Supplier Code of Conduct

1. INTRODUCTION

Loop BV and all its subsidiaries (together “Loop”) are committed to the highest standards of ethical conduct and social and environmental responsibility aligned with the Universal Declaration of Human Rights (UDHR) and the Conventions of the International Labour Organisation (ILO). We expect our Suppliers to align with these standards, ensuring a responsible and sustainable supply chain and comply fully with all applicable laws and regulations. This “Supplier Code of Conduct” sets out the standards expected of any Supplier doing business with Loop.

Suppliers are expected to accurately document and report information related to subjects discussed in this Supplier Code of Conduct and in accordance with Loop’s instructions. This information must be disclosed transparently, without falsification or misrepresentation, to all relevant parties and in compliance with applicable laws.

2. DEFINITIONS

“Confidential Information” means and refers to information, of whatever nature, which is disclosed directly or indirectly by Loop (or on its behalf) to Suppliers, whether orally, in writing or in any format or medium, including but not limited to Loop’s, its affiliates', business partners’, subsidiaries', agents', contractors', clients' and/or vendors' (i) business (including, without limitation, names and expertise of employees, knowhow, ideas, and other technical, business, financial, client and product development plans, forecasts, strategies, techniques and information), (ii) computer programs, computer code, modules, scripts, algorithms, features and modes of operation, inventions (whether or not patentable), techniques, processes, schematics, testing procedures, software design and architecture, product design and function specifications, analysis and performance information, user documentation, internal documentation, designs, ideas, concepts, metaphors and content for sites on the World Wide Web, the Internet and other computer networks, research, development, trade secrets, analyses, memoranda, materials, trade or commercial names, trademarks, commercial terms and conditions, financial or business results, other documents or information which contain or reflect or are generated from such information.
“Countries of Operations” mean the specific nations or regions where the Supplier conducts its business activities, provides its products or services, and maintains a physical or operational presence. These countries are where the Supplier’s facilities, employees, distribution networks, and business operations are established and active.
“Supplier Facility” means any facility, place or location where a Supplier provides its products or services or parts thereof.
“Supplier” means any individual or company (including its subsidiaries, affiliates and subcontractors) providing goods or services related to Loop’s business or undertakes any activity for or on behalf of Loop, either directly or indirectly in relation to Loop’s products.
“Supplier Representative” means any person or entity who collaborates with a Supplier, whether under a contract of employment or any other contract (written or oral) where such person or entity undertakes to do any work or services for the Supplier and includes, without limitation, Supplier’s principals, officers, directors, employees, agents, consultants, advisors or other representatives.

3. DATA PRIVACY, CONFIDENTIALITY AND THE ETHICAL USE OF AI

Suppliers must comply with applicable privacy and data protection laws and regulations in the respective Countries of Operation, including but not limited to the European General Data Protection Regulation (GDPR). Suppliers are expected to implement robust technical and organizational measures to secure Loop’s Confidential Information and personal data and prohibit its unauthorized access or use.

Suppliers must furthermore commit to using AI ethically, responsibly and in line with the applicable AI regulation, including but not limited to the European AI Act. This includes ensuring transparency in the use and understanding of AI, the design and deployment of AI systems to prevent bias and discrimination as well as the regular auditing of the AI systems used. Suppliers should implement robust measures to protect data privacy when using AI and develop and maintain AI systems to be safe, secure, and reliable throughout their lifecycle. Finally, human judgment cannot be substituted by automated decision-making by using AI. Human oversight and regular review by Suppliers should ensure that ethical considerations are prioritized.

4. ETHICAL STANDARDS

Suppliers must conduct business in a manner consistent with Loop’s ethical standards. In particular, Suppliers should abide by the following ethical standards and guidelines:

Obey all relevant laws in the Countries of Operation.
Treat Supplier’s Representatives fairly, with dignity and respect.
Report financial conditions and results of operations, honestly and promptly. • Deal honestly and fairly with clients, customers, suppliers, and financial partners. • Avoid actual and potential conflicts of interest.
Safeguard Loop's assets as well as Loop’s intellectual property.
Protect Loop's reputation.
Separate personal political activities from Loop's business.
Report observed violations of legal and ethical standards to Loop as soon as possible.

5. HEALTH & SAFETY

Loop expects its Suppliers to implement the standards of occupational health and safety at a high level and to report on the measures taken to ensure good health and safety. Suppliers should comply with applicable local occupational health and safety regulations and provide a work environment that is safe and conducive to good health, in order to preserve the health of Supplier Representatives and prevent accidents, injuries and work-related illnesses. Regular health and safety training should be provided to employees, promoting awareness and preventing accidents or occupational illnesses. Suppliers shall maintain and regularly inspect equipment, machinery and facilities to ensure their safe operation. Suppliers are obliged to provide personal protective equipment to their employees in locations where this is required or recommended by the World Health Organization based on its working conditions. Suppliers shall continuously monitor their production environment to substitute any possible hazardous work by non-hazardous activities.

