TECHCET CA LLC

Code of Conduct

For Employees and Contractors

Standards for Business Ethics

It is TECHCET’s policy that all contractors and employees are committed to the highest standards of ethical conduct when dealing with other contractors, employees, and customers.

Business Integrity  

The highest standards of integrity are to be upheld in all business interactions. Contractors, or employees shall have a “zero tolerance” policy to prohibit any and all forms of bribery, corruption, extortion, or embezzlement (including promising, offering, giving, or accepting any bribes). All business dealings shall be transparently performed and accurately reflected in Contractor’s, or employee’s business books and records. Monitoring and enforcement training shall be implemented to ensure compliance with anticorruption laws.

No Improper Advantage  

Bribes or other means of obtaining undue or improper advantage are not to be offered or accepted.

Disclosure of Information  

Information regarding business activities, structure, financial situation, or performance is to be disclosed in accordance with applicable regulations and prevailing industry practices. Falsification of records or misrepresentation of conditions or practices is unacceptable.

Intellectual Property  

Intellectual property rights are to be respected, and the transfer of technology and know‐how is to be done in a manner that protects intellectual property rights.  It is understood that TECHCET maintains a non-disclosure agreement with every Critical Materials Council Member and that care and diligence is expected to prevent any violation of these agreements.

Fair Business, Advertising and Competition  

Standards of fair business, advertising, and competition are to be upheld. Appropriate means to safeguard TECHCET information must be available.

Privacy

Contractors and employees are committed to protecting the reasonable privacy  expectations for personal information of everyone they do business  with, including sub-contractors, clients/customers, CMC Fab Members, CMC Associate Members, employees, and other contractors.  Contractors and employees are to comply with privacy and information security laws and regulatory requirements when personal information is collected, stored, processed, transmitted, or shared.

Whistleblower Protection and Anonymous Complaints or Suggestions

TECHCET will provide an anonymous complaint mechanism for workers to report workplace grievances in accordance with local laws and regulations. TECHCET shall have a formal communication program to ensure that every employee and Contractor is fully informed of and understands the policy of non‐retaliation.