AML RightSource Supplier Code of Conduct

Introduction

Our Corporate Mission is to be THE global, end-to-end, tech-enabled services company serving as a true partner and trusted advisor to our clients by helping optimize people and reimagine compliance. Our values: Teamwork; Integrity; Customer Centricity; Excellence; Innovation, and Partnership guide us in achieving our goals.

As a global organization, we take our clients’ trust very seriously. We comply with all applicable laws and regulations of the respective legal systems in which we operate. Therefore we also require our employees to act by the highest ethical and legal standards, which are embedded in our Employee Handbook. We also want to ensure that our supply chain complies with international standards.

As such, our expectations of our suppliers and service providers are outlined below around business ethics and integrity, working conditions, environment, and health and safety.

1. Business Ethics

All Suppliers are expected to conduct all AML RightSource business and related activities in an ethical, lawful, and professional manner and must act in good faith while exercising fairness, accuracy, integrity, and respect for others.

Legal Requirements

We expect our suppliers to fully comply with the applicable laws and regulations. Our suppliers shall abide by all national, local, and international laws relating to managing their businesses.

Confidentiality

Suppliers who may have access to confidential, proprietary, or private information (“non-Public Information”) of various types, including financial records, Client and Company business information, personally identifiable information (PII), intellectual property, and other information, are required to sign a Confidentiality Agreement with AML RightSource. All Suppliers must follow all applicable legal, contractual, and policy restrictions on the use non-public information.

Anti-Trust and Fair Competition

AML RightSource abides by laws regarding anti-competitive practices. Sales must not share market data, pricing, or or client lists with competitors to set prices for services in the marketplace. Our suppliers shall keep confidential any such information they obtain from us.

Suppliers shall compete fairly in accordance with all applicable anti-trust and competition laws.

Intellectual Property Rights and Business Secrets

AML RightSource is committed to respecting the intellectual labor and property of others. This commitment extends to all authors, producers, and publishers in all media. Since electronic information is highly portable and easily reproduced and transmitted, respect for the work and personal expression of others is especially critical in computer environments. Our suppliers shall only make appropriate use of confidential information and ensure that all intellectual property rights and business secrets are respected.

Conflict of Interests

Our suppliers must examine any situation in which they may have a conflict of interest and take steps to resolve the conflict. Should a situation arise that may present a conflict of interest between AML RightSource and our supplier, the supplier shall immediately inform AML RightSource and provide all relevant information so that AML RightSource can assess the situation. The Supplier, therefore, warrants that they will not be involved in or influence any decision which can give rise to any actual or perceived conflict of interest.

Anti-Bribery/Anti-Corruption

Our suppliers shall condemn and act against corruption in all its forms, including embezzlement, extortion, and kickbacks. Our suppliers shall not offer any gifts, any form of hospitality, entertainment events, or other benefits to AML RightSource employees that could improperly influence the AML RightSource employees. They shall have a zero-tolerance policy against all such practices.

No form of bribery may be offered or accepted.

Human Trafficking and Exploitation

Exploitation comes in many different guises. It includes the exercise of ownership over a person; services coerced under threat, human trafficking, and child labor exploitation. AML RightSource is proud to be part of the fight against Human Trafficking as part of its Anti-Money Laundering investigations.

AML RightSource condemns modern slavery in all its manifestations and has a zero-tolerance approach. We believe in the individual’s ethical treatment and respect for human rights and dignity and encourage and promote a corresponding attitude in its Suppliers.

AML RightSource does not employ in any capacity the services of any person under the minimum legal working age applicable to such a position; the Company does not engage any Supplier using slave labor. The Company will terminate its relationship with any Supplier who is in breach. Further legal steps may be taken, which may include criminal prosecution.

Supply Chain Due Diligence

Our suppliers should be aware of their responsibilities and due diligence obligations along the whole supply chain. They should take this into account when entering contracts with new subcontractors and vendors. They should perform appropriate reviews and risk assessments and support us (and their other clients) in meeting our legal obligations under local supply chain legislation as far as it applies to them.

The supplier shall also report to AML RightSource any potential risks or suspected breaches of requirements.

Diversity and Economic Sustainability

Our suppliers are encouraged to foster a workplace that is ethical, productive, inclusive, and respectful. We expect Suppliers to treat all people with respect and dignity, encourage diversity, remain receptive to diverse opinions, promote equal opportunity, and foster an inclusive and ethical culture.

2. Environment

AML RightSource expects our suppliers to act under any applicable statutory and international standards regarding environmental protection and sustainable procurement.

