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Supplier Code of Conduct

This Code of Business Conduct for Suppliers (this “Code”) sets forth basic principles for supplier conduct when working with Pinnacle Operating Corporation and its subsidiaries. Pinnacle is committed to these principles and expects its suppliers to be as well.

The expectations in this Code do not replace or alter specific requirements in Pinnacle's contracts with suppliers. Rather, these expectations are intended to supplement the specific requirements in such contracts. If a contractual term is stricter than these expectations, the supplier must meet the stricter contractual requirement.

HUMAN RIGHTS & LABOR:

Respect Freedom of Association and Collective Bargaining: Suppliers will respect the rights of employees to associate, organize and bargain collectively as well as the rights of employees to refrain from doing so.

No Human Rights Abuses: Suppliers will conduct business in a way that is not complicit in any human rights abuses, including child labor, slave labor and human trafficking.

No Discrimination: Suppliers will not engage in unlawful discrimination in their employment practices.

Appropriate Work Hours and Wages:Suppliers will comply with all  applicable laws on work hours and overtime, as well as applicable laws on wages and benefits.

ENVIRONMENT, HEALTH & SAFETY:

Respect the Environment: Suppliers will comply with all applicable environmental laws. Supplier will have systems in place in place to ensure safe management of waste, air emission and wastewater discharges.

Protect Health and Safety: Suppliers will provide their employees and others working on their premises with safe and healthy workplaces.

ETHICS AND LEGAL REQUIREMENT:

Avoid Conflicts of Interest: Suppliers will avoid any interaction with a Pinnacle employee that may conflict, or appear to conflict, with that employee acting in the best interests of Pinnacle. This includes offering payments or employment opportunities to Pinnacle employees.

No Bribery: Suppliers will not engage in any form of commercial bribery or otherwise offer any incentive to any Pinnacle employee or Pinnacle employee's family or friends in order to obtain or retain Pinnacle business. Suppliers will comply with the U.S. Foreign Corrupt Practices Act, the UK Bribery Act and all other local or otherwise applicable laws dealing with the bribery of government officials.

Fair Competition: Suppliers will comply with all applicable laws regarding fair competition and antitrust.

Accurate Accounting and Business Records: Suppliers will keep  – and provide to Pinnacle upon request – accurate records of all matters related to the supplier's business with Pinnacle.

Protect Information: Suppliers will secure Pinnacle's private and confidential information in the supplier's possession, use such information per our instructions and safeguard it from unapproved or unintended disclosure. This obligation continues after our business relationship ends.

COMPLIANCE:

Compliance with Laws: In addition to the legal standards mentioned in this Code, suppliers will comply with all applicable laws and regulations in the provision of products or services to Pinnacle.

Implementation of Systems and Controls: Pinnacle expects suppliers to implement systems and controls to promote compliance with applicable laws and the principles set forth in this Code, including policies, training, monitoring and auditing mechanisms.

Applicability to Supply Chain: Suppliers should also apply these or similar principles to the subcontractors and suppliers they work with in providing goods and services to Pinnacle.

Assessment and Monitoring: Suppliers are responsible for monitoring and documenting their compliance with this Code and their efforts to promote compliance within their supply chain. Pinnacle reserves the right to investigate any instances of a supplier’s non-compliance with this Code of which it becomes aware. Suppliers who are not in compliance with this Code are expected to implement corrective actions or they may not be considered for future business.

REPORTING CONCERNS: Suppliers who believe that a Pinnacle employee or anyone acting on behalf of Pinnacle has engaged in illegal or otherwise improper conduct with respect to their business with the supplier should report the matter to Pinnacle. Suppliers should also report any potential violation of this Code. Reports may be made via email at suppliercodeofconduct@pinnacleag.com.