Groendyke Transport Supplier Code of Conduct

Groendyke Transport, Inc. (“Groendyke Transport”) is committed to conducting business with integrity, safety, and environmental responsibility. This Supplier Code of Conduct (“Code”) outlines the minimum standards expected from suppliers, vendors, contractors, service providers, and other third-party relationships who provide goods or services to Groendyke Transport or conduct business on its behalf, together with their Supplier Personnel (collectively, a “Supplier”).

Suppliers are expected to comply with this Code and all applicable laws and regulations and operate in a manner consistent with ethical business practices, the protection of the environment, respect for human rights and the commitment to health and safety, and sustainability. Suppliers are also expected to communicate these principles to their employees, agents, subcontractors, and suppliers (collectively, “Supplier Personnel”) and to take reasonable steps to cause, enforce, and ensure that their Supplier Personnel operate in accordance with the principles described in this Code.

In implementing this Code, Groendyke Transport recognizes that no code of conduct, not even this Code, can anticipate or specifically address all potential or possible situations or events. Therefore, Groendyke Transport expects all Suppliers to not only abide by and comply with the specific provisions of this Code, but also use sound judgment to reasonably align with and perform under the spirit of the terms set forth herein.

Supplier’s compliance with this Code is hereby incorporated in and made a part of all contracts and agreements by and between Groendyke Transport and the Supplier (each an “Agreement”). Specifically, this Code is intended to supplement, not supersede, the terms and conditions of existing Agreements.

I. Ethics and Legal Compliance

Groendyke Transport expects all Suppliers to comply with anti-corruption and fair competition laws and regulations to prevent their engagement in activities that could eliminate, diminish, or discourage competition.

A. Business Integrity

Suppliers must conduct business in an honest and ethical manner. Integrity must guide all Supplier interactions with its customers, employees, regulators, business partners, and Groendyke Transport. All business dealings by Supplier should be transparently performed and accurately reflected on the Supplier’s business books and records. Information regarding Supplier’s labor, health and safety records, environmental practices, business activities, structure, financial situation, and performance is to be disclosed in accordance with applicable regulations and prevailing industry practices. Falsification of records or misrepresentation of conditions or practices in the supply chain is unacceptable.

B. Compliance with Laws

Suppliers must comply with all applicable local, state, federal, and international laws and regulations in the jurisdictions where they operate. Suppliers shall not engage in transactions that violate antitrust or competition laws. Such transactions may include, but not be limited to, participating in cartels, price fixing, bid rigging, or information sharing that could prejudice fair competition in the marketplace.

C. Anti-Bribery and Anti-Corruption

Suppliers must comply with all applicable anti-bribery and anti-corruption laws and must not directly or indirectly offer, promise, authorize, or provide anything of value in order to improperly influence a business decision or obtain an unfair advantage. Suppliers should never offer, promise, authorize, make, solicit, or accept bribes, kickbacks, or other improper payments, regardless of local practice or perceived customs. This applies to interactions with any persons, whether in the private or public sector.

Suppliers must be especially cognizant of interactions with government officials, including employees of state-owned enterprises that can present heightened risk. Facilitating payments to expedite or secure non-discretionary routine governmental processes should not be made.

D. Conflicts of Interest

Suppliers must avoid situations that may create an actual or perceived conflict of interest with Groendyke Transport. Any potential conflicts must be disclosed promptly.

E. Gifts and Hospitality

Gifts, entertainment, or hospitality offered to Groendyke Transport employees must be modest in value, infrequent, and must not influence or appear to influence business decisions.

F. Confidential Information

Suppliers must protect confidential and proprietary information belonging to Groendyke Transport and must only use such information for legitimate business purposes. Therefore, Suppliers shall protect data and other information obtained in the course of business, taking appropriate steps to protect Groendyke Transport’s proprietary or confidential information, including employee information, customer data, intellectual property, and trade secrets.

II. Health, Safety, and Environmental Responsibility

Groendyke Transport expects all Suppliers to protect the health and safety of their Supplier Personnel and undertake actions that will minimize their impact on the environment.

Suppliers are to maintain procedures and systems to prevent, manage, track, and report occupational injury and illness, including provisions to encourage employee reporting, classify and record injury and illness cases, provide necessary medical treatment, investigate cases and implement corrective actions to eliminate their causes, and facilitate the return of employees to work.

A. Health and Safety

Suppliers must provide safe and healthy working conditions for their Supplier Personnel. This includes implementing appropriate safety procedures, training programs, hazard identification processes, and the use of appropriate personal protective equipment.

Suppliers are encouraged to select and train emergency response teams, duly certified as required by regulation, and ensure Supplier Personnel are able to identify emergency response team members on their shift or at their workstation. Emergency drills must be executed at least annually or as required by local law, whichever is more stringent. Suppliers must respond to and investigate reported safety-related incidents or complaints.

Supplier Personnel potential for exposure to health and safety hazards (chemical, electrical, and other energy sources, as well as fire, vehicles, fall hazards, etc.) are to be identified, assessed, and mitigated. This includes eliminating the hazard, substituting processes or materials, controlling through proper design, implementing engineering and administrative controls, enacting preventative maintenance and safe work procedures (including lockout/tagout), and providing ongoing occupational health and safety training.

Where hazards cannot be adequately controlled by these means, Supplier Personnel are to be provided with appropriate, well-maintained, personal protective equipment, and educational materials about risks to them associated with these hazards. Reasonable steps must also be taken to remove pregnant women and nursing mothers from working conditions with high hazards; remove or reduce any workplace health and safety risks to pregnant women and nursing mothers, including those associated with their work assignments; and provide reasonable accommodations for nursing mothers.

B. Operational and Transportation Safety

Suppliers providing transportation, logistics, maintenance, or operational services must comply with all applicable transportation safety regulations and maintain equipment in safe operating condition.

