Lakeview Farms, LLC
Supplier Code of Conduct


Lakeview Farms, LLC (“Lakeview”) expects our suppliers to project our values and principles, to act with integrity, and to treat people and the environment with respect. These actions reflect Lakeview’s priorities. In this way, we partner with only the highest caliber suppliers that demonstrate social responsibility and a commitment to fairness and honesty. We encourage all our suppliers to familiarize themselves with this Supplier Code of Conduct, as we expect each supplier to adhere to these principles. Lakeview may discontinue its relationship with suppliers who fail to comply with this Supplier Code of Conduct.


Ethics

  1. Highest Ethical Behavior – Our policies and practices direct Lakeview employees to conduct
    business lawfully and ethically wherever we operate. We adhere to firm, uncompromising
    standards for Lakeview’s leadership and employees concerning interactions with customers,
    and we expect that our suppliers comply with these same ethical standards as they work on
    Lakeview business.
  2. Anti-corruption – We expect our suppliers to comply with all laws and regulations forbidding
    the payment of money, products, gifts, or services, directly or indirectly, to any individuals or
    entities as an attempt to corruptly induce favorable business treatment or to corruptly affect
    governmental decisions. Bribes, kickbacks, and similar payments are strictly prohibited.
  3. Conflict of Interest – Lakeview considers it inappropriate for suppliers’ employees to have any
    personal business or financial interest that conflicts with his or her responsibilities to their
    employer.
  4. Fair Competition – Any kind of competition activities must always be undertaken in a
    fair manner that complies with applicable antitrust and competition laws and rules.
    Supplier should not enter into any kind of agreement with competitors that could be
    evaluated as an illegal restraint on trade.
  5. Intellectual Property – Intellectual property rights are to be respected. Transfer of technology
    and know-how is to be done in a manner that protects intellectual property rights, and
    customer and supplier information is to be appropriately safeguarded.
  6. Privacy – Suppliers should protect the reasonable privacy expectations for personal
    information of everyone with whom they do business, including suppliers, customers, and
    employees. Suppliers are to comply with privacy and information security laws and
    regulatory requirements when personal information is collected, stored, processed,
    transmitted, and shared.
  7. Non-Retaliation – Programs that ensure the confidentiality, anonymity, and protection of
    supplier and employee whistleblowers are to be maintained unless prohibited by law.
    Suppliers should have a communicated process for their personnel to be able to raise any
    concerns without fear of retaliation.

Human Rights and Labor

  1. Conditions of Employment – We stress to our suppliers the importance of operating with
    reasonable working hours to maintain a positive and productive work environment consistent
    with commonly accepted practices in each locale. We oppose any form of forced, bonded,
    or indentured labor or involuntary prison work. Further, compensation practices should
    comply with applicable wage laws, including those relating to minimum wages, overtime
    compensation, and legally mandated benefits. All workers performing work within the United
    States must be legally authorized to work in the United States under federal and any other
    applicable laws. Prior to each worker’s assignment, supplier must require and review
    documentation proving such work authorization.
  2. Discrimination – Our company expects suppliers to prohibit discrimination against or
    harassment of any employee or applicant based on race, color, religion, sex, sexual
    orientation, age, disability, national origin, or any other factor deemed unlawful.
  3. Freedom to Associate – Suppliers should respect the rights of workers to associate freely and
    seek representation to the extent permitted under local laws.
  4. Humane Treatment – Lakeview objects to any form of harsh or inhumane treatment,
    including sexual harassment, sexual abuse, corporal punishment, mental or physical coercion,
    or verbal abuse.
  5. Prohibition of Child Labor – We oppose child labor, and we forbid our suppliers to use child
    labor in any facility or business.
  6. Working and Living Conditions – We expect our suppliers to have a healthy and safe working
    environment in accordance with all applicable laws and regulations and to protect employees
    from short, immediate, and long-term harm under appropriate occupational health and
    safety and risk management systems. Where housing is provided, we expect our suppliers to
    provide a healthy and safe living environment for employees in accordance with all applicable
    laws and regulations.

Other

  1. Environment – Suppliers should operate their facilities in a manner that minimizes their
    impact on natural resources, protects the environment and meets or exceeds applicable laws
    and regulations related to air emissions, water discharges, toxic substances and hazardous
    waste disposal. We further stress the need for our suppliers to foster programs that reduce
    energy consumption and waste in their facilities. We emphasize the importance of creating
    innovative products and services that improve energy efficiency and reduce environmental
    harm.
  2. Management Systems – Suppliers should maintain a management system that demonstrates
    the adoption of the principles embodied in this Supplier Code of Conduct and that tracks and
    documents compliance with all applicable laws, government policies, and regulations.
  3. Transparency; Compliance – Supply chain transparency is required to confirm compliance
    with this Supplier Code of Conduct. Accordingly, suppliers shall cooperate with Lakeview in
    any requests for documentation, onsite audits, and associated action plans. Lakeview may
    review on a regular basis the supplier’s compliance with the requirements of this Supplier
    Code of Conduct. A self-assessment shall be undertaken by each Supplier at Lakeview’s
    request to confirm the compliance. Furthermore, we reserve the right to audit our Suppliers
    compliance, and we are entitled to involve an external service provider in any such audit.
    Supplier commits to cooperating to resolve any adverse findings.
  4. Training – Suppliers should maintain programs for training managers and workers to
    implement policies, procedures, and improvement objectives and to meet applicable legal
    and regulatory requirements. Suppliers are expected to assist Lakeview in enforcing this
    Supplier Code of Conduct by communicating its principles to their supervisors, employees,
    and suppliers.
  5. Supply Chain Management – Lakeview expects its suppliers to use good faith best efforts to
    extend the principles embodied in this Supplier Code of Conduct to their suppliers and agents
    that are engaged in the production, supply, and support of products or services for Lakeview
    Farms.

Adherence to this Code of Conduct is mandatory for each supplier and its supply chain. Acceptance shall be confirmed by any action reflecting a supplier’s agreement to undertake or continue business with us. In the event of a violation of this Code, Lakeview may terminate its relationship with the supplier without penalty. The terms of this Code are supplemental to any existing or future agreements between the parties and will serve to supplement rather than supersede such terms.