As a condition of doing business with MHD-ROCKLAND-ROCKLAND, we expect all suppliers to operate in a manner which meets or exceeds our minimum requirements and to be able to demonstrate that suitable measures are in place to meet our ethical minimum requirements.

MHD-ROCKLAND’s minimum requirements are informed by applicable laws, international and industry standards, MHD-ROCKLAND’s business needs and our stakeholders’ expectations.

Compliance with this Supplier Code of conduct (“Code”)is an important criterion which is taken into consideration in MHD-ROCKLAND’s supplier selection process.

If a supplier is unable to demonstrate compliance with this Code or fails to meet minimum requirements, MHD-ROCKLAND reserves the right to pursue appropriate action, including remediation or termination of the business relationship with the supplier.

This Code applies to MHD-ROCKLAND’s product and services suppliers, consultants, agents and representatives (each a “Supplier” and collectively the “Suppliers”).

Minimum Requirements

All our Suppliers must:

• Comply with all relevant laws and regulations.
• Comply with MHD-ROCKLAND’s Environmental Social and Governance (ESG) requirements as set out in this Code.
• Respond to requests for information from MHD-ROCKLAND in a timely manner, including but not limited to questionnaires, interviews, site visits, audits and corrective action plans.
• Provide a true and accurate account of their operations and supply chain when responding to requests for information from MHD-ROCKLAND.
• Promptly advise MHD-ROCKLAND of any non-compliance with this Code.
• Implement processes which allow for workers to report non-compliance with this Code, anonymously and free of retribution or other unfavorable treatment.
• Remedy any non-compliance with this Code as a matter of highest priority.

SOCIAL EXPECTATIONS

At MHD-ROCKLAND, we respect human rights and are committed to preventing and ending all forms of modern slavery, child labour and human trafficking in our supply chain.

We expect our Suppliers to manage their operations and supply chain in a manner that upholds the United Nations’ (UN)Universal Declaration of Human Rights, the UN Guiding Principles on Business and Human Rights and the International Labour Organisation’s (ILO) Core Conventions.

Forced Labour

Our Suppliers cannot make use of modern slavery practices in their operations or supply chain. Modern slavery includes human trafficking, forced labour, slavery, servitude, debt bondage, child labour, forced marriage or deceptively recruiting workers for labour or services. Workers must not be required to submit deposits or government-issued identity documents (such as passports) to be held as a condition of employment.

Suppliers must actively support the abolition of forced labour and modern slavery by taking measures to identify and mitigate modern slavery risks along their supply chain.

Child Labour:

Our Suppliers must not employ children below the minimum legal working age where the work is undertaken;use children in modern slavery practices. Suppliers must not require children to engage in hazardous work which may cause harm to their health, safety or morals.

Worker Entitlements

Suppliers must provide workers with entitlements in compliance with relevant labour laws and applicable industrial instruments, in the country where the work is undertaken. Suppliers must ensure that workers are correctly engaged and classified as either employees or independent contractors and treated as such, and that all legal obligations due to the worker are satisfied.

Sub-contractors

Suppliers must keep a register of sub-contractors. This register must be made available to MHD-ROCKLAND, on MHD-ROCKLAND’s request.

Freedom of Association

Suppliers must ensure that workers’ rights to freedom of association and collective bargaining are respected, and that workers have the right to form and join trade unions, in accordance with local laws.

Inhumane Treatment

Suppliers must ensure that workers are not subjected to corporal punishment, physical abuse or discipline, verbal or mental abuse, sexual abuse or any type of exploitation.

Discrimination, Harassment and Bullying

At MHD-ROCKLAND, we are committed to providing a workplace free from discrimination, harassment and bullying.

We expect our Suppliers to:

• Comply with workplace laws in respect of discrimination, harassment and bullying in their operations and supply chain.
• Have and uphold reasonable standards of behavior in the workplace which apply to all workers.
• Ensure work environments are inclusive and recruitment and employment practices are free from discrimination based on age, religion, culture, ethnicity, gender, sexual orientation, marital status, family responsibilities, disability or health status of workers, in accordance with law.

Safety Culture

At MHD-ROCKLAND, we provide a healthy and safe workplace that strives for a proactive safety culture.

We expect our Suppliers to:

• Comply with relevant laws in respect of Work Health and Safety in their operations and supply chain.
• Ensure that work environments and accommodation, where applicable, are safe and hygienic.
• Have processes in place to prevent and minimize health and safety risks.
• Inform MHD-ROCKLAND immediately of any workplace deaths due to poor workplace practices and provide details of workplace incidents, at MHD-ROCKLAND’s request.

Diversity

MHD-ROCKLAND promotes and seeks diversity across its supply base.

We expect our Suppliers to promote and increase supplier diversity within their organization and supply chain by seeking equitable, mutually-beneficial opportunities with a broad range of businesses, for example: small and medium-sized enterprises (SMEs), social enterprises, women owned businesses, businesses that support and employ people with disabilities, LGBTIQA+ owned businesses and Indigenous businesses.

ENVIRONMENTAL EXPECTATIONS

At MHD-ROCKLAND, we care for our environment and are committed to a sustainable future.

Consequently, all our Suppliers must:

• Comply with relevant environmental protection laws, regulations and standards.
• Establish programs that seek to reduce the environmental impact of their operations and supply chain.

GOVERNANCE EXPECTATIONS

Fraud, Bribery and Corruption

At MHD-ROCKLAND, we do not tolerate behavior that is dishonest, illegal, fraudulent, corrupt or unethical.

We expect our Suppliers

• to employ reasonable measures and controls to ensure that their workers and Suppliers do not commit fraud, bribery or corruption, or become involved in such activities.
• Keep accurate records and ensure that information provided to MHD-ROCKLAND is a true and accurate reflection of their operations, supply chain and business dealings.

Ethics and Conduct

At MHD-ROCKLAND, we fulfil our purpose in accordance with the highest standards of ethics and conduct.

We expect our Suppliers to:

• Ensure that they do not source goods or services on behalf of MHD-ROCKLAND from any country, entity or persons subject to internationally-recognized trade sanctions.
• Disclose any actual, potential or perceived conflicts of interest in respect of their dealings with MHD-ROCKLAND.
• Avoid offering or receiving gifts, entertainment or travel that could affect, or be seen to affect, their dealings with MHD-ROCKLAND.
• Pay their workers, Suppliers and sub-contractors fairly and on time, in accordance with applicable laws and agreements.

REPORTING A CONCERN OR ISSUE

For any questions, concerns, or if any ethical or compliance issues arise, Suppliers have the responsibility to bring them forward by contacting MHD-ROCKLAND:

By mail: MHD-ROCKLAND Inc.

   Atthention: Ethics & Conduct Officer

   21250 Industrial Blvd.

   Sainte-Anne-de-Bellevue, Quebec Canada

   H9X 0B4

By email: info@mhdrockland.com

By phone: 514.453.1632