CODE OF CONDUCT POLICY

OUR VISION

Year after year, we want to see Vomela and its people regarded among the BEST specialty graphics providers in North America.

OUR MISSION

To be the industry leader providing creative, innovative and technologically advanced graphic products and value added services to our customers.

CORPORATE CITIZENSHIP

LABOR PRACTICES AND HUMAN RIGHTS

The Vomela Companies uphold the highest standard of human rights with the belief that all workers in our supply chain deserve a fair and ethical workplace and should be treated with the utmost dignity and respect.

The Vomela Companies do not discriminate against any worker or applicant based on age, disability, ethnicity, gender, marital status, national origin, political affiliation, race, religion, sexual orientation, gender identity or any other status protected by law in hiring and other employment practices.

The Vomela Companies are committed to a workplace free of harassment and abuse ensuring that workers are not threatened, intimidated, or subjected to harsh or inhumane treatment, including but not limited to verbal abuse and harassment, psychological harassment, mental and physical coercion, and sexual harassment. Additionally, The Vomela Companies ensure that all work is freely chosen and will not use any indentured or forced labor, slavery or servitude, and shall only employ workers who meet the applicable minimum legal age requirement.

The Vomela Companies actively demonstrate a commitment to equality, diversity and inclusion through all aspects of workplace management giving clear consideration to equality of opportunity in employment. Our Affirmative Action Plan reflects our commitment to building a diverse and inclusive workforce. EEO1 reports are completed and submitted annually as required for government contractors. As part of this commitment, we actively encourage work with diverse businesses throughout our supply chain.

CONFLICT MINERALS

As is sometimes required by our clients, The Vomela Companies test suppliers and keep record of any raw goods that might be considered at risk of containing conflict minerals. We work diligently to avoid the need or use of conflict minerals in the creation or manufacturing processes used by The Vomela companies. In addition, we work closely with all of our suppliers to ensure the products we sell do not contain conflict minerals that directly or indirectly finance or benefit armed groups who have potentially profited and contributed to violence and exploitation in the eastern provinces of the Democratic Republic of the Congo.

CORPORATE SOCIAL RESPONSIBILITY

COMMUNITY INVOLVEMENT

Vomela believes that to be a good corporate citizen we need to give back to our communities. In doing so, we actively and regularly promote local food shelf collections, United Way fundraisers, Adopt a Family, Toys for Tots, Big Brothers Big Sisters, Children’s Hospital campaigns and other nonprofit and charitable events. In addition, many of our locations donate left over materials to schools.

The Vomela Companies and its affiliates regularly donate graphics, banners, decals and signage to Community programs and non-profits. We support our Employee participation in fund raising marathons and as a company, we support various local Foundations by participating in fundraising events regularly. Our goal is to support the local communities in which we live and work.

ETHICAL BUSINESS PRACTICES

The Vomela Companies are committed to the highest standards of ethical conduct in compliance with all applicable local, state and federal laws and regulations when dealing with its employees, suppliers and customers. All locations are expected to conduct business with integrity, respect, truthfulness, and accuracy and remain in full compliance with those regulations that pertain to trade, antitrust and fair competition, and anti-corruption. The Vomela Companies will not participate in boycotts that are not sanctioned by the United States government.

The Vomela Companies strive to be competitive in every aspect of our business by conducting ourselves in an ethical, socially responsible, professional and legal manner. Vomela does not engage in any form of corruption, extortion, embezzlement, or bribery to secure business. The Vomela Companies and all its employees avoid ever taking unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts or any other intentional unfair dealing or practice.

Specific language is included in our employee handbooks to help ensure that everyone understands our intolerance for anyone engaging in activity that might create an actual, potential or apparent conflict of interest between employees, any of the Vomela companies or our business partners. We discourage giving or receiving gifts to ensure business relationships are not compromised or improperly influenced.

