Supplier Code of Conduct

Corporate accountability, responsible procurement, ethical business conduct, and respect for workers are essential principles governing the supply chain of BRC, Inc. and its related entities. These expectations apply to manufacturers, suppliers, distributors, contractors, service providers, vendors, and other organizations that provide products or services associated with the Company. The Supplier Code of Conduct establishes fundamental standards concerning labor conditions, employee welfare, occupational safety, environmental stewardship, ethical behavior, product integrity, and responsible supply chain oversight. Depending on the products, materials, or operational risks involved, suppliers may also be subject to additional requirements or specialized standards.

Suppliers are expected to ensure that the Code is communicated effectively to the people working within their operations. Reasonable steps should be taken to make the requirements accessible through workplace postings, employee communications, educational materials, or recurring training programs. Any expenses associated with translating, preparing, distributing, displaying, or explaining these requirements are generally the responsibility of the Supplier. The standards extend throughout relevant facilities and operations and apply to permanent employees, temporary personnel, migrant workers, contractors, agency workers, subcontractors, and other individuals performing work within the Supplier’s operations.

Suppliers are also responsible for promoting equivalent expectations among their own business partners. Responsible sourcing requirements should extend across manufacturing, packaging, transportation, distribution, marketing, sales, product certification, employment practices, immigration compliance, intellectual property protection, environmental management, occupational safety, and product quality. Suppliers should maintain accurate records capable of demonstrating compliance and should make appropriate documentation available when reasonably requested. The Company and its designated representatives may review records, conduct assessments, inspect facilities, interview relevant personnel, or take other reasonable steps to evaluate compliance.

Any known or suspected breach of these standards should be reported through an appropriate reporting mechanism as soon as reasonably possible. Individuals who raise concerns honestly and in good faith must be protected from retaliation, threats, intimidation, disciplinary action, or other adverse consequences. Suppliers are expected to maintain an environment where workers can raise concerns without fear of punishment.

All suppliers must conduct their activities in accordance with applicable laws, regulations, governmental orders, ordinances, and relevant international requirements. This includes requirements governing trade, export controls, economic sanctions, competition, antitrust, privacy and data protection, employment, environmental protection, and workplace health and safety. When legal requirements and the standards established by the Code differ, suppliers should apply the requirement that provides the greater level of protection when doing so is legally permissible.

Improper payments and unethical commercial conduct are not acceptable. Suppliers must prohibit bribery, corruption, kickbacks, extortion, embezzlement, and comparable forms of misconduct. Appropriate internal controls should be maintained to identify and prevent these activities, and personnel should receive suitable compliance guidance. Gifts, meals, entertainment, hospitality, favors, or other benefits involving Company personnel must remain appropriate and customary and must never be provided for the purpose of improperly influencing a business decision. Cash payments or comparable advantages intended to secure an unfair commercial benefit are prohibited.

Suppliers must also maintain compliance with applicable anti-money-laundering and counter-terrorism requirements. Commercial relationships should be based on legitimate business purposes and lawful sources of funds. Internal procedures should be designed to identify suspicious activity and reduce the possibility of prohibited transactions. Suppliers must not knowingly participate in transactions involving illegal proceeds or activities associated with terrorist financing.

Economic sanctions and export-control obligations must be observed in all applicable transactions. Suppliers may not knowingly conduct prohibited business with sanctioned individuals, organizations, or restricted entities, nor may Company resources be used for the benefit of parties subject to applicable restrictions. Appropriate screening procedures and compliance controls should be maintained to identify potentially prohibited relationships before transactions occur.

Potential conflicts of interest must be identified and disclosed when appropriate. Suppliers and individuals representing them should avoid circumstances that could interfere with impartial commercial judgment or create the appearance of improper influence. Ownership interests, personal relationships, financial connections, or other circumstances involving Company employees should be disclosed when they could create an actual or perceived conflict. Where prior written approval is required, Supplier agreements may not be assigned, transferred, or subcontracted without the Company’s authorization.

Confidential information and intellectual property belonging to the Company must be appropriately protected. Suppliers may have access to proprietary information, trademarks, trade names, designs, business materials, technical information, or other protected assets and may use such materials only for authorized business purposes. Unauthorized disclosure, reproduction, distribution, or use is not permitted. Suppliers should also maintain sufficient traceability regarding the origin of key materials incorporated into products supplied to the Company. When requested, suppliers may be required to provide information concerning manufacturing locations, sourcing arrangements, materials, components, regulated substances, or other supply chain characteristics.

Trading securities based on confidential information obtained through a business relationship is prohibited. Suppliers, their employees, and relevant family members must not use material nonpublic information concerning the Company to make investment decisions or trade securities. Such information must not be disclosed to unauthorized individuals, published, or otherwise distributed.

Employment must be freely chosen throughout the supply chain. Forced or compulsory labor is prohibited in all forms, including bonded labor, debt-related labor, involuntary prison labor, slavery, trafficking, and other arrangements in which individuals are compelled to work through threats, coercion, or unlawful restrictions. Workers should be able to leave employment in accordance with applicable law without unreasonable financial penalties, intimidation, retaliation, or disciplinary consequences. Suppliers should take reasonable steps to ensure these protections are respected by their own suppliers and labor providers.

Child labor is prohibited. Suppliers must comply with applicable minimum employment age requirements and ensure that young workers are protected from conditions that could interfere with education, health, development, or general well-being. Individuals under eighteen should not perform hazardous work or prohibited night work where applicable laws or recognized standards restrict such activities.

Employees must be permitted to exercise lawful rights relating to freedom of association and collective bargaining. Suppliers may not improperly interfere with workers who choose to establish, join, participate in, or decline to participate in lawful worker organizations. Retaliation, discrimination, threats, punishment, or other unfavorable treatment because of legitimate union participation or collective bargaining activity is not permitted.

