Suppliers Code of Conduct

LOUISA FOOD PRODUCTS, INC.

CODE OF CONDUCT FOR SUPPLIERS

At Louisa Food Products, Inc. (Louisa Foods) our mission is to be recognized as the leading provider of high-quality frozen filled pasta designed for superior culinary performance. To achieve our mission, we stay true to the core values that made Louisa Foods successful long ago.

• We believe in building lasting and mutually beneficial relationships with our customers, based upon honesty, integrity and delivered value.
• We believe that we earn business by listening to our customers and responding promptly, creatively, and with flexibility.
• We believe the success of Louisa Foods is dependent on the talents and efforts of our people. We employ a diverse group of individuals, all of whom are committed to excellence in what they do.
• We believe growth is essential and is the result of continued improvement and innovation.

In alignment with our mission and as part of our ongoing sustainability efforts, we have developed the Louisa Foods Supplier Code of Conduct to ensure that all of our business partners, suppliers, and manufacturers meet our basic expectations of doing business related to legal requirements, ethical practices, human rights, and environmental management.

This Supplier Code of Conduct sets forth the principles and high ethical standards that we strive to achieve, and expect our supply partners to work toward throughout the course of our business relationship.

BUSINESS INTEGRITY AND BUSINESS COURTESIES/GIFTS

Louisa Foods is committed to the highest standards of business integrity. We will not tolerate any practice that is inconsistent with the principles of honesty, integrity, and fairness. We expect our supply partners to conduct business ethically and pursuant to best practices in our industry.

Louisa Foods awards business based on considerations such as product and service quality, competitive pricing and contract performance. Louisa Foods prohibits of all forms of bribery, corruption, kickbacks, or offering anything of value to its employees for the purpose of getting business, and keeping business.

Gifts, excessive meals and/or entertainment and special favors are not, and will not become, part of doing business with Louisa Foods. Although nominal gifts and modest meals may be accepted under our current policies, our employees are prohibited from soliciting any item of value from our supply partners. No Louisa Foods employee shall give or receive any gift or favor that could be reasonably viewed as being given or received to gain a business advantage.

COMPLY WITH APPLICABLE LAWS, RULES, AND REGULATIONS

Louisa Foods commitment to integrity begins with complying with laws, rules, and regulations where we do business. Furthermore, supply partners must comply with all laws, rules, and regulations applicable to their business. Where applicable, supply partners must comply with relevant international laws.

CONFIDENTIAL INFORMATION

Supply partners with access to confidential and proprietary information about Louisa Foods, and its business partners, must not disclose that information to any other person or entity without prior written consent. Confidential and proprietary information includes marketing data, product specifications, production processes, cost, pricing, customer information, and information pertaining to business development opportunities and new products and services.

HUMAN RIGHTS

When it comes to our employees, Louisa Foods is not only committed to observing all applicable labor laws and regulations, we are committed to observing fair labor practices. We expect our supply partners to make the same commitments in their business practices by having controls in place that:

• Prohibit child labor, forced, or compulsory labor and human trafficking;
• Verify the employment eligibility of their employees – without requiring workers to lodge “deposits” or their identity papers with their employer and are free to leave their employer after reasonable notice;
• Ensure compliance with applicable wage, hour, and benefits laws, including minimum wage, overtime, and maximum work week laws;
• Respect the right of employees to freely associate; and
• Ensure a workplace free from discrimination and harassment, especially based on race, color, gender, sexual orientation, religion, caste, national origin, ethnicity, marital status, disability, pregnancy, or political beliefs.

PRODUCT SAFETY, QUALITY, AND REGULATORY COMPLIANCE

One of the most significant values of Louisa Foods is our commitment to providing safe, high-quality frozen pasta to our customers. We are committed to meet and/or exceed food safety, quality, regulatory, GFSI, and customer requirements. We expect our supply partners to provide products and services that meet or exceed all applicable government and contractual standards of safety and quality.

In addition, allergens pose a food safety risk, and Louisa Foods has strict policies and practices to protect consumers from those risks. Louisa Foods expects supply partners to consider the

PRODUCT SAFETY, QUALITY, AND REGULATORY COMPLIANCE - CONTINUED

safety and quality of our products to be of paramount importance and comply with its own company food safety requirements and specifications to prevent allergen risks at all times .

Supply partners must immediately report to Louisa Foods any deficiencies in product safety or quality so that the appropriate actions may be taken to recall or withdraw products.

ENVIRONMENT, HEALTH AND SAFETY

Louisa Food Products, Inc. is committed to conducting business in a safe, environmentally responsible manner. We expect our Supply partners to:

• Make a continuous effort to achieve a workplace that is free from work-place injuries and illnesses;
• Complies with all applicable environmental, health, and safety laws, regulations, and standards; and
• Strives to responsibly manage the impacts of their operations on the environment.

ANIMAL WELFARE

Louisa Foods is committed to the health and welfare of animals. Louisa Foods expects each Supplier to meet or exceed the applicable federal, state, and local laws and regulations for animal welfare.

VERIFICATION OF SUPPLIER COMPLIANCE

Louisa Foods expects all of its supply partners to company with all aspects of its Supplier Code of Conduct. If a supply partner violates this code, Louisa Foods may terminate the business relationship or require the supplier to implement a corrective action plan. Supply partners must inform Louisa Foods immediately of any departure from this Code, including regulatory compliance failures or other events that may put our customers at risk or cause damage to our reputation.

 

Note: We rely on many third-party resources who are independent contractors for various goods and services. This includes but not limited to contractors, consultants, and suppliers, and their associated employees, agents, and/or subcontractors. For simplicity, we refer to these third-party resources as “supply partners” in this Supplier Code of Conduct.