This SUPPLIER CODE OF CONDUCT applies to companies, individuals, consultants and contractors that provide goods or services to SUN Automation Group; subcontractors or agents of a Supplier who at Supplier’s direction do business on behalf of SUN Automation Group; and where applicable, the employees of our Suppliers, subcontractors and/or agents (“Suppliers”).

We require that our Suppliers follow this Supplier Code of Conduct and expect our Suppliers to develop and implement processes to ensure compliance with this document.

SUN Automation is committed to the highest standards of environmental and social responsibility and ethical conduct. We select reputable Suppliers that uphold our high standards. We choose to work with Suppliers who share our commitment to ethical business conduct, which includes going beyond mere compliance with the law.

We take the commitment to this Supplier Code of Conduct very seriously, and violations by Suppliers of this Supplier Code of Conduct will result in a review of our business relationship, up to and including terminations of the relationship according to our contractual rights and applicable law.

ABOUT SUN AUTOMATION:

We are a United States ESOP company with operations throughout the world. We recognize the cultural and economic diversity of our Suppliers and we also know that laws, rules and regulations where we do business may be different than U.S. laws, rules and regulations. However, wherever our Suppliers (including any of our Supplier’s subcontractors who perform work for SUN Automation) are located, the products produced or services provided for us must meet our high standards and must positively impact our Brand; while upholding the highest commitment to human rights and sustainability of this Supplier Code of Conduct.

COMPLIANCE WITH LAWS:

Suppliers must conduct business in a way that conforms to the letter and intent of the law. Supplier’s business operations and activities must comply with all federal, state, local and foreign laws, rules and regulations, including, but not limited to environmental, human rights, intellectual property, anti-bribery, trade compliance and competition and antitrust laws.

BUSINESS COURTESIES:

While it is generally acceptable to give and receive customary business courtesies (which are gifts, meals and entertainment of nominal value), there are certain guidelines that we require our Suppliers to follow to ensure that the business courtesies are not considered excessive and inappropriate for a business relationship:

Cash or its equivalent (such as gift cards) should never be given or received as a business courtesy. Suppliers are not permitted to provide SUN employees with gifts, entertainment or services. Meals may be provided if they have a business purpose, are reasonable in cost and appropriate as to time, place and expense. Trips, use of vacation homes and other gifts of excessive entertainment are inherently compromising and should not be offered or accepted.

CONFLICTS OF INTEREST:

Suppliers must avoid any situation, relationship or arrangement that conflicts with SUN’s interests or compromises the ability to ethically fulfill contractual obligations. We expect our Suppliers to report any potential conflict of interest following the RAISING CONCERNS section of this Supplier Code of Conduct document.

COMMITMENT TO ANTI-BRIBERY AND ANTI-CORRUPTION:

While conducting business on behalf of SUN AUTOMATION throughout the world, it is critical that our Suppliers adhere to any and all relevant anti-bribery and anti-corruptions laws, regulations and guidelines (including the United States Foreign Corrupt Practices Act (FCPA), the UK Bribery Act, and any local regulations). Our Suppliers, and subcontractors, and or third parties who are doing business on behalf of SUN AUTOMATION are strictly prohibited from offering or paying a bribe or kickback or providing anything of value to a government official to obtain or retain business or influence a government official.

ACCURATE BOOKS AND RECORDS:

Our Suppliers are required to maintain truthful, accurate books and records and have a system of internal controls sufficient to, provide assurances to SUN that business conducted on behalf of SUN is compliant with all relevant laws, regulations and guidelines, including FCPA.

TRADE COMPLIANCE:

Suppliers must lawfully and compliantly transfer SUN AUTOMATION’s products, services, tools, equipment, information and/or knowledge across borders in compliance with all applicable trade control laws that regulate the import and export of goods and services.

CONFIDENTIALITY/CONFIDENTAL AND PRIVATE INFORMATION:

Suppliers are responsible for protecting the confidential, private and proprietary nature of SUN AUTOMATION’s information, which must be used for our business purposes only and be used consistently with the confidentiality terms set forth in our confidentiality and Non-disclosure agreements.

