Last Modified: June 12, 2025

INTRODUCTION

Avantus’ Vendor Code of Conduct (the “Code”) defines the guidelines and requirements that Avantus expects consultants, contractors, service providers and suppliers of goods and/or services (“Vendor(s)”) of Avantus LLC and any of its subsidiaries and affiliates (together with Avantus Clean Energy LLC, “Avantus”), including Vendor and Vendor’s agents and representatives, to strive to follow in their normal business activities.

Avantus is committed to respecting the highest standards of labor, human rights, environmental, and ethical conduct. Our Code is based on internationally recognized human rights, as set out in the United Nations’ International Bill of Human Rights and the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work ¹. Avantus reserves the right to require Vendor’s compliance with any amendments to the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work upon prior written notice to Vendor.

Avantus will take steps to work with Vendor to ensure that Vendor’s business practices are consistent with the Code; however, Vendor is ultimately responsible for ensuring their compliance with the Code. This Code applies both in our selection of any new Vendor and in our ongoing relationships with our existing Vendors. We expect our Vendors to not only conduct business in a manner consistent with this Code, but also to set similar expectations within their own supply chain. Avantus may request Vendor to participate in audits, site visits, data collection, and reporting practices related to their compliance with the Code.

The Code represents a minimum standard which Vendor is expected to follow and where there are differences between the Code and applicable local or national laws and regulations, Avantus expects Vendor to follow the stricter standard.

Vendor must promptly report to Avantus any violation of the Code. Avantus will work with Vendor to correct any identified issues and ensure compliance. Failure to comply with the Code may result in the imposition of a remediation plan, removal of Vendor from Avantus’ sites or projects, or termination of the business relationship.

Avantus reserves the right to modify the provisions in this Code based upon evolving legal and regulatory agencies that it is subject to. If Avantus updates the Code, Avantus shall notify Vendor in written form.

Vendor must comply with their written contract, agreement, and/or purchase orders with Avantus. This Code is intended to complement the written contract, agreement, and purchase orders, not to replace them. Nothing in this Code is meant to supersede any more specific provisions in a particular contract, and to the extent there is any inconsistency between this Code and other provisions of a particular contract, the contract provision will control.

LABOR, HUMAN RIGHTS & RESPONSIBLE SOURCING

Labor and Human Rights in the supply chain is of the utmost importance to Avantus. To ensure high standards across our supply chain, the standards outlined in this section are intended to mitigate possible work-related issues at project sites and address potential risks associated with sourcing materials for solar and battery energy storage systems. Vendor must maintain employee records in accordance with the relevant local, state and federal labor laws and industry requirements and, upon Avantus’ written request, provide employee records in a timely manner.

Voluntary Labor
All labor must be voluntary. Slave, underage, forced, trafficked, bonded (including debt bondage) or indentured labor, involuntary prison labor, slavery, or trafficking of persons will not be tolerated. This includes transporting, harboring, recruiting, transferring, or receiving vulnerable persons by means of threat, force, coercion, abduction, or fraud, or making payments to any person having control over another person for the purpose of exploitation. Workers must be allowed to maintain control over their identity documents.Workers must be free to leave their employer after reasonable notice.

Employers, agents, and sub-agents may not hold or otherwise destroy, conceal, or confiscate identity or immigration documents, such as government-issued identification, passports, or work permits. Employers can only hold documentation if such holdings are required by law. In this case, at no time should workers be denied access to their documents. Vendors’ workers’ contracts shall clearly convey the conditions of employment in a language understood by the workers. Third-party recruitment agencies used by Vendors shall be compliant with the provisions of this Code and applicable laws and regulations. This Code shall be made available to workers upon request, and it is encouraged that Vendors inform employees of their rights and the concepts presented throughout this Code.

Labor Hours
Vendors must provide workers with rest days and must ensure that working hours are consistent with the relevant local, state and federal labor laws and industry requirements.

Child Labor
There must be no recruitment or employment of child labor.No individuals shall be hired under the legal minimum age for employment in the country.Vendors must have policies and programs which prevent the recruitment and employment of child labor.

Vendors shall employ only workers who are at least 15 years of age or the applicable minimum legal age, whichever is higher. If any underage labor is detected, the Vendor shall immediately stop such underage labor and ensure the worker recruitment process includes robust safeguards adequate to detect and prevent underage labor from being employed in the future. The use of legitimate student intern programs, which comply with all applicable laws, regulations, and applicable International Labor Organization (“ILO”) conventions, is supported.

Young workers over the legal minimum age for employment may be hired, however, young workers under the age of 18 shall not perform work that could jeopardize the health or safety of young workers, including night shifts and overtime, or work longer hours than is permitted by local law consistent with applicable ILO conventions.

Non-Discrimination
Vendors shall comply with national and other relevant laws protecting against discrimination and harassment and shall be committed to a diverse and equal opportunity workplace. Vendors shall not engage in unlawful discrimination based on race, color, age, gender, gender identity, sexual orientation, ethnicity, disability, pregnancy, religion, political affiliation, union membership or marital status in hiring and employment practices, such as wages, promotions, rewards, and access to training.

