Supplier Code of Conduct

Purpose of the Supplier Code of Conduct

The Supplier Code of Conduct outlines ShipBob’s expectations of its Suppliers (defined below) and provides guidelines with respect to responsible sourcing, including our commitments to human rights, the environment, health and safety, business ethics and the development of a diverse and sustainable supply chain. All Suppliers and business partners must comply with our Supplier Code of Conduct (“SCC”). We refer to “Suppliers” as any third party that provides goods or services to ShipBob for compensation, including, but not limited to, vendors, distributors, fulfillment partners, channel partners, agents, and contractors. All Suppliers must communicate these expectations throughout their supply chain.  Sub-contractors of Suppliers are also expected to comply with our Supplier Code of Conduct.   

All Suppliers must comply with all applicable national, state, and local laws/regulations in the markets where they operate. However, where local laws or standards differ from this Supplier Code of Conduct, we expect our Suppliers to comply with the more stringent standards and principles. 

In the spirit of continuous improvement, ShipBob is committed to working with and supporting our Suppliers to meet the requirements in this Supplier Code of Conduct. 

Introduction to Sustainable Procurement at ShipBob

The principles of sustainable procurement are integral to our business strategy: 

• Value creation 

• Sustainable environmental performance 

• Corporate social responsibility (CSR) 

Within ShipBob we are committed to 5 core values: Be Mission Driven, Be a Creative Problem Solver, Be Humble, Be Safety Minded and Be Resilient. These values are not only appropriate but create a strong foundation to underline our approach to sustainable development. 

Our approach to sustainable procurement includes how we work with our Suppliers; we integrate sustainable development into our procurement strategy, our day-to-day operations, and our relationships with Suppliers. 

All ShipBob entities, the ShipBob Fulfillment Network (“SFN”) partners and their suppliers are required to identify, prevent, and manage risks pertaining to health and safety, social responsibility, and environment in their supply chains, and we expect the same from our Suppliers. 

Our Commitment to Suppliers

ShipBob seeks to engage Suppliers that are socially responsible, behave with integrity and focus on sustainable development. Our goal is to partner with Suppliers to deliver value-for-cost procurement for ShipBob and ShipBob’s customers who will demonstrate the same principles to their Suppliers.  

ShipBob has established methodologies to implement strategic procurement strategies and to guide relationships with Suppliers. These guidelines ensure a fair, competitive, and transparent negotiation process consistent with our policies and values. 

We act with integrity and demonstrate good citizenship in our business dealings – we expect the highest standards of conduct from our own people. 

Our Expectations of Suppliers

ShipBob expects our Suppliers to meet high social, environmental and health and safety standards. Suppliers must adhere to the following standards: 

Business Integrity and Standards

Laws, Regulations, and Trade Control

We expect our Suppliers to comply with applicable laws, regulations, and industry standards. Our Suppliers must comply with trade sanctions and similar restrictions issued by recognized authorities, including the United Nations, the European Union and the United States.  We expect our Suppliers to comply with all applicable export and import control laws, and to ensure that their cross-border shipments are authorized under applicable laws. 

Competition and Antitrust Laws

Suppliers must comply with competition and anti-trust laws in the countries where they operate or sell products. Suppliers must not coordinate market conduct with competitors or their own Suppliers in a way that improperly restricts competition. 

Bribery and Corruption

Suppliers shall comply with all applicable anti-corruption laws and regulations and, to this effect, have a zero-tolerance policy towards any form of bribery, corruption, extortion, and embezzlement. Suppliers shall not offer, pay, solicit or accept bribes or make any other inducement (including kickbacks, facilitating payments, excessive gifts and hospitality, grants or donations) in relation to their business dealings with customers and public officials. Suppliers are expected to perform all business dealings transparently and these dealings shall be accurately reflected in their business books and records. 

As a minimum, we expect our Suppliers to: 

• Comply with the Foreign Corrupt Practices Act of 1977, the UK Bribery Act 2010 and locally applicable laws and regulations. 

• Never offer or accept anything of value where there is an intention of improperly influencing a business decision, or where the person is not permitted by their employer or local law to receive it. 

• Disclose to ShipBob where they or their associates may have connections with government officials.  

• Never bribe government officials of any kind. 

Conflicts of Interest

Suppliers will avoid conflicts of interest. Any situation that may create a conflict of interest with a Supplier’s work with ShipBob must be reported to ShipBob’s legal team. For example, our Suppliers must disclose whether one of their employees or employee’s relatives is related to a ShipBob employee that could make decisions that affect the Supplier’s or ShipBob’s business.

Gifts, Meals and Entertainment 

Suppliers must respect that ShipBob employees cannot provide or accept excessive or inappropriate meals or entertainment and may only offer or accept non-cash gifts of modest value occasionally. Gifts, meals and entertainment should never create a feeling of obligation or the impression of an obligation because this could be perceived as a bribe. We expect Suppliers to ensure they have appropriate controls in place so that gifts, meals or entertainment (or anything else of value provided to another party) are not bribes or perceived as such especially if the recipient is a government official. 