HEALTH AND SAFETY

The Vomela Companies are committed to creating a workplace that is safe, healthy and injury-free. Our employees are our most valuable assets, and their safety and health is our first priority. Safety is essential to all business functions and is never compromised under any circumstance. Every employee is required to know their respective site-specific Safety Orientation process including emergency preparedness and response. Employees also have a responsibility to maintain our work environment including reporting hazards and working toward preventing accidents.

We provide training, review our procedures, review accidents and maintain the equipment needed to run our business. In the event of an injury, we actively investigate, document and review in detail to avoid potential future recurrence. Our Drug and Alcohol policy is strictly enforced with no exceptions.

We provide support to our Safety Committees throughout our network by providing the time, employees and management commitment needed to reach our common goal of a safe and injury free workplace. Members engage in conducting periodic in-house inspections of our operations and as appropriate develop action plans for continuous improvement.

The Vomela Companies are proud of achieving an Experience Modification Factor < 1 for the past 4 years and are committed to continuing our momentum in injury/accident reduction strategies and communicating safe work practices.

ENVIRONMENTAL REGULATIONS AND PROTECTION

The Vomela Companies are committed to reducing its impact on the environment. Our commitment to the environment extends to our customers, our staff, and the community in which we operate. We are committed to:

Compliance with all applicable environmental regulations;

Pollution prevention whenever possible;

Staff training on our environmental programs and empower them to contribute and participate;

Communicating our environmental commitment and efforts to our customers, staff, and our community; and

Continuous improvement over time by striving to measure our environmental impacts and by setting goals to reduce these impacts each year.

Key Vomela Accomplishments:

Achieved the Small Hazardous Waste Generator status by introducing environmentally friendly ink technologies into our operations.

Invested in state of the art equipment allowing us to transition from solvent-based to UV, Latex, Vegetable and Aqueous-based inks which significantly reduced any potential to emit GHG emissions.

Developed an integrated waste reduction strategy for all plastics, wood, paper, corrugated, substrates, metals, computer related equipment, ink cartridges and maintenance tanks, office paper, pre-press films, batteries, fluorescent lamps and post-consumer recyclables. We continue to identify product alternatives made from recycled materials as well as being recyclable that can replace existing non-recyclable materials.

Continually work with suppliers on packaging solutions to minimize the amount of materials required to properly pack merchandise.

More efficient lighting systems have been installed in some locations resulting in a reduction in our energy consumption. As we plan for the future, we will continue to explore opportunities to reduce our energy usage throughout all operations.

Select Vomela companies have joined forces with the Forestry Sustainability Council (FSC) which means they are able to offer products certified by FSC to their respective customers. We continue to look to increase our participation in environmentally appropriate and socially beneficial activities, respecting the rights of workers, communities and indigenous people.

PROTECTION OF ASSETS AND INTELLECTUAL PROPERTY

The Vomela Companies have a variety of manufacturing facilities across the United States which has allowed us to build cross-functional business continuity into our operations to ensure seamless transitions in the case of a catastrophic event. Our operations are set up to offer versatility in meeting the demands of our customers thereby ensuring consistent quality and timely deliveries.

The protection of intellectual property rights is vital to the success of The Vomela Companies. We respect and protect the intellectual property rights of all parties by only using information technology and software that has been legitimately acquired and licensed. The Vomela Companies prohibits the use of technology and systems to create, access, store, print, solicit, or send any material that is intimidating, harassing, threatening, abusive, sexually explicit or otherwise offensive or inappropriate, or send any false, derogatory or malicious communications.

During the course of service with any of The Vomela Companies, individuals will acquire or be provided access to information regarding clients, systems, marketing or strategic plans, fees and revenues, performance and other knowledge considered proprietary by The Vomela Companies. Except for authorized business purposes, employees are not permitted to disclose any proprietary information. This includes, but is not limited to, information stored on any computer system as well as proprietary software developed by or for The Vomela Companies.

Any individual who possesses confidential information has the important responsibility to keep that information confidential within The Vomela Companies, and to disclose such information internally only on a “need to know” basis. Individuals must be discreet with this information and avoid communicating The Vomela Companies matters in ways that are susceptible to interception or use by third parties.

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