SUPPLIER CODE

WIN NUTRITION – SUPPLIER CODE OF CONDUCT

Last updated June 19, 2025

WIN Nutrition (“WIN,” “we,” “our,” or “us”) is dedicated to delivering custom nutrition products with uncompromising quality, innovation, and service. We believe a responsible supply chain balances today’s needs with those of future generations, and we are committed to strong environmental, social, and governance (ESG) principles. This Supplier Code of Conduct (“Code”) sets the minimum standards we expect from every vendor, consultant, contract manufacturer, raw-material producer, logistics provider, and other business partner (“Supplier Partner”).

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GUIDING PRINCIPLES

1. Adherence to Law

Supplier Partners must:

• know and comply with all laws, regulations, and industry standards that apply to their operations and the goods or services supplied to WIN.
• monitor legal changes and update policies and practices accordingly.
• treat legal requirements as a baseline, not a ceiling.
• promptly alert WIN to any material issue affecting product safety, quality, or regulatory compliance.

2. Business Integrity

Supplier Partners must:

• compete for WIN’s business fairly and ethically.
• never offer or accept bribes, kickbacks, or improper incentives
• limit gifts or hospitality to nominal, customary business courtesies—never cash or cash equivalents.
• avoid conflicts of interest with WIN employees or representatives.
• cascade equivalent integrity expectations to their own suppliers and subcontractors.

3. Recordkeeping

Supplier Partners must:

• maintain accurate, honest, and timely books and records in accordance with applicable standards.
• implement robust quality, audit, and compliance processes covering product safety and labor practices.
• disclose, upon reasonable request, facility locations and origin of materials to enable traceability.

4. Good-Faith Dealing

Supplier Partners must:

• conduct business transparently and honor commitments.
• communicate material issues promptly, accurately, and completely.
• manage unexpected events proactively and collaboratively.

5. Dignity, Respect, and Human Rights

Supplier Partners must:

• operate safe, healthy, and inclusive workplaces.
• respect workers’ freedom of association and collective bargaining rights.
• pay competitive, lawful wages and comply with working-hours regulations.
• prohibit child labor, forced labor, and human trafficking in all operations and supply chains.
• prohibit discrimination based on race, color, national origin, gender, marital status, sexual orientation, religion, disability, or any other protected characteristic.
• respect land and resource rights, particularly of Indigenous peoples and local communities.

6. Protection of WIN’s Information, Assets, and Interests

Supplier Partners must:

• safeguard WIN’s confidential information, intellectual property, and physical assets.
• notify WIN immediately of any unauthorized disclosure or security incident involving WIN data.
• comply with data-protection laws governing any personal information processed on WIN’s behalf.
• maintain rigorous product-safety controls to protect WIN’s reputation and customers.

7. Environmental Responsibility

Supplier Partners must:

• minimize environmental impact through resource efficiency, waste reduction, and emissions control.
• protect water resources by reducing usage, preventing contamination, and safeguarding community access.
• work toward climate, land, air, and biodiversity stewardship consistent with international frameworks (e.g., UN Guiding Principles on Business and Human Rights, ILO Core Conventions, OECD Guidelines for Multinational Enterprises).
• provide effective grievance mechanisms for workers and stakeholders to raise concerns confidentially and without retaliation.

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COMPLIANCE, INVESTIGATIONS, AND CORRECTIVE ACTIONS

WIN builds trust-based relationships with ethical suppliers. We may request data, certifications, and on-site or remote audits to verify compliance. Supplier Partners must cooperate fully with such requests and ensure their own suppliers uphold these standards.

If WIN identifies potential breaches, we will typically investigate and, where appropriate, collaborate on a corrective-action plan. During an investigation, WIN may suspend orders. Failure to remedy a violation or to cooperate may result in termination of our business relationship.

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GENERAL

• Supplier Partners are independent contractors; this Code does not create a joint venture, partnership, agency, or employment relationship.
• WIN may amend this Code at any time and will communicate material changes.
• Questions about this Code should be directed to info@winutrition.com.

By supplying goods or services to WIN Nutrition, Supplier Partners confirm their understanding of, and commitment to, this Code of Conduct.