Mytra Supplier Code of Conduct

1. Introduction and scope

Mytra, Inc. and its affiliates (“Mytra”) expect every supplier to operate lawfully, safely, ethically and with respect for people and the environment. This Supplier Code of Conduct (this “Code”) sets out Mytra’s minimum expectations.

This Code applies to all suppliers, vendors, contractors and service providers that provide goods or services to Mytra (each, a “Supplier”). It covers each Supplier’s employees, temporary and agency workers, and anyone working on its behalf.

Suppliers must follow all applicable laws where they operate. Where this Code and local law differ, Suppliers must follow the stricter standard, unless doing so would break the law.

Suppliers must require their own suppliers, subcontractors and labor agents that support work for Mytra to meet standards consistent with this Code, including through their agreements, and must take reasonable, risk-based steps to monitor their compliance.

Suppliers may find the Responsible Business Alliance (RBA) Code of Conduct a useful reference for more detailed guidance on the topics in this Code.

2. Labor and human rights

Suppliers must treat workers with dignity and respect, consistent with internationally recognized human rights standards such as the United Nations Guiding Principles on Business and Human Rights and the International Labour Organization (ILO) Declaration on Fundamental Principles and Rights at Work. These requirements apply to all workers, including temporary, migrant, student, contract and agency workers. Workers must be legally authorized to work in the country where they work, and Suppliers must verify their eligibility.

No forced labor. No forced, bonded (including debt bondage), indentured, involuntary prison or trafficked labor, and no human smuggling. Workers must be free to leave their jobs on reasonable notice without penalty. Suppliers must not hold, destroy or conceal workers’ identity or immigration documents, require security deposits, or unreasonably restrict workers’ freedom of movement, including their freedom to enter and leave company-provided housing. Workers must not be charged recruitment fees or related costs, including travel, document processing and visa costs, by the Supplier or its labor agents. If workers are found to have paid such fees, the Supplier must reimburse them. Workers must receive written terms of employment in a language they understand before they start work; migrant workers must receive them before leaving their home country, and those terms must not be replaced with less favorable ones after the worker arrives. Suppliers must not knowingly source materials produced with forced labor, including materials from regions subject to U.S. import restrictions, such as those under the Uyghur Forced Labor Prevention Act, and must provide supply chain traceability information on request.

No child labor. No workers under 15 years of age, or under the local legal minimum age for employment or the age for completing compulsory education, whichever is highest. Suppliers must have a reliable way to verify workers’ ages. Workers under 18 must not do hazardous work, night work or overtime. Legitimate apprenticeship and internship programs that comply with local law are allowed; student workers, interns and apprentices must have proper records and be paid at least the legal minimum wage. If child labor is found, the Supplier must stop it immediately, tell Mytra, and fix its age-verification process.

Fair wages and hours. Pay at least the legal minimum wage and legally required benefits, on time. Give workers clear pay statements, and do not make wage deductions as a disciplinary measure or beyond what the law allows. Wages, advances and loans must not be used to deceive workers or tie them to their jobs. Working hours, including overtime and rest days, must follow local law. Unless local law sets a stricter limit, regular working hours must not exceed 48 hours per week, total working hours including overtime must not exceed 60 hours per week, and workers must have at least one day off every seven days. Overtime must be voluntary and paid at the legally required rate.

Non-discrimination. No discrimination in hiring, pay, promotion, training, discipline or termination based on race, color, ancestry, national origin, ethnicity, religion, sex (including pregnancy), gender identity or expression, sexual orientation, age, disability, medical condition, genetic information, marital status, military or veteran status, citizenship status, political affiliation, union membership or any other characteristic protected by applicable law. This does not prevent Suppliers from verifying that workers are legally authorized to work. Provide reasonable accommodation for religious practices and disability. Do not use medical or pregnancy tests in a discriminatory way.

Humane treatment. No harassment, threats (including against a worker’s family), workplace violence, corporal punishment, or physical, sexual, psychological or verbal abuse. Disciplinary rules must be clear, fair and communicated to workers.

Freedom of association. Respect workers’ rights to join or not join unions and to bargain collectively, as permitted by local law. Where local law restricts these rights, allow workers to elect representatives through other lawful means. Workers must be able to raise concerns about working conditions with management without fear of reprisal.

