Supplier Code of Conduct

Mahoney Environmental Solutions’, a Neste company, Supplier Code of Conduct is the cornerstone of everything we do.

We believe that ethical work is also successful work. Our goal is to operate ethically, with integrity, and in compliance with the law, always and everywhere. Bribery and corruption in any form are unacceptable in our business.

Our business partners and other stakeholders may report observed or suspected violations of the Code of Conduct (anonymously and confidentially) by using Neste Ethics Online. Here’s how to report a concern by calling 1-866-2506706 or Reporting via Ethics Online. The Access Code is 64884.

___________________________________________________________________________________________________________________________

SUPPLIER CODE OF CONDUCT       1.1.2025

1. Introduction

1.1 Mahoney is a part of the corporate family of Neste Corporation, a global renewable fuel producer. Our vision is to create responsible choices every day. In addition to providing responsible solutions to customers, our vision means that we always carry out our business with integrity and in line with ethical standards expressed in our Supplier Code of Conduct (“Code”). Responsible sourcing plays a significant role in achieving the vision. Our commitments to responsible and ethical business depend not only on our own people but also upon forming relationships with suppliers who share our commitments.

1.2 This Code outlines requirements for Mahoney’s suppliers, aggregators, vendors, and lessors to comply with in their business transactions with Mahoney and in business interactions with their own employees, suppliers and other stakeholders.

1.3 In this Code, “Supplier” means any individual or legal entity which provides Mahoney with products, components, materials, services, or leaseholds. The definition of “Supplier” also includes Supplier’s own 1st tier suppliers, contractors and other business partners participating in the delivery of products, components, materials or services to Mahoney.

1.4 Supplier shall ensure that its own 1st tier suppliers, contractors and other business partners participating in the delivery of products, components, materials and services to Mahoney comply with the minimum requirements set out in this Code, and that this Code is communicated by Supplier to them.

2. Compliance with laws and regulations

Supplier shall comply with all applicable laws and regulations applicable to its operations. Should a requirement of this Code contradict national laws or regulations, Supplier shall comply with whichever is more stringent.

3. Business Conduct

3.1 Zero tolerance for corruption

Mahoney expects Supplier to have zero tolerance towards bribery and corruption. Mahoney requires that Supplier shall have standards and procedures in place to ensure that its directors, employees and third parties acting on its behalf do not offer, promise, give or accept any bribes, or make or accept improper payments (such as facilitation payments or kickbacks) to obtain new business, retain existing business, or secure any other improper advantage. Supplier shall not provide Mahoney employees with any gifts or hospitality in any situation in which said gifts or hospitality might influence, or appear to influence, employee’s decision in relation to Supplier.

3.2  Competing fairly

Supplier shall compete in a fair manner in compliance with all applicable antitrust laws and regulations and shall have standards and procedures in place to ensure that its directors and employees do not engage in any anti-competitive practices.                

3.3 Compliance with anti-money laundering and privacy rules and trade sanctions

Supplier shall comply with all applicable laws and regulations on anti-money laundering and privacy and on all applicable economic and trade sanctions.

3.4 Avoiding conflicts of interests

Supplier shall avoid any situations where a conflict of interest between Supplier and Mahoney exists including interactions with a Mahoney employee that could create a conflict of interest with Mahoney employee’s duty to act in the best interest of Mahoney. Supplier shall disclose to Mahoney any potential or existing conflict of interest situation in its relationship with Mahoney.

4. Human and labor rights

Mahoney respects the rights enshrined in the International Bill of Human Rights and the ILO Declaration on Fundamental Principles and Rights at Work. Supplier is also expected to respect these rights, and comply with applicable human and labor rights laws including, at a minimum, that it shall:

4.1 adhere to applicable laws regarding working hours, minimum wages, overtime, sufficient breaks and rest time, sick leave and annual holidays, as well as parental leave and mandatory benefits (e.g. social security), and have appropriate records of these in place;

4.2 ensure that all employees are made aware of the key terms of their employment prior to commitment to work;

4.3 not employ workers younger than 15 years of age, or younger than 13 years for tasks considered light work (work that is not harmful to the health or development of the child and does not interfere with their education) nor employ workers under the age of 18 in hazardous work, and establish systems to ensure fulfillment of and follow-up on these requirements;

4.4 not use any compulsory or forced labor, and ensure that recruitment fees and associated costs are not borne by workers;

4.5 provide equal opportunity and treatment in employment to all protected classes under applicable law and without regard to race, color, religion, sex, political opinion, national extraction, social origin or any other similar distinction which is not based on the inherent requirements of the work;

4.6 not tolerate any type of harassment of its employees whether direct or indirect, physical or verbal; and

4.7 recognize and respect employees’ right to organize freely and bargain collectively.

5. Occupational health, safety and security

Supplier shall provide its employees with a healthy, safe and secure workplace in compliance with all laws and regulations applicable to its operations. At a minimum, Supplier shall:

5.1 ensure that appropriate health and safety information and equipment are provided to its employees and contractors;

5.2 provide employees and contractors with drinking water, clean toilets, adequate ventilation, emergency exits, proper lighting and access to first aid supplies or other provision for emergency care; and

5.3 if working at Mahoney’s premises, comply with Mahoney’s health and safety requirements to the extent separately agreed with Mahoney.

6. Environmental impact and climate change

Supplier is encouraged to establish and implement procedures to minimize any adverse impact of its operations on the environment and to demonstrate continuous improvements therein. At a minimum, Supplier shall, in its operation:

6.1 fulfill applicable environmental requirements set forth in relevant laws, regulations and environmental permits in the jurisdiction where Supplier operates;

6.2 monitor, control and appropriately treat wastewater, air emissions and waste generated from its operations including, without limitation, the treatment of hazardous waste, in compliance with applicable legislation and process manufacturer’s instructions; and

6.3 consider the climate impact of its operations and undertake greenhouse gas reduction measures where reasonable.

7. Reporting

7.1 Suspected violations of the Code can be reported by using Neste Ethics Online at: https://www.neste.com/sustainability/sustainability-at-neste/code-of-conduct/report-concern. Such reporting may be also done anonymously and confidentially.