NEENAH INC ETHICAL PURCHASING POLICY This Plicy was issued by Michael D. Wdy, Vice President U.S. Prcurement n December 1, 2011 Revised January 2018
Ethical Purchasing Plicy Sustaining an ethical prcurement and supply prgram Neenah Inc. is cmmitted t being a respnsible crprate citizen by cnducting business ethically and with integrity t benefit sciety as well as ur stakehlders, emplyees, custmers, investrs and mre. Neenah Inc. likewise believes that wherever we are in the wrld, certain universal and minimum standards f business cnduct frm ur suppliers must als be expected. Neenah Inc. has an bligatin t ensure its purchasing practices and standards place a pririty n prmting safety, prtecting the envirnment, and valuing human rights. Neenah Inc. s Ethical Purchasing Plicy Neenah Inc. will purchase gds and services which are prduced and delivered under cnditins which d nt abuse r explit any persn r the envirnment. It is each emplyee and supplier s respnsibility t ensure that ur prducts and services are btained frm surces which respect safety, health, envirnment, prduct stewardship, prduct quality, scial, legal and ethical standards, and sustainability requirements as defined belw. These requirements frm the backbne f the evaluatin and selectin criteria fr gds and services purchased by Neenah Inc. Neenah Inc. will seek alternative surces where the cnduct f suppliers vilates any f these standards r plicies and where there is n effrt by the supplier t address the situatin within an agreed time perid. Neenah Inc. expects certain minimum standards f perfrmance, business behavir, and legal and ethical cmpliance frm its suppliers and everyne assciated with Neenah Inc., including emplyees that deal with suppliers. These minimum standards are: Safety, Health and the Envirnment We are cmmitted t excellence in safety and health. There are n higher pririties fr us than the safety f ur clleagues, custmers, suppliers and lcal cmmunities. We are cmmitted t a gal f zer injuries, believing that all are preventable. Cnsequently, Neenah Inc. will wrk t nly trade with suppliers wh place a high regard n safety. We are cmmitted t prtecting ur natural resurces. Neenah Inc. will carefully cnsider any relatinships with rganizatins that are prven t vilate lcally applied pllutin legislatin r gd sustainability practices. If ur relatinship is deemed a risk and the rganizatin in questin fails t reslve its behavir r perfrmance, we will seek t terminate the relatinship. Labr and Human Rights Neenah Inc. will: trade with suppliers wh bserve the UN s Universal Declaratin f Human Rights (UDHR). Where a supplier is fund t be in grss vilatin f the principles f the -1-
declaratin, we will advcate a change f practice, wrking with the supplier t highlight cncerns and develp mutually acceptable slutins. If this prcess fails, we will terminate the relatinship; trade with suppliers wh pay their emplyees wages and benefits that meet lcal industry benchmarks and natinal minimum requirements; avid suppliers wh impse excessive wrking hurs and pr r unsafe wrking cnditins n their emplyees; trade with suppliers wh d nt discurage r prevent their emplyee frm jining trade unins and ther wrkers assciatins; nt trade with suppliers wh abuse r intimidate their emplyees; nly trade with suppliers wh wrk within the laws f their cuntry; supprt the eliminatin f child, frced and slave labr. In this regard, Neenah Inc. has pledged its supprt fr the UN Glbal Cmpact. nt trade with suppliers that use any prisn, frced, indentured r bnded labr. nly trade with suppliers that cmply with all current r later adpted laws, rules and regulatins f the cuntry in which they are ding business regarding use f child labr. require suppliers t certify that that the materials incrprated int their prducts cmply with the laws regarding slavery and human trafficking f the cuntry in which they are ding business. Cnflict-Free Minerals In August 2012, the U.S. Securities and Exchange Cmmissin ( SEC ) adpted final rules implementing Sectin 1502 f the Ddd-Frank Wall Street Refrm and Cnsumer Prtectin Act, als knwn as the Cnflict Minerals Rule. Under these rules, publicly traded cmpanies must annually reprt t the SEC whether prducts they manufacture r cntract t manufacture cntain specific cnflict minerals riginating frm the Demcratic Republic f the Cng r adjining cuntries ( the DRC ). The cnflict minerals are clumbite-tantalite (tantalum), cassiterite (tin), gld, wlframite (tungsten). If public cmpanies determine they are subject t the Rule, they must cnduct a cuntry f rigin inquiry reasnably designed t determine whether any cnflict material used riginated frm the Demcratic Republic f the Cng r adjining cuntries (cllectively, the DRC Regin ). Neenah Inc. therefre: Is cmmitted t cmpliance with the requirements f the Cnflict Minerals Rule and t any further actin that ensures the prtectin f human rights. Expects its suppliers t: surce materials frm scially and ethically respnsible suppliers; identify any cnflict minerals in prducts supplied t Neenah Inc. and the rigin f such minerals; and prvide infrmatin t Neenah Inc. t aid in Neenah Inc. s ability t cmply with the Rule. Supplier Relatinship Expectatins -2-