Hiring and Employment Practices
Vendors must implement hiring practices that accurately verify workers’ age and legal right to work in the country prior to employment.Job seekers and current employees shall not be charged or required to pay fees or deposits in order to gain or maintain their employment.All terms and conditions of employment including, but not limited to, hiring, pay, training, promotion, termination, and retirement must be based on an individual’s ability and willingness to do the job.

Compensation
Vendors must compensate all workers with wages, overtime premiums, and benefits that meet or exceed local labor laws or collective agreements, whichever are higher.

Freedom of Association and Collective Bargaining
Where local laws and regulations permit, Vendors shall respect, and shall not interfere with, the right of workers to form and join worker council or trade unions of their own choosing, to bargain collectively and to engage in peaceful assembly, and respect the right of workers to refrain from such activities.

Workers and/or their representatives shall be able to openly communicate and share ideas and concerns with management regarding working conditions and management practices without fear of discrimination, retaliation, interference, or harassment.

Protection of Identity and Non-Retaliation
Vendors are recommended to provide an anonymous reporting mechanism for managers and workers to report workplace grievances. Vendors are expected to protect whistle-blower confidentiality and prohibit retaliation.

Responsible Material Sourcing
Vendors should share our commitment to responsible sourcing and transparency. Vendors shall ensure that materials acquired for use in products sold to Avantus were obtained and processed in a manner that adheres to local environmental and human rights regulations and requirements, and if applicable, trade agreements. Vendors shall confirm and maintain records that materials used are not associated with human rights abuses and shall avoid sourcing from regions where forced labor is prevalent as identified in the Uyghur Forced Labor Prevention Act (UFLPA) entity list.

Vendors shall comply with United States and any other applicable trade laws. Vendors shall not engage in direct or indirect business, purchasing or supply activities, or other dealings with countries or persons that are subject to trade embargoes, prohibited persons lists, economic sanctions, or import or export controls under such laws.

HEALTH AND SAFETY

Safe and Healthy Work Environment
Vendors must follow all relevant health and safety laws and regulations, provide workers with a safe and healthy work environment and, if applicable, safe and healthy dormitories and canteens. Vendors shall take proactive measures to prevent workplace hazards, including hazards to the physical structure of buildings and facilities.Vendors must appoint a senior management representative to be responsible for ensuring a safe and healthy workplace environment.

Health & Safety Training and Communication
Vendors shall provide workers with appropriate workplace health and safety requirements and regular and recorded health and safety training in their primary language. Such training should be repeated for new or reassigned workers.Vendors are expected to clearly post in their facilities health and safety related information in accordance with local law and regulations. Vendors are encouraged to implement a health and safety management system such as Occupational Health and Safety Assessment Series (OHSAS) 18001 or equivalent.

Worker Health & Safety Committees
Vendors are encouraged to initiate, document as needed and support worker health and safety committees to enhance ongoing health and safety education and to encourage worker input on and participation in health and safety issues in the workplace.

Recordkeeping and Reporting Requirements
Vendor shall utilize appropriate recordkeeping and reporting mechanisms to meet relevant health and safety laws and regulations and, upon Avantus’ written request, provide records in a timely manner.

BUSINESS ETHICS

Avantus is committed to ethical business practices, and we hold our Vendors to the same high standards. It is Avantus’ policy to comply with all applicable laws and regulations of the countries and regions in which we operate and to conduct our business activities in an honest and ethical manner.Vendors must comply with the following ethical business practices and Vendor is responsible for assuring that each of its contractors of all tiers comply with the following ethical business practices.

Business Integrity and Anti-Corruption
Vendors shall be ethical and uphold the highest standards of integrity in all business interactions. Vendors shall comply with all applicable laws and regulations, including anti-corruption laws. Vendors must not offer, promise, give, or authorize the giving of anything of value, including a bribe, rebate, payoff, influence payment, facilitation payment, kickback, or other unlawful payment, to any government official, political party, candidate for public office, or other person, directly or indirectly, in order to obtain or retain business, gain any unfair or improper advantage, or influence any act or decision of a government official or individual in the private sector.

Maintain Accurate Records
Vendors must create and maintain accurate and verifiable records and not alter any record entry to conceal or misrepresent the underlying transaction represented by it. All records, regardless of format, made or received as evidence of a business transaction must fully and accurately represent the transaction or event being documented. When a record is no longer needed to conduct current business, records should still be retained based on the specific provisions in the written contract or Vendor’s record retention policy, whichever is greater.

Conflicts of Interest and Insider Trading
Vendors shall avoid any actual or apparent conflicts of interest in their work with Avantus and will promptly disclose any known personal, family, or business relationships with Avantus employees, management, or board members. Vendors will support Avantus’ actions to remediate any actual or apparent conflict.

Avantus partners with Vendors to meet shared goals and obligations and in doing so may share confidential information. Insider trading laws and Avantus policy prohibit Vendors’ use of any material non-public information obtained while working with Avantus to trade or tip others to trade in any securities.

