Supplier Code of Conduct

Introduction
Connie’s Tiny Kitchen Inc. and its shareholders, subsidiaries and affiliates (collectively, “Connie’s Tiny Kitchen”) fully intend to conduct their businesses in a socially responsible manner and in compliance with all applicable laws. We have adopted the Connie’s Tiny Kitchen Code of Conduct for our employees to reflect our commitment to the highest standards of ethical business conduct. We expect that our business partners that manufacture products or supply materials or services for Connie’s Tiny Kitchen (“Suppliers”) will do the same, and this Supplier Code of Conduct (“Code”) sets forth the standard of conduct by which Connie’s Tiny Kitchen requires our Suppliers and their contractors and subcontractors (“Suppliers”) to operate. This Code may be amended to reflect subsequently developed standards either by Connie’s Tiny Kitchen or a governmental, human rights or non-governmental organization who code Connie’s Tiny Kitchen chooses to adopt.

Purpose.
This Code is to inform Connie’s Tiny Kitchen’ Suppliers of our expectations and requirements regarding socially responsible, ethical and compliant operations that are required for the purpose of doing business with us. Connie’s Tiny Kitchen will conduct periodic and unannounced audits on our Suppliers to ensure that all Suppliers and facilities that produce materials and products for Connie’s Tiny Kitchen meet requirements of this Code.

Scope.
Each Supplier is subject to this Code. Additionally, subcontractors that produce partial assembly, piece goods or component parts where there is an identifiable Connie’s Tiny Kitchen proprietary trademark/name are also subject to the requirements of this Code.

Policy.
Connie’s Tiny Kitchen is committed to protecting the working rights and safety of the people who supply products, materials and services for Connie’s Tiny Kitchen, while recognizing and respecting the cultural and legal differences found throughout the world. Connie’s Tiny Kitchen will only do business with Suppliers who adhere to this Code. Connie’s Tiny Kitchen will review whether any Supplier has violated this Code. If a violation has occurred, Connie’s Tiny Kitchen will consult with the Supplier and determine the appropriate measures to be taken. The remedy will, at a minimum, include requiring the Supplier to take all steps necessary to correct such violations. If consultation and agreed upon measures fail to adequately resolve the violations within a specified time period, Connie’s Tiny Kitchen and the Supplier will implement a corrective action plan on terms acceptable to Connie’s Tiny Kitchen. Connie’s Tiny Kitchen reserves the right to terminate its relationship with any Supplier that continues to conduct its business in violation of the corrective action plan, in accordance with the terms set forth in the Supplier agreement.

Audit Ethics
The highest standards of integrity are expected in all aspects of the audit process. Any and all forms of bribery, corruption, deception and records falsification are strictly prohibited. The business relationship may be immediately impacted by any such finding.

Compliance with the Law and this Code
The business and labor practices of all Suppliers must conform to the requirements of applicable law and the requirements of this Code. Nothing in this Code is to be construed as encouraging, authorizing or condoning any action by any company or individual that breaches any applicable law or regulation, directly or otherwise. It is the responsibility of the Supplier to ensure that it understands and complies with this Code and to inform Connie’s Tiny Kitchen if and when any situation develops that causes a Supplier to operate in violation of this Code. Suppliers are expected to self-monitor their compliance with this Code. Suppliers are strongly encouraged to implement training and monitoring processes to ensure that the requirements of this Code can be met in a consistent manner.

Anti-Bribery and Anti-Corruption
Connie’s Tiny Kitchen has zero tolerance for bribery and corruption of any kind and in any form. Connie’s Tiny Kitchen is bound by international anti-bribery and anticorruption laws, including, but not limited to, the U.S. Foreign Corrupt Practices Act and UK-Bribery Act. Suppliers must comply with all applicable anti-bribery and anti-corruption laws, which includes not giving, accepting, soliciting or receiving anything of value if it would improperly influence someone or gain an improper or unlawful advantage. This is particularly relevant in dealings with government officials. Even the appearance of impropriety should be avoided at all times and under all circumstances.