3. Health and safety

Suppliers must provide a safe and healthy workplace and comply with applicable health and safety laws, such as the regulations of the U.S. Occupational Safety and Health Administration (OSHA) or their local equivalents.

Hazard control. Identify and assess workplace hazards, including chemical, biological, physical and electrical hazards, and control them in order of effectiveness: eliminate or engineer out the hazard first, then use administrative controls, then personal protective equipment. Provide required protective equipment to workers free of charge.

Machine and equipment safety. Keep physical guards, interlocks and barriers in place and maintained. Use lockout/tagout procedures for servicing and maintenance.

Physically demanding work. Identify and control the risks of heavy or repetitive lifting, prolonged standing and highly repetitive or forceful tasks.

Pregnant and nursing workers. Take reasonable steps to remove pregnant and nursing workers from high-hazard work and to reduce health and safety risks to them, and provide reasonable accommodations for nursing mothers.

Emergency preparedness. Maintain emergency plans, fire detection and suppression, clearly marked and unobstructed exits, and regular evacuation drills.

Injuries and illness. Record, investigate and report work-related injuries and illnesses as required by law, provide necessary medical treatment, and take corrective action to prevent them from happening again. Encourage workers to report injuries and hazards.

Training and communication. Train workers on the hazards of their jobs and on safety procedures before they start work and regularly after that, in a language they understand. Post health and safety information where workers can see it.

Sanitation and housing. Provide clean toilets and drinking water, and sanitary facilities where food is prepared or eaten. Any worker housing or dormitories provided by the Supplier or a labor agent must be safe and clean, with emergency exits; hot water; adequate lighting, heat and ventilation; secure storage for personal belongings; reasonable personal space; and reasonable entry and exit privileges.

Work at Mytra sites. When working at a Mytra facility or customer site, follow Mytra’s and the site’s safety and security rules.

4. Environment

Suppliers must operate in an environmentally responsible way and comply with applicable environmental laws.

Permits and reporting. Obtain, maintain and comply with all required environmental permits and registrations, and meet their reporting requirements.

Hazardous materials and waste. Identify, label, handle, store, transport and dispose of hazardous materials and waste safely and lawfully. Track and document hazardous and solid waste data.

Pollution prevention. Control and monitor wastewater, air emissions and spills so they do not harm workers, neighbors or the environment.

Restricted substances. Meet legal restrictions on substances in products and packaging where applicable, such as the EU Restriction of Hazardous Substances (RoHS) Directive, the EU REACH Regulation, the U.S. Toxic Substances Control Act (TSCA) and California Proposition 65. On request, provide safety data sheets and material or substance declarations for items supplied to Mytra.

Energy and emissions. Track energy use and greenhouse gas emissions, and provide this data to Mytra on request. Suppliers are encouraged to set reduction goals and to reduce their water use and waste.

5. Business ethics

Suppliers must conduct business honestly and with integrity.

No bribery or corruption. Never offer, pay, request or accept bribes, kickbacks or other improper payments, directly or through a third party, whether to government officials or private parties. This includes facilitation payments and political or charitable contributions made to gain an improper advantage. Suppliers must comply with all applicable anti-corruption laws, including the U.S. Foreign Corrupt Practices Act (FCPA) and, where applicable, the UK Bribery Act. Suppliers must maintain a written anti-corruption policy or code and train relevant employees on it.

Gifts and hospitality. Do not offer Mytra employees gifts, entertainment or anything else of value that could influence, or appear to influence, a business decision. Modest business courtesies, such as an occasional business meal or promotional items of nominal value, are generally acceptable. Never offer cash or cash equivalents, such as gift cards, and do not offer gifts or entertainment while Mytra is evaluating a bid, negotiating a contract or making a sourcing decision involving the Supplier. Never give gifts, entertainment or anything of value to government officials on Mytra’s behalf. If in doubt, ask Mytra at [email protected] before offering anything.

Accurate books and records. Keep accurate business records and invoices, retain them as required by law, and make records relating to work for Mytra available for review on request. Never falsify records or misrepresent transactions, working conditions or practices, including in audits or questionnaires.

Conflicts of interest. Tell Mytra about any relationship with a Mytra employee that could create a conflict of interest, including any financial interest that a Mytra employee or their family member holds in the Supplier’s business. Do not proceed with any transaction affected by the conflict unless Mytra approves it in writing. Do not offer employment or payments to Mytra employees involved in decisions about the Supplier’s business.

