Supplier Compliance Policy

  1. 2Encapsulate Limited and its related entities (“2Encapsulate”) strive to maintain throughout their global operations a work environment that reflects the highest standards of business ethics and workplace behavior, and is committed to legal compliance and ethical business practices in its operations worldwide. In furtherance of these goals, 2Encapsulate expects all of its suppliers to comply with applicable laws and regulations in the places in which they do business, and to maintain the highest degree of ethics in their business dealings with 2Encapsulate. 2Encapsulate is firm in its resolve to do business with suppliers who share in its commitment to integrity. By contracting with 2Encapsulate, each supplier is representing and certifying to 2Encapsulate that it is in compliance with this Policy. If any standard set forth in this policy is, in the supplier’s judgment, deemed to violate an applicable local law, it must advise 2Encapsulate promptly in writing to the 2Encapsulate General Counsel.

    2Encapsulate expects compliance with applicable laws, regulations and standards regarding:

    • Anti-corruption and anti-bribery, including for example, the United States Foreign Corrupt Practices Act, the UK Bribery Act 2010 and the Organization for Economic Cooperation and Development Convention on Combating Bribery of Foreign Public Officials in International Business Transactions;

    • Fair trade, including free competition, anti-trust laws, and intellectual property rights;

    • Political contributions and payments;

    • Anti-slavery and human trafficking;

    • Maintaining accurate financial reporting systems and records relating to each supplier’s dealings with 2Encapsulate;

    • Trade embargos and boycotts (particularly United States anti­ boycott laws);

    • Government contracting;

    • Imports and exports and other global trading, including United States sanction laws as promulgated by the United States Department of Treasury Office of Foreign Asset Control and, including those related to technology;

    • Privacy, data and information security;

    • Discrimination, harassment, human rights abuse and retaliation; and

    • Fair and ethical employment practices including those relating to minimum age, child and forced labor; wages; hours; overtime and benefits; freedom of association and collective bargaining; and health, safety and the environment.

    In particular, suppliers engaging in business with 2Encapsulate are prohibited from engaging in the following conduct:

    • The offering or giving of direct or indirect, improper payments, gifts or other things of value, to any domestic or foreign government official or employee, as well as their representatives, agents or family members;

    • The offering or giving of discounts, entertainment, meals, transportation, gifts or other favors or personal benefits to 2Encapsulate employees, other than as expressly provided in the BCS;

    • Use of 2Encapsulate's name, assets, facilities or services without written authorization from authorized 2Encapsulate personnel or for any improper purpose;

    • Disclosure of confidential and proprietary information to any third party (including, without limitation, the press) without prior written authorization from authorized 2Encapsulate personnel;

    • Sub-contracting without the prior written consent of authorized 2Encapsulate personnel (all approved subcontractors are held to the same standards, policies, rules and regulations);

    • Improper discrimination in the work environment, including but not limited to discrimination on the basis of gender, race, age, color, national origin, disability, citizenship, veteran status, marital status, sexual orientation, religious or cultural beliefs;

    • Acts of sexual, physical, mental or any other form of harassment, abuse, disciplinary tactics or improper behavior in the workplace and in any work-related setting outside the workplace, such as during business trips, business meetings and business-related social events; and

    • Employing workers by means of force, threats of force or physical restraint, or by means of actual or threatened abuse of law or legal process, or by any other means or scheme, plan or pattern intended to cause the person to believe that if that person did not perform such labor or service, that person or another person would suffer serious harm or physical restraint.

    For any questions regarding 2Encapsulate’s Supplier Compliance Policy, please contact 2Encapsulate’s General Counsel.

    September 2025