Trade Compliance
Connie’s Tiny Kitchen is committed to complying with all customs, trade and export laws. Suppliers are expected to comply with all applicable U.S. and international trade laws and regulations, including import and export controls regulations, national and international sanctions and embargoes; and duties, levies and tax obligations that apply. Export controls and economic sanctions regulate when, where, and to whom we can sell, give, or otherwise transfer our products, services or technical data. Suppliers will establish and maintain programs and documentation to support country-of-origin production verification in order to prevent the illegal transshipping of merchandise.

Gifts and Other Conflicts of Interest
Connie’s Tiny Kitchen provides excellent products and services, and we expect the same quality and service from our Suppliers. Accordingly, any attempt to influence purchasing or selling decisions with gifts, gratuities, or payments to Connie’s Tiny Kitchen employees is strictly prohibited.

Employment Practices
The business and labor practices of all Suppliers must conform to the requirements of applicable law and the requirements of this Code. Nothing in this Code is to be construed as encouraging, authorizing or condoning any action by any company or individual that breaches any applicable law or regulation, directly or otherwise. It is the responsibility of the Supplier to ensure that it understands and complies with this Code and to inform Connie’s Tiny Kitchen if and when any situation develops that causes a Supplier to operate in violation of this Code. Suppliers are expected to self-monitor their compliance with this Code. Suppliers are strongly encouraged to implement training and monitoring processes to ensure that the requirements of this Code can be met in a consistent manner.

Anti-Bribery and Anti-Corruption
Connie’s Tiny Kitchen has zero tolerance for bribery and corruption of any kind and in any form. Connie’s Tiny Kitchen is bound by international anti-bribery and anticorruption laws, including, but not limited to, the U.S. Foreign Corrupt Practices Act and UK-Bribery Act. Suppliers must comply with all applicable anti-bribery and anti-corruption laws, which includes not giving, accepting, soliciting or receiving anything of value if it would improperly influence someone or gain an improper or unlawful advantage. This is particularly relevant in dealings with government officials. Even the appearance of impropriety should be avoided at all times and under all circumstances.

Trade Compliance
Connie’s Tiny Kitchen is committed to complying with all customs, trade and export laws. Suppliers are expected to comply with all applicable U.S. and international trade laws and regulations, including import and export controls regulations, national and international sanctions and embargoes; and duties, levies and tax obligations that apply. Export controls and economic sanctions regulate when, where, and to whom we can sell, give, or otherwise transfer our products, services or technical data. Suppliers will establish and maintain programs and documentation to support country-of-origin production verification in order to prevent the illegal transshipping of merchandise.

Gifts and Other Conflicts of Interest
Connie’s Tiny Kitchen provides excellent products and services, and we expect the same quality and service from our Suppliers. Accordingly, any attempt to influence purchasing or selling decisions with gifts, gratuities, or payments to Connie’s Tiny Kitchen employees is strictly prohibited.

Health and Safety
Conditions in all work-related facilities (including corporate housing) must be safe, clean, and consistent with all applicable laws and regulations for the workplace health and safety in the countries in which Suppliers operate.

Health and Safety Education
Employees must be trained on the importance of health, safety, and good sanitation. Suppliers must take steps and adopt procedures to prevent accidents, injuries, and the spread of communicable diseases. Readily understandable instructions and signs must be posted, and/or manuals must be accessible describing the safe operation and handling of dangerous equipment and hazardous materials. Employees who use hazardous or flammable materials or operate dangerous equipment must be properly trained. Personal Protective Equipment (PPE) must be provided to workers and must be adequate and appropriate to the hazards the worker encounters in their scope of work. Suppliers will create and maintain training records for all employees.

Material and Chemical Safety
All hazardous, combustible or flammable material must be stored in approved containers in designated storage areas, or in approved flammable liquid storage cabinets.

