Supplier Code of Conduct

Purpose

Doman Building Materials Group Ltd. and its subsidiaries and affiliates (“Doman”) are committed to conducting business in a legal, ethical and socially responsible manner that reflects our values as a company. In furtherance of that commitment, Doman seeks to work with suppliers committed to doing the same. This Supplier Code of Conduct (this “Code”) sets forth its expectations of all suppliers of goods and services to Doman (collectively, “Suppliers”) related to labour and human rights, worker health and safety, ethical business practices and the environment. Doman requires Suppliers and their employees to commit to this Code as a condition of doing business and expects Suppliers to cascade similar expectations through their own supply chains.

The Doman Entities require honest and accurate recording and reporting of information. The Doman Entities’ accounting records are relied upon to produce reports for management, directors, shareholders, governmental agencies and persons with whom the Doman Entities do business. All of the Doman’s financial statements and the books, records and accounts on which they are based, must appropriately reflect the Doman Entities’ activities and conform to applicable legal, accounting and auditing requirements and to the Doman Entities’ system of internal controls.

Scope

This policy applies to all suppliers for all Doman divisions.

Compliance with Laws and Doman Policies

Suppliers must comply with all applicable laws and regulations, the supplier code of conduct as well as the Business Conduct and Ethics Policy. Suppliers are expected to be familiar with the basic requirements set out in this Code and to communicate these business practices to their own suppliers and subcontractors, and ensure they operate according to this Code. Doman reserves the right to terminate its relationship with Suppliers who fail to comply with this Code. Doman reviews this Code periodically and reserves the right to modify or amend this Code at any time at its sole discretion.

Labour and Human Rights

Child Labour

The unlawful use of child labour by Suppliers is strictly forbidden. If the jurisdiction in which the Supplier is doing business does not define “child” for purposes of minimum age of employment, the minimum age shall be 15 years of age. If the Supplier employs minors, the Supplier must observe all legal requirements regulating hours and working conditions for minors.

Forced Labour

All work must be voluntary. Suppliers shall not use any form of forced, trafficked, compulsory, bonded (including debt bondage), indentured, slave or involuntary or exploitative prison labour or purchase materials or services from companies engaging in such practices. Workers must be able to freely enter and leave the workplace, resign without repercussion, and Suppliers must not withhold worker identity documents, other original personal documents, pay deposits, or other valuable items as a condition of employment.

Hiring and Employment Practices

Suppliers must treat all workers with respect, dignity and fairness. Suppliers shall employ only those individuals who are legally authorized to work. Suppliers are responsible for verification of employees’ legal right to work through appropriate documentation. Suppliers shall maintain a workplace free from discrimination, inappropriate behavior, unfair treatment and retaliation. All forms of harassment and discrimination in the workplace shall be strictly prohibited. No worker shall be subject to corporeal punishment, or physical, sexual, psychological or verbal harassment or abuse.

Worker Hours and Compensation

Suppliers shall comply with all applicable wage, hour and other employment laws. Workers must not be required to work in excess of the relevant legal and industry standard limits on working hours, overtime hours and number of working days in any given period.

Health and Safety

Suppliers must provide workers with a safe and healthy work environment. Suppliers shall have systems in place to prevent, detect and respond to potential risks to the safety, health and security of all workers and must ensure their operations comply with all laws related to health and occupational safety.

Ethics

Gifts and Gratuities

Suppliers must not offer gifts or entertainment to Doman employees. This includes gifts of nominal value.

Anti-Bribery

Suppliers shall not engage in any form of bribery, kickbacks, corruption, extortion or embezzlement. This ban applies even when local laws may permit such activity.

Confidentiality and Data Protection

Suppliers must respect and protect all Doman information, electronic data, and intellectual property or technologies with appropriate safeguards. At a minimum, Suppliers must comply with all applicable privacy, data protection and information security laws and regulations. Suppliers shall apply information security and business practices that conform to industry standards and best practices and adequately protect the confidential information and data entrusted to them.

Management Systems

Suppliers shall implement management systems that ensure compliance with applicable laws, regulations, and this Code, identify and mitigate risks of non-compliance, and facilitate continuous improvement.

Communication

Suppliers must communicate the provisions of this Code to all employees, supervisors and suppliers.

Reporting

Suppliers shall have a process in place through which workers can report concerns or workplace grievances without fear of retaliation.

Environment

Suppliers shall conduct their operations in a way that conserves natural resources and minimizes the environmental impact of their activities. At a minimum, Suppliers must comply with all applicable environmental laws and regulations and have systems in place to ensure the safe handling, movement, storage, recycling, reuse and management of waste, air emissions and wastewater discharge.

Monitoring and Compliance

Supply chain transparency is required to confirm compliance to this Code. Doman reserves the right to audit Suppliers’ compliance with this Code. Audits may be conducted by Doman and/or its agents and contractors.

Date Issued: December 28, 2023 
Date Revised: December 17,2024