Business Records and Confidential Information

We expect Suppliers to keep accurate and up-to-date records of matters related to their business with ShipBob, and to demonstrate compliance with applicable laws and regulations. We expect our Suppliers to ensure appropriate technical and organizational security measures to safeguard ShipBob confidential and personal information, and to meet the requirements of applicable data privacy laws and regulations to ensure there is no disclosure of our confidential information to third parties without our prior authorization. We also expect our Suppliers to inform ShipBob immediately in the event of a potential or actual data breach, or if our information is released without authorization. 

Human Rights and Labor Standards

We want to make a positive contribution to human rights and society. We are committed to promoting and respecting human rights throughout our supply chain and complying with applicable laws in these areas, and we expect the same from our Suppliers. We expect our Suppliers to act in accordance with these laws, principles and commitments, and we have minimum standards in the following areas: 

Child Labor

Suppliers shall not use Child labor. The term “Child” for purposes of this code of conduct means any person under the age of 15 (or 14 where the law of the country permits) or under the applicable legal minimum working age. Suppliers employing Young Workers (“Young Worker(s)” for purposes of this agreement are those workers above the minimum age of employment but under the age of 18) must comply with applicable laws and regulations regarding hours, compensation, and must avoid conditions or restrictions that could be harmful to their morals, health, safety, education, and development.

Suppliers may use legitimate workplace apprenticeship programs for the educational benefit of any Young Worker. Suppliers shall implement and maintain a reliable system to verify the eligibility of all workers, including age eligibility and legal status of any foreign workers. 

Forced Labor

All labor must be voluntary. Suppliers shall not use or benefit from any form of human trafficking, including forced, compulsory, bonded, indentured or prison labor in their operations or in their supply chain under any circumstances. Suppliers must ensure that every worker is there voluntarily, meaning all workers shall have the freedom to leave the workplace outside of working hours and to terminate their working arrangement at any time without penalty. No worker shall be subject to any form of harsh or inhumane treatment, corporal punishment, threats of physical or sexual violence, or other forms of psychological or physical harassment, intimidation, abuse, coercion, or sanctions that result in wage deductions, reductions in benefits or compulsory labor. No part of any worker’s wages, benefits, property, or documents shall be withheld to force such worker to continue working.  

Protected Activities 

Suppliers shall not include any provision in an agreement that impairs or limits any rights an employee has to participate in any legally protected activities, such as (i) forming, joining, or supporting labor unions, (ii) bargaining collectively through representatives of employees’ choosing, (iii) discussing wages, benefits, or terms and conditions of employment, and (iv) discussing, or raising complaints about, working conditions for the purpose of mutual aid or protection of the employee or the Supplier’s other current or  

former employees, to the extent such activities are protected under applicable law.  To the extent a union represents Suppliers’ employees, Suppliers must abide by all applicable laws requiring the supplier to negotiate with such union in good faith to determine working conditions.  

Non-discrimination

Suppliers shall not discriminate in hiring, compensation, training, advancement, promotion, termination, retirement, or any other employment or work-related practice based on personal characteristics such as age, race, religion, color, ethnicity, national origin, disability, sexual orientation, gender, gender identity, gender expression, marital status or any other characteristic protected by applicable law. Suppliers should treat all workers with respect and dignity.  

Wages and Benefits

Suppliers shall ensure all employees are paid a fair wage, including overtime premiums and benefits that meet the higher of: the legal minimum standards established by applicable law, collective agreements, or appropriate industry standards. Suppliers shall provide payments and benefits in a timely manner as required by applicable law.  Suppliers shall not make any deductions from wages except for those permitted under applicable law.  

Suppliers shall provide proof of payment to workers in the workers’ native language showing (1) hours worked; (2) wage amounts and rates (including regular, overtime and bonus); (3) deductions; and (4) any other information required by applicable law. Suppliers shall also ensure proof of payment is accurate and clearly calculated and maintain proper documentation of wage statements for Suppliers’ internal records.  

Abuse and Harassment of Labor

Suppliers must strictly prohibit any kind of harassment, intimidation, bullying or abuse of any employee or worker. This includes any threat of physical punishment or disciplinary action, as well as physical, sexual, racial, psychological, or verbal harassment. 

Working Hours

We expect our Suppliers to ensure employees’ working hours are in compliance with applicable law or any collective agreements, as applicable.  Suppliers shall not require workers to work more than the maximum legally permitted number of regularly paid hours worked per week. Any additional overtime hours are voluntary and must not exceed the maximum legally permitted number of overtime hours worked per week. Suppliers shall use an industry-accepted time-keeping system to track worker hours.  