Suppliers shall report any work-related injuries to Loop which have occurred in activities related to the Loop products. Following health and security events, Suppliers will report on the preventive actions taken in order to avoid reoccurrence of said incident.

Suppliers maintains a drug and alcohol-free work environment. No Supplier or Supplier Representative is permitted to possess, consume, sell, or be under the influence of alcohol and illegal drugs (and legal drugs that are not used in a manner consistent with dosage requirements) while in any Supplier Facility. Firearms and any other weapons are not allowed in any Supplier Facilities and may not be carried when conducting any Loop business. Violent or abusive behavior will not be tolerated at Loop.

6. PROHIBITIONS AGAINST DISCRIMINATION AND HARASSMENT

Loop does not tolerate unlawful discrimination or harassment in the workplace. Suppliersmust not engage in any unlawful discriminatory or harassing conduct in Supplier’s Facilities or directed at anyone in the workplace. Discrimination or harassment based on race, color, religion, national origin, citizenship, ancestry, gender (including pregnancy), gender identity, age, disability, marital status, sexual orientation, or other protected characteristic or status is strictly prohibited.

Sexual harassment is generally defined as unwelcome sexual advances, requests for sexual favors, or other visual, verbal or physical conduct of a sexual nature when: (i) submission to such conduct is made, either explicitly or implicitly, a term or a condition of employment; (ii) submission to or rejection of such conduct affects employment opportunities; or (iii) such conduct interferes with an individual's work or creates an intimidating, hostile, or offensive work environment. Examples of sexual harassment include, but are not limited to: sexual gestures, leering, or displaying sexually suggestive objects or pictures; derogatory comments, epithets, slurs, teasing and jokes of a sexual nature; graphic comments about an individual’s sex life or body; suggestive or obscene letters, e-mails, notes or invitations; and unwelcome physical contact.

Suppliers must establish clear reporting mechanisms for employees to report instances of discrimination or harassment without fear of retaliation.

7. COMPLIANCE WITH LABOR LAWS; LABOR STANDARDS

Suppliers must comply with all applicable labor laws and adhere to international labor standards, including the ILO Conventions on child labor, forced labor, and freedom of association. Suppliers should support the principles of the United Nations Global Compact, the UN Universal Declaration of Human Rights as well as the 1998 International Labour Organization Declaration on Fundamental Principles and Rights at Work, in accordance with national law and practice.

Child labour. Suppliers are prohibited from using workers under the legal age of employment in any country or local jurisdiction where Suppliers perform work for Loop. If the minimum age of employment is not defined, the minimum age of employment shall be 16 years of age. Measures will be taken to ensure that minors (i.e. workers that are under 18 years of age) do not perform work that might jeopardize their health, safety, or morals.
Forced labour. Suppliers shall not employ or use any form of forced, bonded or compulsory, or other forms of slavery or human trafficking and will take all reasonable steps to ensure that there is no form of forced, bonded or compulsory labor, or other forms of slavery or human trafficking employed or used within its business or in its supply chains.
Compensation and working hours. Suppliers shall comply with the respective national laws and regulations regarding working hours, wages and benefits. The normal work week shall not exceed 60 hours. Hours worked beyond the normal work week shall be voluntary and fairly renumerated, unless legally allowed or agreed through legal means, such as collective bargaining agreements. Suppliers must strive towards reducing the working hours to meet the established ILO standard of 48 hours per week. Except under exceptional circumstances, personnel shall be provided with at least one full day (24 hrs) off in every seven-day period. Suppliers should provide clear and transparent payroll information to all employees. In addition, in line with the ILO Conventions, Suppliers commit to ensuring that all wages paid meet or exceed the minimum living wage necessary to provide a decent standard of living for workers and their families. This living wage must cover the cost of basic needs including adequate food, water, housing, education, and healthcare, as well as other essential needs including clothing and transportation. Suppliers are expected to conduct regular reviews of their wage practices to ensure alignment with changes in the cost of living and economic conditions in their operating regions. Suppliers should provide clear and transparent payroll information to all employees. This includes detailed explanations of how wages are calculated, including all deductions and bonuses. Transparency in payroll practices is crucial to ensure that employees understand their compensation and to foster trust and compliance with these standards.
Disciplinary practices/coercion. Loop firmly believes that everyone should be treated with dignity. Suppliers shall not inflict or threaten to inflict corporal punishment or any other forms of physical, sexual, psychological or verbal abuse or harassment on any employees.
Freedom of association. Supplier Representatives shall be free to join organizations of their own choice. Suppliers shall respect and recognize the right of employees to join and organize associations of their own choosing, and to bargain collectively. Employees shall not be subject to intimidation or harassment in the exercise of their right to join or to refrain from joining any organization. Suppliers shall engage in good-faith negotiations with worker representatives and trade unions regarding employment terms and conditions. Collective agreements shall be implemented in full compliance with national laws and international labor standards.
Employee housing. In case Suppliers offer housing for its employees it should ensure decent housing accommodation and a suitable living environment. The aim should be that adequate and decent housing accommodation should not cost the worker more than a reasonable proportion of income, whether by way of rent for, or by way of payments towards the purchase of, such accommodation.
Gender equality and non-discrimination. Suppliers shall ensure that all employment decisions are based on the principle of equal pay for work of equal value, regardless of gender, ensuring fairness and equity in compensation across similar roles and responsibilities. Measures shall be implemented to prevent and address any form of gender discrimination or bias in the workplace. This includes but is not limited to, establishing clear policies, training programs to promote gender sensitivity, and mechanisms for reporting and resolving complaints of discrimination. Furthermore, Suppliers are dedicated to creating a supportive environment that accommodates the unique needs of all employees, including flexible working arrangements and parental leave policies that support work life balance for all genders. Suppliers are committed to regularly reviewing and adjusting its policies to close any gender pay gaps and ensure an inclusive workplace culture that values diversity and equality.