COMMUNICATION:

Communication with or on behalf of SUN AUTOMATION (including electronic and via social media) must be appropriate for the intended audience: not contain any offensive or harassing language; and not contain any language or information that violates any laws, rules or regulations.

RESPONSIBLE SOURCING OF MATERIALS:

SUN AUTOMATION is committed to supporting responsible sourcing of its materials from our Suppliers that share our values around human rights and environmental responsibility. We are committed to complying with the requirement set forth in the final rule regarding the use of “Conflict Minerals” under Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act, and the related rules and regulations issued by the U.S. Securities and Exchange Commission.

TRADEMARK AND INTELLECTUAL PROPERTY:

Suppliers must help protect the SUN AUTOMATION intellectual property and trademarks and ensure they are used appropriately and legally. Suppliers cannot use any trademark owned by SUN AUTOMATION for any reason without first receiving the written consent and the terms of use by SUN AUTOMATION.

ANTITRUST AND FAIR COMPETITION:

Our Suppliers must comply with applicable laws, regulations and standards of fair business, advertising and competition.

SUSTAINABLE COMMITMENT:

Our Suppliers are expected to conduct their business operations in ways that minimize their impact on natural resources and protect the environment, customers, and employees. International, federal, state and local environmental laws, rules and regulations should guide all efforts aimed at minimizing the emission, generation, discharge and disposal of hazardous materials and other waste. At a minimum, our Suppliers must make decisions that comply with all laws, rules and regulations relating to air emissions, water discharges, toxic substances and hazardous waste disposal.

HUMAN RIGHTS/SAFE WORKPLACE ENVIRONMENT:

SUN AUTOMATION Suppliers must uphold the highest standards of human rights, by conducting their business activities in a manner that respects human rights as set out in The United Nations Universal Declaration of Human Rights. Our Suppliers must comply with all applicable laws rules and regulations, including those governing the manufacture of our products, safety, employment, labor and the environment.

Suppliers are responsible for protecting the confidential, private and proprietary nature of SUN AUTOMATION’s information, which must be used for our business purposes only and be used consistently with the confidentiality terms set forth in our confidentiality and Non-disclosure agreements.

EMPLOYMENT LAWS:

Our Suppliers must follow and respect employment laws, rules and regulations wherever they operate in the world, including international labor standards and laws, rules and regulations governing freedom of expression, rights of association, privacy and equal opportunity. Suppliers must promote and maintain a workplace free from discrimination, and treat employees with fairness, dignity and respect without any form of physical, sexual, psychological or verbal abuse or harassment.

NO CHILD LABOR:

Suppliers must not use workers who are under the age of 16, or under the applicable minimum age for completion of compulsory education, or under the minimum age for employment in any particular country, whichever is the highest. Additionally, a Supplier must comply with all applicable child labor laws, rules and regulations and maintain official records relating to its workers’ employment, including verification of workers’ birth date.

WAGES AND BENEFITS:

Wages and benefits provided to workers must be in compliance with applicable laws, rules and regulations.

NO FORCED LABOR:

We do not use, nor do we allow any of our Suppliers to use, any form of slave, forced, bonded, indentured or involuntary labor, regardless of local business customers. Our Suppliers will not engage in human trafficking or exploitation, or import goods tainted by slavery or human trafficking.

SAFE WORK ENVIRONMENT:

Suppliers must provide a safe working environment that promotes accident prevention, minimizes exposure to health risks, and complies with environmental laws, rules and regulations.

RAISING CONCERNS:
REPORTING A POTENTIAL VIOLATION OF THE SUPPLIER CODE OF CONDUCT:

If you have information about a violation (or potential violation) of this Supplier Code of Conduct, you have a responsibility to report it. No action will be taken against the reporter as a result of reporting misconduct or raising an ethical issue in good faith. This includes reporting information about the potential misconduct of a SUN AUTOMATION employee. If allowable in the country where the report is lodged, the report can be made anonymously.

REPORTING PROCEDURE:

Concerns can be raised with your SUN AUTOMATION representative. Patricia Carner, Director of Supply Chain & Operations 1 410 472 2900 x117 or calling SUN AUTOMATION main phone line 1 410 472 2900 and contacting Human Resources.