Intellectual property and confidential information. Protect Mytra’s confidential information, designs, drawings and intellectual property. Use them only for Mytra’s work, and follow the confidentiality terms in the Supplier’s agreement with Mytra. Respect the intellectual property rights of others. Do not use Mytra’s name, logo or relationship in marketing or publicity without Mytra’s written consent.

Fair competition. Follow competition and antitrust laws. Do not engage in price fixing, bid rigging, or market or customer allocation with competitors. Advertise and market products truthfully.

Trade compliance. Follow all applicable export control, sanctions, anti-boycott, customs and import laws, including the U.S. Export Administration Regulations and sanctions administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). Do not involve sanctioned persons, entities or countries in work for Mytra, and do not supply items that contain components or raw materials from comprehensively sanctioned countries. Provide accurate country-of-origin and product information. On request, provide the Export Control Classification Number (ECCN) and Harmonized Tariff Schedule (HTS) code for items supplied to Mytra. Do not share Mytra technical data with any third party without Mytra’s written permission.

Responsible sourcing of minerals. Adopt a responsible minerals policy and exercise due diligence on the source and chain of custody of tin, tantalum, tungsten, gold and cobalt in items supplied to Mytra, consistent with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas or an equivalent framework. Avoid minerals that finance armed groups or contribute to serious human rights abuses. On request, provide a completed Conflict Minerals Reporting Template (CMRT) and Extended Minerals Reporting Template (EMRT) and information about the Supplier’s due diligence.

Privacy and data security. Comply with applicable privacy laws when handling personal data. Protect any personal data the Supplier receives, and any access it has to Mytra systems, with reasonable physical, technical and administrative security measures, and access Mytra systems only as authorized. Notify Mytra at [email protected] within 48 hours of discovering any actual or reasonably suspected security incident affecting Mytra data or systems.

Product quality and counterfeit parts. Deliver goods that meet agreed specifications and safety requirements. Keep traceability records for parts and materials supplied to Mytra. Tell Mytra in advance of changes to materials, processes, manufacturing locations or sub-suppliers that could affect items supplied to Mytra, as required by the Supplier’s agreement with Mytra. Do not supply counterfeit, used-as-new or unauthorized substitute parts. If the Supplier learns that counterfeit or suspect parts may have been delivered to Mytra, it must notify Mytra promptly.

6. Speaking up

Suppliers and their workers should report any suspected violation of this Code or the law in connection with work for Mytra to [email protected]. This includes concerns about the conduct of Mytra employees. Mytra will keep reports confidential to the extent possible, consistent with applicable law and the need to review the concern.

Mytra does not tolerate retaliation against anyone who raises a concern in good faith, even if the concern turns out to be unfounded. Suppliers must not retaliate against their own workers for raising concerns, and must give their workers a way to raise concerns confidentially and without fear of retaliation.

Suppliers must cooperate reasonably with any Mytra review of a reported concern.

7. Compliance and consequences

Suppliers are responsible for ensuring they meet this Code and should keep policies and records, appropriate to their size, that show how they do so. Mytra may ask Suppliers to complete a self-assessment, provide records, or allow an on-site review with reasonable notice. Suppliers must also complete Mytra’s supplier questionnaires and provide the information Mytra reasonably needs to meet its customers’ requirements.

If a Supplier becomes aware of a violation of this Code in its operations or in work for Mytra, it must tell Mytra promptly and describe the steps it is taking to fix it.

If a Supplier does not meet this Code, Mytra may, depending on the nature and severity of the issue, require the Supplier to prepare and complete a corrective action plan within a timeframe set by Mytra; suspend new orders or awards until the issue is resolved; take the Supplier’s compliance into account in future sourcing decisions; or terminate the business relationship, including any agreement or purchase order, in accordance with their terms.

For serious violations, such as forced or child labor, bribery, falsified records or knowing violations of sanctions or export control laws, or if a Supplier refuses to cooperate with a Mytra review, Mytra may terminate the relationship without first offering a corrective action plan. These steps are in addition to any other rights and remedies Mytra has under its agreement with the Supplier or applicable law.

This Code supplements, and does not replace, the terms of any agreement between Mytra and the Supplier. If they conflict, applicable law comes first, then the agreement between Mytra and the Supplier, then this Code.

Mytra may update this Code from time to time and will provide the current version to Suppliers on request.