Money Laundering
Vendors must not engage in money laundering, which involves making money or goods generated by illegal activity appear to have come from a legitimate source. It is generally unlikely that Avantus’ Vendors will engage in or encounter money laundering situations, but it is important for Vendors to be aware of and exercise due diligence to avoid any such activity, and to notify Avantus promptly if any situation or transaction that the Vendor encounters raises red flags about possible money laundering.

Fair Competition and Fair Dealing
Vendors must comply with applicable competition and antitrust laws and regulations.Avantus expects our Vendors to conduct business honestly and fairly and not take unfair advantage of anyone through any misrepresentation of material facts, manipulation, concealment, abuse of privileged information, fraud, or other unfair business practice.

ENVIRONMENT

Avantus is committed to delivering clean, renewable energy at scale and to protect the climate for future generations. We are committed to improving sustainability and protecting the environment in the way we operate, and we expect Vendors to do the same.Vendors must ensure that every manufacturing facility and all of Vendors’ products and services comply with all applicable environmental laws, regulations and required permits, including those related to waste disposal, air emissions, discharges, toxic substances, hazardous waste disposal, and standards ISO 14001 and ISO 45001 (if applicable).

INFORMATION SECURITY

Confidential/Proprietary Information
Avantus expects our Vendors to properly handle sensitive information, including confidential, proprietary, and personal information.Information must not be used for any purpose (e.g., advertisement, publicity, and the like) other than the business purpose for which it was provided, unless there is prior authorization from the owner of the information. Vendors should not disclose to Avantus any confidential, proprietary, or personal information that belongs to any third party without prior written consent.

Intellectual Property
Vendors must comply with all applicable law governing intellectual property and other proprietary rights, including patents, copyrights, trademarks, and trade secrets.Avantus owns and shall retain all such rights with respect to the inventions, materials, services, know-how, and trade names Avantus has developed or purchased and uses.Vendors shall respect and protect the intellectual property of Avantus and its third parties, and must not use any infringing materials in the goods or services provided to Avantus.

Public Disclosure of Business Relationship or Dealings with Avantus
Vendors wishing to inform third parties or to make it publicly known that they do business with Avantus must request and receive express written consent from Avantus.

Data Privacy
Vendors must protect the confidential and proprietary information of others, including personally identifiable information (PII), from unauthorized access, destruction, use, modification, transfer, and disclosure, and shall comply with the relevant data protection and other laws, regulations, and best practices for protecting such information.

Security
Avantus expects our Vendors to maintain appropriate security standards in order to protect confidential and proprietary information that Vendors receive from or in relation to Avantus. At minimum, Vendors should:

• Implement effective electronic, physical, and administrative security controls.
• Continuously assess and monitor security threats and vulnerabilities and the Effectiveness of Vendors’ controls.
• Communicate security requirements to Vendors’ employees and subcontractors as applicable.
• Promptly report to Avantus any breach of security that may be impactful or relevant to the business or data of Avantus, its third parties, or partners.

GOVERNANCE

Avantus reserves the right to audit Vendor’s records, at Vendor’s cost and no more than once per calendar year, to ensure Vendor’s compliance with the Code, unless a prior audit in such calendar year reveals a discrepancy or in the event Vendor discloses noncompliance to Avantus. Avantus encourages Vendor to implement policies and procedures to ensure compliance with the standards in this Code.Avantus may request Vendors to participate in audits, site visits, data collection, and reporting practices related to this compliance.

Vendors shall ensure compliance within their own supply chain.

RAISING COMPLIANCE QUESTIONS AND CONCERNS

Vendor must notify Avantus of any concern, violation or suspected noncompliance involving or affecting Vendor or its business activities. Raising questions and concerns allows Avantus and Vendor to address problems early and minimize potential harm to both Avantus and Vendor, our stakeholders, and our reputations. As one of our Vendors, you are required to self-report concerns or incidents of noncompliance involving your employees or your third parties within 24 hours of discovery. Your employees and Vendors should also report suspected noncompliance directly to Avantus. All reports are confidential and can be made through any of the following channels:

• Talk to your Avantus business contact
• Send an email to transactions@avantus.com
• Submit an anonymous report, where local law permits, by completing this online form.

This Code is available on our website. Vendors are encouraged to inform employees of their rights and the concepts presented throughout this Code and to enforce a zero-tolerance policy for retaliation or intimidation against anyone who reports noncompliance.

CONSEQUENCES OF FAILURE TO COMPLY

Failure to comply with laws and this Code can have severe consequences for your company, our company and the people involved. In addition to potentially damaging each of our reputations, conduct that violates the Code may also violate the law. Violations of this Code may lead to disciplinary action, up to and including termination of our business arrangements.

¹ Please note, while this code of conduct is in alignment with the conventions of the ILO, depending on where work is performed (i.e., within the United States vs outside of the United States), there may be trade agreements, trade laws, and/or local regulations that may supersede the requirements outlined in the ILO. Where work is done in the United States, the ratified ILO conventions and domestic labor laws and practices apply.