8. PROTECTION OF VULNERABLE GROUPS

Suppliers shall take proactive measures to protect vulnerable groups, including but not limited to: • Migrant workers, ensuring fair wages, safe working conditions, and protection from exploitation. • Women in the workforce, ensuring equal opportunities, maternity protections, and freedom from gender-based violence and harassment.

Young workers, ensuring compliance with minimum age requirements and preventing child labor in all operations and supply chains.
Indigenous and marginalized communities, respecting their rights, land, culture, and consultation in business activities that may impact them.

9. ENVIRONMENT

Suppliers shall comply with all applicable local environmental laws, regulations and standards as well as all European regulations with an effect on Suppliers providing products or services to European companies, like Loop.

Suppliers shall implement an effective system to identify, quantify and eliminate potential hazards to the environment and report thereon. Suppliers should wherever possible support a precautionary approach to environmental matters, undertake concrete and quantifiable initiatives to promote greater environmental responsibility: waste reduction, energy efficiency, recycling and responsible water usage practices. Suppliers should set measurable environmental targets and share progress with Loop periodically or when requested.

Suppliers should identify, monitor, measure and reduce energy, water and resource consumption, carbon emissions and resource consumption, specifically related to the products or services provided to Loop. This data shall be shared upon request and/or via carbon accounting and/or LCA platforms. Loop shall be allowed to audit, monitor and verify this data.

10. SOURCING

Suppliers are obliged to source their materials and components responsibly, considering factors such as environmental impact and human rights throughout the supply chain. Suppliers must thereby adhere to the principles of the OECD Due Diligence Guidance for Responsible Supply Chains, the UN Guiding Principles on Business and Human Rights, and the Responsible Business Alliance (RBA) Code of Conduct.

Suppliers are furthermore expected to implement policies in this regard and regularly audit their material and components suppliers. Suppliers should obtain and provide relevant chain-of-custody or material certifications where applicable, enabling Loop to verify responsible sourcing.

11. COMMUNITY INVOLVEMENT

Loop seeks to work with Suppliers that partner with local governments and communities to improve the educational, cultural, economic and social well-being of the communities in which they live and serve.

12. GIFTS; CONFLICTS OF INTEREST

Suppliers should refrain from offering gifts valued over €50 to Loop employees. Any potential conflicts of interest, such as business relationships with competitors, must be disclosed to Loop. Suppliers should further refrain from accepting or giving any gifts, favors, payments, entertainment, loans or the like with a purpose of obtaining any improper advantage or influence for Suppliers, Loop or any third party with any client, prospective client or other third party or that create any appearance of impropriety.
Suppliers must disclose all potential conflicts of interest, including those in which Suppliers may have been placed inadvertently due to either business or personal relationships with customers, suppliers, business associates, or competitors of Loop, or with other Loop employees. Employees of Suppliers may not act on behalf of Loop in any transaction or business relationship involving themselves or members of their family, or other persons or organization with which they or their family have any significant personal connection or financial interest.

