Supplier Code of Conduct

Last Updated: March 5, 2025

Introduction: Troutman Pepper Locke LLP and its subsidiaries (collectively “Troutman Pepper Locke,” the “Firm,” “we,” “our,” or “us”), is committed to socially and environmentally responsible business practices and adhering to the highest standards of ethics, compliance, and integrity. Troutman Pepper Locke expects the same commitment from entities and individuals who provide products and services to the Firm (“Suppliers”). This Code of Conduct outlines our expectations for every Supplier with whom we do business.

Scope and Supplier Compliance: This Code of Conduct applies to all Suppliers and their subsidiaries, employees, agents, and subcontractors that provide goods or services to the Firm. While Troutman Pepper Locke recognizes that Suppliers operate in different geographies, with different legal requirements and cultural norms, the Firm expects all of its Suppliers to adhere to this Code of Conduct unless doing so would cause a Supplier to violate a legal or regulatory obligation. To the extent this Code of Conduct conflicts with a contract executed between the Firm and a Supplier, the contract prevails.

In addition to ensuring their own compliance with this Code of Conduct, the Firm also expects that Suppliers will promote the principles of this Code of Conduct throughout their own supply chains and will conduct due diligence on their own Suppliers to ensure they are adhering to standards similar to those set forth in this Code of Conduct.

We may evaluate any Supplier’s adherence to this Code of Conduct at the time of selection/renewal and throughout the Supplier’s relationship with the Firm, including through the use of questionnaires (whether issued by us or a third party), review of the Supplier’s public disclosures or regulatory reporting, auditors, and/or site visits. If it is determined that a Supplier is not in compliance with this Code of Conduct, the Firm reserves the right to cease business with that Supplier.

Legal Compliance: Suppliers must comply with all applicable laws, regulations, and standards within the geographies in which they operate. This includes, without limitation: employment, wage, and labor laws; workplace health and safety laws; human rights, slavery, child labor, and human trafficking laws; privacy laws; anti-money laundering laws; anti-bribery and corruption laws; tax laws; and trade and sanctions laws. Suppliers must have comprehensive policies in place to ensure compliance with all relevant laws, regulations, and standards. Suppliers must also have documented policies and procedures to encourage reporting (whistleblowing) of any violations of relevant laws, regulations, or standards, without risk of retaliation to the individual who reports the alleged wrongdoing.

Non-Discrimination: Fundamental to our core values is a culture that is equitable and inclusive. Troutman Pepper Locke expects Suppliers to operate their workplaces free of employment discrimination, harassment, and retaliation on the basis of any characteristic protected by applicable federal, state, or local law, such as race, color, national origin or ethnicity, gender (including gender identity or expression and transgender status), sexual orientation, pregnancy, religion, age, disability, service in the uniformed services, and genetic information.

Environmental Sustainability: Troutman Pepper Locke is committed to minimizing the impact of our operations on the natural environment and seeks to do business with Suppliers that share this commitment. The Firm expects Suppliers to comply with all environmental laws and regulations applicable to the geographies in which they operate. Troutman Pepper Locke further expects Suppliers to evaluate and mitigate the environmental impact of their operations and their upstream and downstream supply chains by, among other things, measuring and managing energy usage, greenhouse gas emissions, water usage, waste disposal, production of and/or reliance on plastics or other materials that are detrimental to the environment, consumption of natural resources, and impact on biodiversity. Troutman Pepper Locke encourages its Suppliers to impose appropriate obligations on individuals and entities throughout their supply chains to support a collective approach to environmental sustainability efforts.

Business Continuity: The Firm expects Suppliers to assess and manage the risk that Suppliers may experience a disruption in their critical business functions during a disaster event. The Firm expects Suppliers to have actionable business continuity plans in place that will safeguard Suppliers’ employees and minimize disruption to critical business functions in the event of an environmental disaster, security breach, crisis situation, or other emergency.

Please contact procurement@troutman.com with any questions about this Supplier Code of Conduct or to report any concerns about a Supplier’s compliance.