Rest and Meal Breaks 

Suppliers shall allow workers to take reasonable rest breaks, including bathroom breaks and shall allow all workers to take reasonable meal breaks. All meal and rest break periods must be administered and tracked in accordance with applicable law.  

Health and Safety Standards

ShipBob is committed to maintaining safe and secure working conditions for all workers. We expect our Suppliers to have the same approach. For our Suppliers, we have minimum standards in the following areas:

Laws and Regulations

Suppliers shall comply with applicable federal, state, and local health and safety laws and regulations, including those related to the construction and maintenance of facilities for employees and contract workers. Suppliers shall obtain, keep current, and comply with all applicable health and safety permits, registrations, and reporting requirements.  

Health and Safety Policy

Suppliers shall have a clear, publicly-available health and safety policy statement in place. Suppliers must be committed to developing and applying appropriate health and safety management systems, including clear assignment of management responsibility for health and safety, and monitor and report corrective actions against incidents (including accidents or near misses). Suppliers shall develop and implement emergency plans and response procedures that will minimize harm to life, environment, and property.  

Safe Working Environment

Suppliers will maintain a safe, healthy, clean, and well-lit work environment including appropriate and adequate facilities and protection from hazardous materials or conditions. We expect our Suppliers to maintain the same standards in their fulfillment centers. If housing is provided for employees, all housing must be maintained in a clean, safe fashion. Suppliers shall provide workers with adequate and appropriate personal protective equipment to protect workers against hazards encountered in their scope of work. Additionally, ShipBob strictly forbids the use of cruel and unusual disciplinary practices in the workplace. 

Risk Assessment

We expect our Suppliers to conduct routine risk assessments, reflecting existing and emerging issues and good practice; to understand health and safety issues both generally and specifically for their sector; and to take appropriate action to mitigate identified risks. 

Continuous Improvement

We expect Suppliers to progressively improve health and safety standards to prevent accidents and injuries. Similarly, we encourage the adoption of health and safety management systems that can be externally verified and certified. 

Data Security, Confidentiality and Accuracy

Suppliers will handle and process data only for the purposes for which it was collected or otherwise made available and will only process data upon ShipBob’s instructions. Suppliers shall demonstrate data privacy and security controls appropriate to the risk that meet or exceed appropriate industry standards and best practices to ensure that the confidentiality, integrity, and availability of information is protected and secure, and shall ensure that their own subprocessors commit to the same level of security controls. In addition to the above minimum requirements, Suppliers shall also follow any data security policies and requirements specified in contractual agreements with ShipBob. Suppliers must respect and maintain the confidentiality, integrity, and availability of all non-public or otherwise sensitive information about ShipBob or its activities and all non-public information obtained in the performance of the Supplier’s duties about ShipBob’s customers, clients or applicable third parties. Suppliers must ensure that all personnel authorized to process data on ShipBob’s behalf are subject to a similar obligation of confidentiality. Subject to any contractual requirements, Suppliers will notify ShipBob at [email protected] without undue delay of any known or suspected data security incident and will work with ShipBob and its agents to contain the incident and determine a root cause. Finally, Suppliers will assist ShipBob, including by sharing all relevant available information, in complying with its own obligations under applicable data protection laws.  

Environmental Impact

ShipBob is committed to making our brands and business more sustainable by significantly reducing our environmental impact along our entire supply chain and by considering the environmental implications of every major business decision that we make. We also work with our business partners, suppliers, contractors, customers, and consumers to reduce impacts along the whole supply chain. 

For our Suppliers, we have minimum standards in the following areas: 

Environmental Policy and Regulations

Our Suppliers shall have a clear and publicly available environmental policy statement that addresses the key impacts from their operations and commits to improvement, Suppliers will manage their environmental impact responsibly in line with applicable laws and regulations. Our Suppliers shall have a clear and publicly available environmental policy statement that addresses the key impacts from their operations and commits to improvement, Suppliers will manage their environmental impact responsibly in line with applicable laws and regulations.

Reduce Environmental Impacts

Suppliers shall continually strive to reduce their environmental impacts and manage their natural resources efficiently. This includes implementing measures to prevent pollution, minimize the use of energy and production of waste and manage water responsibly. 

Raising a Concern

We believe knowing about potential breaches early means we can deal with them quickly and appropriately. We take every report seriously and we will not tolerate any reprisal by a ShipBob employee against a Supplier who has reported a concern in good faith or assisted us with an investigation.  

Suppliers must promptly inform ShipBob if they believe they or other people—including ShipBob employees—have or may have violated this SCC. Violations of this SCC may be reported anonymously or confidentially to ShipBob’s General Counsel or to ShipBob’s whistleblower hotline as follows:  

ShipBob will not permit retaliation of any kind against anyone who makes a report or complaint in good faith. ShipBob encourages and values good faith reporting of conduct that may violate this SCC or applicable laws. 

Effective June 8, 2026.