When performing work at Groendyke Transport facilities or job sites, Suppliers must comply with all Groendyke Transport safety requirements, complete required training, and promptly report incidents, injuries, hazards, and near misses.

C. Environmental Stewardship

Suppliers are expected to operate in an environmentally responsible manner and comply with all environmental laws and regulations. Suppliers should strive to reduce environmental impacts through responsible resource management, waste reduction, pollution prevention, and energy efficiency.

Suppliers are encouraged to measure and reduce greenhouse gas emissions for their businesses through means including analysis of energy use and identification of opportunities to increase efficiencies and use of energy generation derived from renewable resources.

III. Human Rights and Labor Standards

Groendyke Transport expects all Suppliers to treat all individuals, including Groendyke Transport personnel and Supplier Personnel, with respect and dignity. Suppliers must operate in alignment with the requirements provided below.

A. Respect and Non‑Discrimination

Suppliers must maintain workplaces characterized by professionalism and respect for the dignity of all individuals. Discrimination, harassment, retaliation, violence, or abusive behavior will not be tolerated. Specifically, no Supplier shall engage in discrimination or harassment based on race, color, age, gender, sexual orientation, gender identity and expression, ethnicity or national origin, disability, pregnancy, religion, political affiliation, union membership, covered veteran status, protected genetic information, or marital status in hiring and employment practices such as wages, promotions, rewards, and access to training.

There is to be no harsh or inhumane treatment including violence, gender-based violence, sexual harassment, sexual abuse, corporal punishment, mental or physical coercion, bullying, public shaming, or verbal abuse of Supplier Personnel; nor is there to be the threat of any such treatment.

B. Child Labor and Forced Labor

Suppliers must not use child labor, forced labor, bonded labor, involuntary prison labor, or engage in human trafficking. All work must be voluntary. Child labor is not to be used in any stage of Supplier’s business. The term “child” refers to any person under the age of fifteen (15), or under the age for completing compulsory education, or under the minimum age for employment in the country, whichever is greatest. Suppliers shall implement an appropriate mechanism to verify the age of workers. Young workers under the age of eighteen (18) shall not perform work that is likely to jeopardize their health or safety, including night shifts and overtime.

Forced, bonded (including debt bondage) or indentured labor, involuntary or exploitative prison labor, slavery, or trafficking of persons is not permitted. This includes transporting, harboring, recruiting, transferring, or receiving persons by means of threat, force, coercion, abduction or fraud for labor or services. There shall be no unreasonable restrictions on any Supplier Personnel’s freedom of movement in the facility in addition to unreasonable restrictions on entering or exiting Supplier-provided facilities.

C. Wages and Working Hours

Suppliers must comply with applicable wage, overtime, and working hour laws and provide compensation and benefits consistent with legal requirements. Suppliers shall pay all Supplier employees not less than the minimum wage as defined by local ordinances and provide at least the minimum level of benefits stipulated by local laws and regulations. Supplier employees must be paid for all hours worked and, if applicable, receive overtime compensation as legally required within the country and local jurisdiction in which the work is performed.

No Supplier employee shall receive deductions from wages unless he or she has consented to do so in writing and in accordance with local law. For each pay period, employees shall be provided with a timely and understandable wage statement that includes sufficient information to verify accurate compensation for work performed. All use of temporary, dispatch, and outsourced labor will be within the limits of the local law.

D. Freedom of Association

Suppliers must respect Supplier Personnel’s rights to associate freely and collectively bargain in accordance with applicable laws. Supplier Personnel and/or their representatives shall be able to openly communicate and share ideas and concerns with Supplier’s management regarding working conditions and management practices without fear of discrimination, reprisal, intimidation, or harassment.

E. Worker Concerns

Suppliers should maintain processes that allow Supplier Personnel to raise workplace concerns confidentially and without fear of retaliation.

IV. Sustainability and Responsible Care® Alignment

Groendyke Transport recognizes the importance of sustainability and responsible chemical management within the transportation and logistics industry.

Groendyke Transport supports the principles of Responsible Care®, a global initiative within the chemical industry that promotes continuous improvement in health, safety, environmental performance, and community engagement.

Suppliers that support, provide products or services in, or otherwise engage with the chemical and logistics supply chain are encouraged to operate in a manner consistent with Responsible Care principles, including:

  • Protecting the health and safety of Supplier Personnel, customers, and communities

  • Minimizing environmental impacts and promoting sustainable operations

  • Improving safety performance across the supply chain

  • Ensuring responsible management of chemicals and materials

  • Engaging openly with stakeholders about environmental, health, and safety performance

Suppliers are encouraged to collaborate with Groendyke Transport to improve sustainability performance, reduce emissions, improve operational efficiency, and support environmentally responsible transportation practices.

V. Monitoring and Compliance

Suppliers shall adopt or establish a management system with a scope that is related to the content of this Code. The management system shall be designed to ensure: (a) compliance with applicable laws, regulations, and customer requirements related to the Supplier’s operations and products; (b) conformance with this Code; and (c) identification and mitigation of operational risks related to this Code. It should also facilitate continual improvement. Suppliers should maintain documentation demonstrating compliance with this Code and applicable laws and regulations. Suppliers should perform periodic self-evaluations to ensure conformity to legal and regulatory requirements, the content of the Code, and customer contractual requirements related to social and environmental responsibility. In addition, each Supplier should establish a process for timely correction of deficiencies identified by internal or external assessments, inspections, investigations, and reviews.

Each Supplier shall feel encouraged to proactively approach Groendyke Transport with innovative ideas which contribute to further social, economic or environmental improvement. Groendyke Transport values the open exchange of new ideas and is willing to explore new opportunities jointly with Suppliers.