Supplier Code of Conduct

1. Introduction

Oxenade Industries LLC ("Oxenade") expects all subcontractors, vendors, consultants, and other suppliers ("Suppliers") who provide goods or services in support of our operations and government contracts to conduct their business with integrity, in compliance with applicable law, and in a manner consistent with the values reflected in this Supplier Code of Conduct ("Code"). This Code supplements — and does not replace — the specific terms and conditions set forth in individual subcontracts and purchase orders. Suppliers are expected to flow down applicable requirements to their own lower-tier subcontractors and suppliers.

2. Labor Standards and Worker Rights

Suppliers must treat all workers with dignity and respect and comply with all applicable labor and employment laws. Specifically, Suppliers must:

• Pay all workers at least the legally required minimum wage and provide all legally mandated benefits
• Comply with applicable overtime, working hours, and rest period requirements
• Not use child labor — workers must meet the minimum legal working age in their jurisdiction, and in no case may workers under the age of 15 be employed in any capacity
• Not use forced, compulsory, or involuntary labor of any kind
• Respect workers' rights to freedom of association and collective bargaining where permitted by law
• Maintain a workplace free from harassment, discrimination, and retaliation on the basis of race, color, religion, sex, national origin, age, disability, veteran status, or any other protected characteristic
• Comply with the Service Contract Act (SCA), Davis-Bacon Act, and other applicable prevailing wage laws where required by contract

3. Anti-Trafficking and Combating Human Trafficking

Oxenade is committed to compliance with the Trafficking Victims Protection Act (TVPA) and FAR 52.222-50 (Combating Trafficking in Persons). Suppliers must:

• Not engage in, facilitate, or benefit from any form of human trafficking, forced labor, or debt bondage
• Not use deceptive recruitment practices, including false promises of employment or fraudulent job offers
• Not charge workers recruitment fees that could lead to debt bondage
• Not confiscate or destroy workers' identity documents
• Provide workers with employment agreements in a language they understand prior to departure from their home country, where applicable
• Immediately report any suspected trafficking activity to Oxenade and, where required, to appropriate law enforcement authorities

4. Environmental Compliance

Suppliers must comply with all applicable environmental laws and regulations in the jurisdictions where they operate. Suppliers are expected to:

• Obtain and maintain all required environmental permits and approvals
• Properly manage, handle, store, and dispose of hazardous materials and waste in accordance with applicable law
• Minimize environmental impact through responsible resource use and waste reduction practices
• Promptly report any environmental incidents or spills to Oxenade and applicable regulatory authorities
• Comply with applicable requirements under the Resource Conservation and Recovery Act (RCRA), Clean Air Act, Clean Water Act, and other relevant environmental statutes

5. Data Security and Information Protection

Suppliers who handle, process, store, or transmit government information, controlled unclassified information (CUI), or Oxenade proprietary information must maintain appropriate safeguards. Suppliers must:

• Implement and maintain reasonable administrative, technical, and physical security controls to protect sensitive information from unauthorized access, use, disclosure, or destruction
• Comply with NIST SP 800-171 requirements for protecting CUI in nonfederal systems, where applicable
• Comply with DFARS 252.204-7012 (Safeguarding Covered Defense Information) and related cybersecurity requirements, where applicable
• Promptly notify Oxenade of any actual or suspected data breach or cybersecurity incident involving Oxenade or government information
• Not use government-furnished information for any purpose other than performance of the applicable contract

6. Ethical Business Conduct

Suppliers must conduct their business with integrity and in compliance with all applicable anti-corruption, anti-bribery, and procurement integrity laws. Suppliers must:

• Not offer, give, solicit, or accept bribes, kickbacks, or improper payments in connection with any business activity
• Comply with the Anti-Kickback Act and all applicable provisions of the FAR and DFARS
• Maintain accurate books and records and not submit false claims or fraudulent invoices
• Disclose any actual or potential conflicts of interest to Oxenade promptly
• Comply with all applicable export control laws, including EAR and ITAR, and obtain required licenses before exporting controlled items or technology

7. Prompt Payment and Invoicing

Oxenade is committed to timely payment of its subcontractors and suppliers in accordance with the Prompt Payment Act and applicable contract terms. In turn, Suppliers are expected to submit accurate, complete, and timely invoices supported by appropriate documentation. Suppliers must promptly pass through prompt payment to their own lower-tier subcontractors and suppliers in accordance with applicable law and subcontract terms.

8. Health and Safety

Suppliers must provide a safe and healthy work environment for all workers and comply with all applicable occupational health and safety laws and regulations, including requirements of the Occupational Safety and Health Administration (OSHA). Suppliers performing work on government installations or Oxenade facilities must comply with all applicable site safety requirements and immediately report any workplace injuries, illnesses, or safety incidents to Oxenade.

9. Audit Rights and Cooperation

Oxenade and its government customers reserve the right to audit Supplier records, facilities, and practices to verify compliance with this Code and applicable contract requirements. Suppliers must cooperate fully with such audits and provide access to relevant records and personnel upon reasonable notice. Suppliers must maintain adequate records to support all charges and representations made under applicable subcontracts and purchase orders.

10. Reporting Concerns

Suppliers who become aware of potential violations of this Code, applicable law, or government contract requirements are encouraged to report their concerns to Oxenade promptly. Reports will be treated with appropriate confidentiality to the extent practicable. Oxenade prohibits retaliation against any Supplier representative who reports a concern in good faith.