13. BUSINESS INTEGRITY,ANTI-CORRUPTION AND SANCTIONS

Corruption, bribery, extortion, and embezzlement, in any form, are strictly prohibited. Suppliers must adhere to international anti-corruption standards, including the UN Convention against Corruption, and shall not violate any local or international anti-corruption regulations and conventions. Suppliers must implement anti-corruption training and controls within their organizations and shall not engage in corruption, bribery, extortion or embezzlement in any form. Suppliers shall not offer or accept bribes or other means to obtain an undue or improper advantage. Suppliers must uphold fair business standards in advertising, sales, and competition. In addition, Suppliers shall comply with US sanctions and trade controls, which are administered and enforced by the US Department of Treasury’s Office of Foreign Assets Control (“OFAC”) and other US government agencies and may also be subject to other sanctions laws applicable where we do business. Suppliers must also ensure any persons, including employees, suppliers, agents and contractors of Supplier, who are engaged in providing services to Loop remain compliant at all times with applicable sanctions and trade controls.

14. FRAUD AND INVESTIGATIONS

Suppliers are expected to cooperate with Loop investigators, law enforcement and regulatory agencies in the event of any investigation of wrongdoing by Suppliers or others doing business with Loop. This cooperation includes reporting violations of the law and cooperating with law enforcement agencies in their prosecution efforts. Should Suppliers receive any subpoenas, regulatory requests, media inquiries, or other third-party requests concerning (the products or services provided to) Loop, Suppliers shall promptly forward such matter to Loop, to the extent permitted to do so by law.

15. REPRESENTATION OF LOOP

Suppliers may not represent themselves as an employee of Loop or enter into any agreement on Loop’s behalf or in Loop’s name.

16. COMPLIANCE AND TRANSPARENCY

Loop reserves the right to ask Suppliers to re-affirm compliance with the Supplier Code of Conduct periodically and to audit compliance by Supplierswith the SupplierCode of Conduct at any time. Suppliers are expected to be transparent about their operations, policies, and practices, and they may be required to provide relevant information for auditing and verification purposes.

17. COMMUNICATION

Suppliers should take appropriate steps to ensure that the principles of the Supplier Code of Conduct are communicated to their employees and throughout their own supply chains. Suppliers should also take appropriate steps to ensure that the principles of the Supplier Code of Conduct are adopted and applied by their employees, suppliers, agents and contractors to the extent applicable.

18. DUE DILIGENCE FRAMEWORK

Compliance with International Standards. Suppliers shall establish, implement, and maintain a due diligence framework that aligns with internationally recognized principles, such as but not limited to the UN Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises.
Risk Identification and Mitigation. Suppliers shall conduct regular risk assessments to identify, prevent, and mitigate adverse human rights and environmental impacts within its operations and supply chain. Suppliers shall take appropriate measures to address identified risks and provide evidence of these efforts upon request by Loop.
Monitoring and Reporting. Suppliers shall ensure ongoing monitoring of compliance with all international recognized principles, including but not limited to on-site inspections, interviews and audits. At Loop’s request, Suppliers shall provide reports or other relevant documentation, demonstrating the effectiveness of its due diligence measures.
Cooperation and Transparency. Suppliers shall cooperate fully with Loop in relation to any due diligence inquiries, audits, or assessments concerning human rights and environmental impact. Suppliers shall promptly provide relevant information and access to necessary records, where legally permissible.
Remediation and Corrective Actions. If Suppliers identify or are made aware of any human rights or environmental violations within its operations or supply chain, Suppliers shall take immediate and appropriate corrective action. This includes engaging with affected stakeholders and, where necessary, implementing remediation measures in accordance with international best practices.
Continuous improvement and empowerment. Suppliers shall adopt a proactive approach to continuous improvement , cooperation and empowerment of the stakeholder in the supply chain, ensuring ongoing development of human rights, environmental protection, and responsible business conduct.

19. GRIEVANCE MECHANISM

Suppliers shall establish and maintain an effective grievance mechanism that allows employees, subcontractors, business partners, and other stakeholders to report concerns related to human rights, environmental, and ethical violations. The grievance mechanism shall:

Be accessible, confidential, and non-retaliatory, ensuring that any person who raises a concern is protected against adverse consequences.
Allow for anonymous reporting where legally permissible.
Provide a clear process for receiving, investigating, and resolving grievances in a timely and transparent manner.
Ensure that grievances are addressed in accordance with international human rights standards and, where appropriate, in collaboration with affected parties.
Report on the nature and resolution of grievances to the Purchaser upon request.

20. ENFORCEMENT

If Loop determines that any Supplier has violated the Supplier Code of Conduct, Loopmay either terminate its business relationship or require the Supplier to implement a corrective action plan, depending on the violation. If corrective action is advised, but not taken, Loop will suspend placement of future orders and shall terminate its business relationship with Supplier.

21. CHANGES TO THE SUPPLIER CODE OF CONDUCT

This Supplier Code of Conduct may be revised or updated by Loop from time to time. Loop may modify the present Supplier Code of Conduct at any time upon prior notification to Suppliers. In the absence of opposition within 15 calendar days, Suppliers shall be deemed to have accepted the amendments in their entirety and irrevocably.