, disability, pregnancy, ethnic or national origin, nationality or any other personal characteristic is strictly prohibited.

4. Health, Safety & Environmental

Suppliers and Business Partners must provide workers with a safe and healthy work environment and must take proactive measures to prevent workplace hazards. Suppliers and Business Partners must ensure that their operations comply with national and local environmental laws.

5. Anti-Corruption

Suppliers and Business Partners must not tolerate, permit or engage in bribery, corruption, or unethical practices whether in dealings with public officials or individuals in the private sector. Suppliers and Business Partners may not promise, offer or pay anything of value to a government official or political party to obtain or retain business or secure an improper advantage on behalf of itself or Rite-Hite. Suppliers and Business Partners may not promise, offer or pay anything of value to any business or any individual in the private sector to obtain or retain business or secure an improper advantage on behalf of itself or Rite-Hite.

6. Financial Integrity

Suppliers and Business Partners must keep accurate records of all matters related to their business with Rite-Hite in accordance with standard accounting practices.