Supplier Code of Business Conduct

Technical Adhesives Ltd. And Technical Adhesives USA LLC referred to as “Technical” are committed to the highest standards of social and environmental responsibility and ethical conduct.

Technical’ s Ethics Guide (“Ethics Guide”), which is available in English, French and Spanish languages, is the primary policy on workplace practices, human rights, health and safety and ethical conduct. It applies to all employees, directors, and officers of Technical. Prior to employment, new employees must read, understand, and comply with this Ethics Guide. Failure to comply with these principles may result in disciplinary action, up to and including termination.

The Ethics Guide outlines Technical’ s expectations on various ethical issues and provides guidance on ethical decision-making. It also provides additional resources to help employees make ethical decisions and maintain Technical’ s reputation for high ethical standards. Managers must also promote an environment that invites open and honest communication, which includes supporting any employee who brings forward a concern to be discussed and ensuring that no employee suffers retaliation for doing so.

ETHICS OPEN DOOR

Technical has adopted an open-door policy to establish a work environment where employees can feel free to share ideas, ask questions and share concerns. Each employee has the responsibility to promptly report any violation or potential violation of this Ethics Guide, including those related to forced and child labour, to a supervisor, local management team member or Human Resources representative.

Technical prohibits retaliatory action against employees who report or inquire in good faith about ethical issues or concerns.

As a global company, Technical does business with suppliers from many countries of diverse cultural, social, and economic circumstances. In selecting suppliers, Technical tries to identify reputable suppliers that provide safe working conditions, treat workers with dignity and respect, act fairly and ethically, and use environmentally responsible practices wherever they produce products for Technical. Technical endeavors to work with suppliers that demonstrate a willingness and ability to conduct their business in conformity with all applicable legal requirements and ethical standards. At a minimum, Technical requires that all suppliers meet standards set out in this Code of Conduct. Where applicable local laws impose greater obligations on a supplier, the supplier must comply with any such local laws.

SUPPLIER REQUIREMENTS

Technical’ s purchase contracts explicitly require its suppliers to comply with all applicable laws and regulations of the countries in which the merchandise is manufactured or from which it is exported. Company contracts also require all suppliers to impose the same obligation on their contractors.

A failure by a supplier, or by one of its contractors, to comply with all applicable legal requirements will violate Technical’ s contract with the supplier, giving Technical the right to cancel the contract and seek compensation for any resulting expense or loss. Moreover, serious or repeated violations of such requirements by a supplier or its contractors will result in termination of the supplier’s business relationship with Technical.

COMPLIANCE WITH LAWS

Technical expects its suppliers to fully comply with all applicable national and/or local laws and regulations, including but not limited to those related to labor, immigration, health and safety, environment, economic and trade sanctions, anti-bribery, and anti-money laundering. Suppliers are required to take all steps necessary to ensure legal compliance in the production of merchandise for Technical, the facilities in which production takes place and the performance of work conducted by their contractors.

Technical may visit a supplier’s or a contractor’s domestic or foreign facilities, to watch for and report any legal violations or questionable conduct to Technical’ s officers for follow-up and, when appropriate, corrective action.

Technical may require participation in a factory legal compliance survey program. Under this program, the suppliers that Technical intends to use must conduct a self-survey of key legal compliance and workplace safety issues and then submit to, if requested, an inspection by specially trained personnel and/or Technical’ s associates. If a deficiency is found, the factory is given 30 days to correct it. If it fails to do so, then Technical may cease to do business with this factory / supplier.

LABOR LAWS

Technical expects all its suppliers and their contractors (through monitoring or other means) to comply with applicable local labor laws.

Technical requires that its suppliers identify all of the factories and contractors, domestic or foreign, which they plan to use to produce merchandise and provide certification that each factory will operate in compliance with all applicable labor laws.

Technical will not accept merchandise or components produced in violation of labor laws. Technical will not hesitate to discontinue its relationship with any supplier that it determines lacks either the will or the ability to meet its expectations in this area.

FOREIGN SOURCING COMPLIANCE

To address issues of particular concern in the foreign (cross-border) sourcing of merchandise, Technical will not allow the importation of merchandise that:

• Does not have accurate country-of-origin labeling.

• Was manufactured with convict, forced, or indentured labor.

• Was manufactured with illegal child labor.

• Was manufactured in violation of any other applicable labor or workplace safety law or regulation.

For foreign-produced merchandise, Technical requires foreign suppliers to obtain the manufacturer’s certificate that the merchandise was manufactured at a specified factory (identified by name, location, and country), that neither convict, forced, or indentured labor nor illegal child labor was employed in the manufacture of the merchandise, and that the merchandise was manufactured in compliance with all applicable labor and workplace safety law.

REGULAR INSPECTION AND CERTIFICATION BY SUPPLIER PARTNER

Suppliers shall designate one or more of its officers to inspect each of its facilities which produce merchandise sold to Technical. Such inspections shall be done on at least a yearly basis to ensure compliance with standards, terms and conditions set forth herein. The supplier officer designated to perform such inspection shall certify to Technical following each inspection that he or she performed such inspection and that the results are true and correct.