UNION GALVASTEEL CORPORATION

SUPPLIER CODE OF CONDUCT (“COC”)

(I) COMPLIANCE WITH LAWS

All Suppliers shall conduct their business activities in full compliance with the applicable laws, international
conventions and/or regulations of their respective countries and operating locations.

1. Competition and Antitrust Laws

Suppliers shall conduct business in full compliance with applicable antitrust and fair competition
laws. Suppliers shall not be a party to any unlawful agreement including but not limited to
agreements which affect the price of goods or services provided or offered to UNION
GALVASTEEL CORPORATION (UGC)

2. Anti-Corruption & Anti-Bribery

All members of UGC have been instructed to strictly adhere to the requirements of the applicable
law relating to the prevention of bribery. You are requested to report to Supplier.Relations@cmg.ph
should any employee of UGC be found having committed any offense of corruption under the said
law. Moreover, should any vendor or contractor be found having committed or is believed to have
committed any offense of corruption under the said law, UGC shall be entitled to immediately
terminate all outstanding contract(s) without entitling the vendor or contractor any compensation or
claim for loss.

3. Gifts & Entertainment

Suppliers acknowledge that UGC employees are prohibited from accepting anything more than
occasional and modest gifts from Suppliers.

(II) BUSINESS PRACTICES

Suppliers must be committed to the highest standards of legal and business conduct when dealing with
their employees, and third parties, including UGC.

1. Accurate Business Records

Suppliers shall maintain accurate and timely financial and accounting records of all transactions
related to their business with UGC and retain them as required by applicable laws, but in no case
less than 3 years. No accounting or financial entry that conceals or disguises the true nature of any
transactions or record shall be made

2. Honest & Legal Conduct

Suppliers undertake not to engage in any conduct which would, under any applicable law, constitute
willful misconduct, a criminal offense and/or tortious act.

(III) ETHICAL PRINCIPLES AND CONFLICT OF INTEREST

Suppliers shall conduct their business in a manner which conforms to the highest level of ethical business
behavior. Suppliers should avoid unfair practices and any conflict of interest or appearance of conflict of
interest in all their dealings.

(IV) HEALTH AND SAFETY

Suppliers shall abide by in all safety protocols issued by UGC and relevant local and national government
authorities.

(V) LABOUR

Suppliers shall comply with all applicable labor laws, including but not limited to wages, working hours,
conditions, and prohibition on child labor.

Suppliers shall not discriminate based on race, color, age, gender, sexual orientation, ethnicity, disability,
pregnancy, religion, political affiliation, union membership or mental status in hiring and employment
practices such as promotions, rewards, and access to training.

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(VI) SUPPLIER MANAGEMENT

All Suppliers shall maintain appropriate and meaningful compliance policies and programs consistent with
this its Supplier Accreditation Procedures. UGC shall have the right to audit Suppliers' compliance at a
mutually agreed time and place, and Suppliers shall extend full cooperation to UGC in such event.

(VII) ENVIRONMENTAL COMPLIANCE

Suppliers shall operate in an environmentally responsible and efficient manner to minimize adverse impacts
on the environment and shall comply with all applicable environmental regulations.

(VIII) CONSEQUENCES OF BREACH

In the event that the Supplier is in breach of any of the terms of this COC, UGC shall have, at its sole option,
the right to terminate the contract(s) with the Supplier upon written notice to Suppliers within thirty (30) days
of UGC becoming aware of the breach; and UGC shall be entitled to recover its direct and indirect losses
which are consequences of the Supplier's breach and/or of UGC’s exercise of its option to terminate the
contract(s).

(IX) UGC ETHICS REPORTING RESOURCE

In the event of any breach of this COC, Supplier must promptly contact UGC’s Supplier Relation
Management officer or email to Supplier.Relations@cmg.ph

UGC is committed to investigate every report and will take reasonable precautions to protect the
confidentiality of the identity of, and will not permit any form of retribution against, any person who, in good
faith, reports known or suspected violations.

I understand that information provided to UGC will solely be used for the accreditation process. At any
time, I may request for the retrieval and purging of any information submitted to them if I feel that there is
data privacy risk through Supplier.Relations@cmg.ph
Information collected will be kept confidential within 1 year from the time the business with vendor ceases
or is terminated.

Signed / Executed by:

______________________________________________
Name of Company
By:
Name of Representative: __________________________
Title / Position: __________________________________
Date: _________________________________________

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