Suppliers should demonstrate a clear understanding of the environmental risks, impacts, and responsibilities associated with the products and services they provide. Suppliers should have an effective environmental policy, statement, or program to mitigate environmental risks.

We expect suppliers to minimize the environmental impact when operating and supplying their products and services. This includes but is not limited to the following:

Minimize Environmental Impact

Our suppliers are encouraged to make practical efforts to minimize using energy, water, and raw materials. Where possible, these should be renewable or sustainably sourced.

Suppliers should manage, measure and minimize emissions to air that are likely to cause pollution or contribute to climate change and minimize where possible. Suppliers should strive for alternative and climate-friendly solutions to reduce emissions and become climate neutral.

Environmental Compliance

Our suppliers shall comply with all local regulations and international standards. The handling, storage, movement, treatment, and disposal of all waste must be carried out under applicable regulations and in an environmentally responsible manner.

Recycling

Suppliers should make practical efforts to roll out initiatives to develop and promote the use of renewable resources if possible. Suppliers are encouraged to promote appropriate environmental and social considerations within the entire life cycle of their operations.

Climate Action

At AMLRS, we take proactive steps to address climate change and integrate sustainability into our operations and supply chain. We actively engage with our suppliers through regular communication and collaboration, working together to identify and implement greenhouse gas (GHG) emissions reduction strategies. Our procurement processes prioritize products and services with lower GHG emissions intensity or demonstrated reduction efforts, ensuring that sustainability remains a key factor in our purchasing decisions.

To reinforce our commitment, AMLRS conducts on-site ESG audits to assess supplier compliance with sustainability standards. These audits cover, but are not limited to, energy consumption, GHG emissions, water management, waste reduction, working conditions, biodiversity impact, ethical sourcing, chemical management, labor rights, occupational health and safety, and supply chain transparency. Through these assessments, we ensure continuous improvement and accountability in our supply chain, fostering a responsible and sustainable business ecosystem.

To further minimize our carbon footprint, we have introduced measures to reduce emissions from business travel, employee commuting, and downstream transportation. Additionally, we continuously work with our suppliers to enhance energy efficiency in operations and encourage the adoption of renewable energy solutions across the value chain. By embedding these initiatives into our business practices, AMLRS is committed to fostering a more sustainable, resilient, and environmentally responsible supply network.

Diversity, Equality and inclusion

Suppliers are expected to cultivate a diverse, inclusive, and equitable workplace that upholds respect for all individuals, regardless of race, color, age, pregnancy status, gender identity, sexual orientation, ethnicity, disability, religion, political affiliation, union membership, marital status, or any other characteristic protected by applicable laws. They should actively promote equal opportunities in recruitment, hiring, professional development, and career progression. Suppliers must maintain a work environment free from discrimination and bias while implementing inclusive policies that foster workforce diversity and equitable representation.

The AML RightSource group of companies (AMLRS) is committed to fostering diversity within its supply chain by actively engaging with businesses owned by women, minorities, LGBTQ+ individuals, veterans, people with disabilities, and other underrepresented groups. This dedication ensures that diverse suppliers have meaningful opportunities to contribute to the company’s success while driving economic empowerment and social equity. By collaborating with these businesses, AMLRS enhances supply chain resilience and promotes a culture of inclusivity, collaboration, and shared success.

Right of AMLRS

AMLRS reserves the right to on-site audit, assessment, and assess supplier compliance at any time. This may include on-site evaluations and reviews of records related to key areas such as anti-corruption, information security, environmental impact, and labor and human rights standards. In cases of non-compliance, AMLRS may require corrective actions, terminate business relationships, or take legal measures as necessary. Suppliers are expected to fully cooperate with these assessments and demonstrate a strong commitment to compliance.

Capacity Building of Suppliers

AMLRS strengthens supplier capabilities by providing training and resources on environmental and social responsibility. We offer workshops, webinars, and educational materials covering sustainability, ethics, and compliance while supporting suppliers in minimizing greenhouse gas (GHG) emissions and integrating sustainable practices. Through these initiatives, AMLRS aims to foster a more responsible, resilient, and sustainable supply chain.

Sustainability Incentives for ESG Compliance

AMLRS recognizes and values suppliers dedicated to maintaining high environmental, social, and governance (ESG) standards. To promote sustainable practices, we offer various incentives, including:

• Sustainability Certification: Acknowledging suppliers that demonstrate excellence in ethical and sustainable operations, enhancing their credibility in the market.
• Recognition & Awards: Periodic recognition of top ESG performers to elevate their industry standing.
• Preferred Supplier Status: Greater business opportunities for suppliers that consistently surpass ESG expectations.

Scope
This Code of Conduct applies to all suppliers working with AMLRS worldwide.