We recgnize the safety, health, envirnment, scial, legal and ethical impacts f all supply and prcurement decisins, and will invlve ur suppliers in addressing issues that may arise. We expect ur suppliers t assist us in minimizing any negative effects and neutralizing any risks. Neenah Inc. reserves the right t terminate any relatinship in which a supplier fails t meet ur quality, legal and ethical standards, after apprpriate cnsultatin. We have adpted and develped supply strategies that attempt t achieve best value fr mney that meet ur needs and are within legal and ethical standards. We expect: emplyees f bth Neenah Inc. and ur suppliers nt t deliberately mislead each ther, r take advantage f genuine errrs made by either party. Where errrs are fund t have ccurred, bth parties will endeavr t take the actin necessary t remedy the situatin and minimize the impact f any false infrmatin r errr t each ther; Neenah Inc. emplyees t act impartially and bjectively in all their purchasing activities and t keep recrds where apprpriate t demnstrate that their actins have been fair and abve reprach; ur suppliers t keep recrds where apprpriate t demnstrate that their actins have been fair and abve reprach; emplyees and suppliers t maintain an unimpeachable standard f integrity in all their business relatinships and t fster the highest pssible standards f prfessinal cmpetence in all their supply activities; emplyees and suppliers t cmply with the law f the cuntries in which they perate and with which Neenah Inc. deals, and in all cntractual bligatins incurred by r n behalf f Neenah Inc. Our Cntract with Suppliers By agreeing t supply Neenah Inc., suppliers are required t accept ur ethical purchasing plicy as part f Neenah s terms and cnditins f purchase. Our suppliers must agree t wrk with us t cntinuusly imprve cmpliance t the standards bth within their wn cmpany and thse f their wn suppliers. The implementatin f the ethical purchasing plicy is a shared respnsibility between Neenah Inc. and its suppliers, reinfrced by Neenah Inc. s Cde f Business Cnduct and Ethics and the supplier s wn scial respnsibilities. In line with the Cde, Neenah Inc. will: 1. Cmmunicate its cmmitment t the Ethical Purchasing Plicy and Cde f Business Cnduct and Ethics, t emplyees and suppliers. 2. Prvide guidance t suppliers t prmte and implement the plicy s standards int their wn business prcesses and in their relevant supply chains. 3. Seek t cntinually imprve the way in which suppliers are appinted and supplier relatinships are managed, audited and reprted. Neenah Inc. expects its Suppliers t: 1. Ensure that their prducts and services are prduced and delivered in line with all laws, lcal regulatins and best industry standards and practices. 2. If requested by Neenah Inc., reprt prgress n implementing the ethical purchasing plicy by describing actins taken and detailing future planned activity. -3-
3. Accept respnsibility fr adpting and implementing acceptable safety, envirnmental, prduct quality, prduct stewardship, labr, human rights, scial and legal standards under which prducts are made and services prvided. This includes all wrk cntracted r sub-cntracted. 4. Highlight t Neenah Inc. any areas f legal r ethical cncern s that bth rganizatins can have a cnstructive dialgue abut reslving any gaps and deficiencies. 5. Seek cntinuus imprvement in the way the cmpany prduces and delivers its prducts and services and manages its supplier relatinships. 6. Cmmunicate t Neenah Inc. any practices which culd damage Neenah Inc. s reputatin. Bth Parties will: 1. Wrk tgether as far as pssible t highlight and neutralize areas f risk and cncern and nncmpliance. 2. Ensure the immediate cessatin f serius breaches f the ethical purchasing plicy and, where these persist, terminate their business relatinship. 3. Ensure all emplyees are aware f their individual bligatins under Neenah Inc. s Ethical Purchasing Plicy and Cde f Business Cnduct and Ethics. 4. Recgnize fficial regulatin and inspectin f wrkplace standards, and the interests f legitimate trade unins and ther representative rganizatins. Terms and cnditins Adherence t Neenah Inc. s Cde f Business Cnduct and Ethics plicy is a key cmpnent f terms and cnditins f ding business with Neenah Inc. As a demnstratin f this, Neenah Inc. includes the fllwing clause int all f ur standard terms and cnditins f purchase: The Supplier acknwledges the Neenah Inc. Cde f Business Cnduct and Ethics and Ethical Purchasing Plicy cvering areas such as labr, human rights, safety, health and the envirnment. Cpies f the Ethical Purchasing Plicy and the Cde f Business Cnduct and Ethics may be viewed at www.neenah.cm and are available frm Neenah Inc. n request. Neenah Inc. expects the Supplier t maintain a cnsistently high standard f integrity in all its business relatinships with Neenah Inc. and t fster the highest pssible standards f prfessinal cmpetence in all its activities. T this end, in supplying gds and/r services t Neenah Inc., the Supplier agrees that t abide by the Cde f Business Cnduct and Ethics and the Ethical Purchasing Plicy. Further, n Neenah Inc. emplyee r fficer is authrized t prpse t the Supplier r apprve cnduct incnsistent with the Cde f Business Cnduct and Ethics. Supplier certifies that that the materials incrprated int its prducts cmply with the laws regarding slavery and human trafficking f the cuntry in which it is ding business. Neenah Inc. shall have the right t terminate its business relatinship and any assciated agreements with the Supplier if the Supplier vilates the Cde f Business Cnduct and Ethics r the Ethical Purchasing Plicy (r Neenah Inc. reasnably believes that the Supplier is in vilatin f either plicy) in the case f breaches which are capable f remedy, the Supplier fails t remedy such breach, after written ntificatin by Neenah Inc. f such breach, within the cure perid specified by Neenah Inc. fr such remedy. In determining the length f any cure perid Neenah Inc. shall act reasnably, having regard t the severity and nature f the breach. -4-