Safe Drinking Water and Sanitation
Safe drinking water must be provided and easily accessible at all times. There may not be any restrictions on the normal consumption of drinking water. Adequate and clean toilet and hand-washing facilities with basic hygiene amenities must be provided.

Environmental Requirements
All Suppliers must adhere to all applicable environmental laws and regulations regarding protection and preservation of the environment in their country. All required environmental permits and registrations must be kept current and must be available on premises for review. All hazardous materials and chemicals including waste water and solid waste generated from operations must be disposed of using environmentally responsible practices. Suppliers must comply with all local laws pertaining to the disposal or transport of waste water or other solid waste. Suppliers must also control and manage air emissions. They must obtain and maintain appropriate permits for air emissions as required by law. Suppliers must maintain an inventory of on-site ozone depleting chemicals (ODC) and work to reduce and eliminate their use. Connie’s Tiny Kitchen favors Suppliers who conduct their business using progressive environmental practices and take active steps to preserve and protect the well-being of the environment.

Conflict Minerals
Suppliers shall implement procedures to assure that no products or materials supplied to Connie’s Tiny Kitchen contain conflict minerals that directly or indirectly finance armed groups through mining or mineral trading in the Democratic Republic of Congo or an adjoining country. Conflict minerals include tantalum (columbite-tantalite or coltan), tin (cassiterite), tungsten (wolframite), gold, cobalt, or their derivatives. Upon Connie’s Tiny Kitchen’ request, Suppliers will fully cooperate in responding to any country of origin inquiries regarding conflict minerals (including requesting information from its own suppliers); provide requested documentation; and/or certify its compliance with this provision by providing a sworn declaration of one of its officers, directors, or managing agents.

Audits
Connie’s Tiny Kitchen employees or an authorized third party will conduct periodic audits on our Suppliers to ensure the condition of all Suppliers and facilities that produce the materials and merchandise for Connie’s Tiny Kitchen meet the standards set forth in this Code. Audits may be announced or unannounced.

No Exceptions
Compliance with this Code is mandatory. Domestic and international Suppliers supplying materials, products and/or services for Connie’s Tiny Kitchen are required to disclose their facilities and participate in the audits. Suppliers shall require the facility’s management to provide access to the facility and all books and records that will allow for a comprehensive audit to be conducted, including an opportunity for confidential and private interviews with facility employees selected by the auditor. No retaliation shall be taken against any employee or auditor. Refusal to fully disclose or cooperate may lead to termination of business by Connie’s Tiny Kitchen.

Zero Tolerance Violations
Connie’s Tiny Kitchen has zero tolerance for violations of the provisions of this Code related to Underage Labor, Forced or Compulsory Labor, Harassment, Nondiscrimination, and Anti-Bribery and Anti-Corruption, and Trade Compliance. Connie’s Tiny Kitchen reserves the right to reject, recall or return any product manufactured during the period when a Supplier is discovered to be in violation of Connie’s Tiny Kitchen’ Zero Tolerance Policy. This will be at the Supplier’s expense.

Cost of Audit
Suppliers are responsible for compliance with the provisions of this Code, including the costs of complying with an audit conducted by Connie’s Tiny Kitchen or its customers.

Denial of Audit
Connie’s Tiny Kitchen reserves the right to audit the Supplier’s compliance with this Code. If, after receipt of prior notice of intent to audit as indicated above, the Supplier refuses to grant the Connie’s Tiny Kitchen auditor access to the facility, denies access to review pertinent records, or denies access to reasonable and confidential interviews of workers, Connie’s Tiny Kitchen will regard such denial as a denial of the audit. The audit will cease immediately and Connie’s Tiny Kitchen will conduct an investigation to determine the severity and to ensure compliance.

External Customer Audit
A number of Connie’s Tiny Kitchen customers conduct regular audits. If the external customers conduct their own social responsibility compliance audit of the Supplier, the Supplier must ensure its human rights policies and programs satisfy those customer requirements. Connie’s Tiny Kitchen’ Suppliers must fully accept and cooperate with customer audits.