Supply Chain Ethics

TRS Workforce Solutions (TRS) has an absolute determination to do the right thing in all its business dealings.

We are committed to unyielding integrity and the highest standard of business conduct. This commitment is integral to TRS's continued success, and we believe it positively impacts our diverse and worldwide suppliers, contractors, customers, employees, and investors, and the communities where we do business.

All our suppliers and contractors are expected to do what is necessary to understand and comply with these expectations and, in turn, require their suppliers and subcontractors to conform as well. Our mutual success and continuing business relationships depend on it. TRS reserves the right to verify that a supplier or contractor's business operations meet these expectations. Failure to act in a manner consistent with these expectations may impede our ability to do business together in the future.

TRS expects our suppliers and contractors to maintain and enforce policies requiring adherence to lawful business practices that encompass our expectations, as appropriate. These expectations may occasionally be updated or amended.

Health, Safety and Environmental (HSE)

The health and safety of our employees and all personnel associated with our work is our highest priority. Our suppliers and contractors are expected to:

  • Provide a safe and healthy work environment that supports accident prevention, minimizes exposure to health risks, complies with applicable workers health and safety laws, and minimizes harmful impacts to the surrounding community.
  • Apply safe work practices (including regulatory and contract-specific requirements) to all their activities and instill safety in every aspect of their work processes and in the attitude and behavior of all their workers.
  • Conduct their operations in an environmentally responsible manner and in accordance with applicable environmental laws.

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Human Rights and Employment Practices

The welfare of the workers of our suppliers and contractors is critical to TRS successfully performing our work. Our suppliers and contractors are expected to:

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  • Support and respect human rights and avoid complicity in human rights abuses, including through responsible sourcing of conflict minerals.
  • Perform work without the use of forced, compulsory, bonded, or indentured labor.
  • Never use misleading or fraudulent practices during the recruitment of employees or offering of employment.
  • Treat all their workers with dignity, respect, and fairness.
  • Conduct all their operations in a socially responsible, non-discriminatory manner and in accordance with applicable laws including those associated with equal opportunity, child labor, forced or compulsory labor, working hours, wages and benefits, freedom of association, data privacy, and harassment-free work environment.

Financial and Operation Controls

Our suppliers and contractors are expected to:

  • Keep accurate, complete, fair, timely, transparent, and understandable financial and operational books, records, and accounts, and a system of effective internal controls

  • Create, retain, and dispose of business records in accordance with applicable legal and contractual requirements.
  • Keep accurate and complete records prepared for TRS, including records of work time and expenses.
  • Never share non-public information relating to TRS

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  • Comply with insider trading laws including the prohibition against buying or selling securities or advising (e.g., ripping} others to buy or sell securities while aware of material, nonpublic information relating to TRS.

Improper Payments

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TRS maintains zero tolerance for bribery and expects our suppliers and contractors to do the same. Bribery is directly or indirectly giving or promising to give anything of value co improperly influence actions of a third party. Bribes may include money, gifts, travel expenses, hospitality, vacations, expenses, below-market loans or products, reciprocal favours, political or charitable contributions, or any direct or indirect benefit or consideration.

Trade Controls

Our suppliers and contractors are expected co:

  • Know and comply with the export controls, economic sanctions, and anti-boycott laws applicable to their work with and for TRS.
  • Never participate in boycotts or other restrictive trade practices prohibited or penalized under applicable local laws.
  • Disclose to TRS any apparent conflict between U.S. and applicable local law requirements, such as the laws blocking certain U.S. restrictions adopted by Canada, Mexico, and the members of the European Union.

Money Laundering Prevention

Our suppliers and contractors are expected to follow applicable laws that prohibit money laundering and require the reporting of cash and other suspicious transactions.

Company Resources

TRS resources include property, assets, intellectual property, and confidential information. Our suppliers and contractors are expected to:

  • Safeguard TRS resources utilized while performing work, to use such resources solely for legitimate business purposes to advance the interest of TRS.
  • Honour the intellectual property rights of TRS and the third parties at all times.
  • Maintain, handle, and, if applicable, process any confidential information internally and on a need-co-know basis only, with utmost care and in accordance with applicable law.

Competing Fairly

TRS believes in the free-market system where merit, quality, price, and other objective factors determine who succeeds and who fails. Our suppliers and contractors are expected to:

  • Completely fair and honest.
  • Comply with applicable antitrust and competition laws.
  • Never participate in anti-competitive practices such as price fixing or bid rigging.

Government Work

Our suppliers and contractors who work on projects where government entities or agencies are involved are expected to follow any special rules that apply.

Reporting Concerns

Our suppliers, contractors, and their employees should promptly report any business conduct and ethics concern involving or affecting TRS, whether or not the concern involves the supplier or contractor, by contacting their TRS representative.

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