WD-40 Responsible Sourcing Policy_Flipping Book

BUSINESS ETHICS

IN GENERAL The Company expects the highest standards of ethical conduct from all its Suppliers. Suppliers are required to comply with all laws, rules, regulations, and treaties applicable to the products and/or services provided to the Company in all locations in which business operations are conducted. Relevant items from the Code include:

ANTI-CORRUPTION Suppliers must not engage in, tolerate, or permit bribery, corruption, or other unethical business practices and must demonstrate that they have adequate procedures in place to prevent bribery in all commercial dealings. FAIR COMPETITION AND ANTI-TRUST Suppliers must comply with the competition / antitrust legislation laws in force. In particular, they must not enter into any anti-competitive agreements with competitors, other suppliers, or customers. INTELLECTUAL PROPERTY AND CONFIDENTIALITY Intellectual property is a valuable asset to our business. Suppliers must protect the Company’s intellectual property rights and manage technology and information in a manner that also maintains confidential information of the Company.

RESPONSIBLE SOURCING OF MATERIALS Suppliers must develop and exercise due diligence in their supply chains and management systems in order to identify risks and take appropriate steps to mitigate them, including raw materials or other inputs that originate from regions with high risks. High-risk regions include those associated with conflict, child labor violations as defined by the International Labour Organization, forced labor and human trafficking, gross human rights violations or other reasonably objective high-risk activities, including severe health and safety risks and negative environmental impacts. OTHER REQUIREMENTS Suppliers must also comply with the Business Ethics Compliance provisions of the Code; see Section VI - Business Ethics Compliance.

3 | WD-40 Company Responsible Sourcing Policy October 2024

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