Workers must receive wages, benefits, and other compensation required by applicable law. Compensation should be calculated accurately, paid directly, and provided on a regular schedule. Employees should receive understandable records explaining relevant compensation and deductions. Unlawful or unauthorized deductions are prohibited. Where training, apprenticeship, probationary employment, or similar arrangements are subject to specific wage requirements, suppliers must comply with those requirements as well.

Working hours must remain within applicable legal limits and the standards established by the Code. Suppliers should accurately monitor ordinary working time and overtime while providing legally required rest periods and meal breaks. Reliable timekeeping systems and appropriate records should be maintained so that working-hour practices can be reviewed and verified.

Every worker must be treated with dignity and respect. Physical punishment, threats, intimidation, sexual harassment, sexual misconduct, verbal abuse, psychological mistreatment, and other forms of workplace harassment are prohibited. Suppliers are expected to take preventive measures within their own facilities and should also address similar risks involving relevant contractors, labor agencies, subcontractors, and other business partners.

Employment decisions should be based on legitimate qualifications, capabilities, job requirements, and business considerations rather than unlawful discrimination. Hiring, pay, promotion, training, discipline, termination, retirement, and other employment decisions must comply with applicable nondiscrimination requirements. Suppliers must also follow applicable rules concerning recruitment, worker movement, trafficking prevention, and slavery-related risks.

Workers should be able to leave the workplace after completing their working hours and should not be subjected to unreasonable restrictions when legitimate health, safety, personal, or family circumstances require them to leave. Suppliers may not use threats, excessive financial penalties, retaliation, or coercive practices to restrict lawful worker movement.

Suppliers must provide working environments that are safe, sanitary, and reasonably protective of employee health. Facilities should maintain appropriate emergency exits, fire prevention and response systems, first-aid resources, lighting, ventilation, protective equipment, sanitation, drinking water, and safety procedures. Workers should receive training regarding hazards associated with their responsibilities and have accessible methods for reporting unsafe conditions. Where protected by applicable law, workers should be able to raise legitimate safety concerns or refuse work presenting an immediate and serious safety danger without retaliation.

When housing is provided by a supplier or an associated third party, accommodations should meet applicable health, safety, and sanitation requirements. Residents should have access to safe drinking water, clean sanitation facilities, suitable food preparation and storage areas, and appropriate places for eating. Young workers must not be assigned hazardous duties that could expose them to unacceptable health or safety risks.

Manufacturing and operational facilities must comply with applicable building, zoning, construction, fire, and occupancy requirements. Emergency exits and evacuation routes should remain clearly marked, accessible, and free from obstruction. Facilities should maintain suitable evacuation procedures, emergency lighting, fire detection and suppression equipment, first-aid resources, potable water, sanitary restrooms, and required safety documentation. Areas used for food preparation or dining should also satisfy applicable health, sanitation, food safety, and permitting requirements.

Environmental stewardship forms an important part of responsible supply chain management. Suppliers should seek to use energy and water efficiently, reduce unnecessary waste, limit pollution, and manage environmental impacts associated with their operations. Facilities must comply with applicable requirements concerning emissions, wastewater, waste management, hazardous materials, and other environmental obligations. Chemicals and other hazardous substances should be properly identified, stored, handled, transported, and disposed of, and workers who interact with such materials should receive suitable training.

Products, components, packaging, and other materials supplied to the Company must satisfy applicable product safety and environmental requirements. Suppliers should consider the environmental consequences of their activities and identify practical opportunities to improve resource efficiency, reduce waste, and limit adverse effects on surrounding communities and ecosystems.

Effective grievance systems should be available to workers. Suppliers should provide appropriate channels for raising workplace concerns and, where suitable, allow confidential or anonymous reporting. Individuals who submit concerns in good faith should be protected from retaliation. Workers should understand how to use available reporting mechanisms, and legitimate complaints should be reviewed and addressed within a reasonable timeframe.

The Company may use audits, inspections, assessments, documentation reviews, monitoring activities, or other verification methods to evaluate supplier compliance. When deficiencies are identified, suppliers may be required to implement corrective action. Remediation can include additional training, operational adjustments, stronger documentation, improved controls, or other measures appropriate to the identified issue. Serious or unresolved violations may lead to termination of the applicable commercial relationship, purchase arrangement, or contract.

Suppliers should maintain reliable records demonstrating compliance with employment and worker-protection requirements. Such records may include documentation relating to worker eligibility, age verification, employment status, compensation, working hours, training, and other required matters. Workers should retain possession and control of original identity documents and legally required employment or immigration records. Suppliers must not confiscate or retain passports, birth certificates, work authorization documents, or comparable originals as a condition of employment.

Recruitment practices must not place prohibited financial burdens on workers or their families. Suppliers may not require workers to pay unlawful recruitment fees, assume improper debt, provide financial guarantees, or accept other inappropriate financial obligations as a condition of obtaining or maintaining employment. Recruitment arrangements should be transparent and consistent with applicable legal and ethical requirements.

These supplier standards operate together with contractual obligations, applicable laws, and other requirements governing the relationship between the Company and its suppliers. Compliance with the Code does not eliminate any additional responsibility established by a contract, regulation, policy, or legal requirement. Suppliers are expected to maintain ongoing oversight of their operations and extended supply chains, identify potential risks promptly, investigate concerns appropriately, and take timely corrective action whenever violations or weaknesses are discovered. Through continuous monitoring, responsible management, worker protection, ethical conduct, and environmental awareness, suppliers are expected to contribute to a supply chain that supports lawful, safe, transparent, and responsible business practices.