What is the Supplier Code of Conduct?

The Supplier Code of Conduct establishes the minimum standards that must be met by any supplier that sells goods to or does business with the Company, regarding:

• a supplier’s treatment of workers;
• workplace safety;
• the impact of supplier’s activities on the environment; and
• a supplier’s ethical business practices.

To whom does the Supplier Code of Conduct apply?

Any supplier, manufacturer, distributor or vendor of that sells goods to or does business with The Scotts Company LLC, The Hawthorne Gardening Company and their Affiliates (the “Company”). These requirements also apply to a supplier’s subcontractors.

Why is it important for the Company to have a Supplier Code of Conduct?

This Code of Conduct supports the Company in:

• meeting the growing expectations in global regulations around labor, environmental practices, health & safety, and supply chain transparency;
• maintaining, growing trust and better aligning with our customers;
• ensuring safe, ethical, and fair business practices are occurring throughout our supply chain;
• mitigating risk and establishing resilience in our supply chain;
• maintaining and protecting our reputation as an ethical company; and
• involving stakeholders across our value chain in ESG purpose and priorities.

Where can I find a copy of the Supplier Code of Conduct?

The Supplier Code of Conduct is available under the ESG tab of our website.

To whom does a supplier ask questions about the Supplier Code of Conduct?

Suppliers can submit questions and comments regarding the Code of Conduct at [email protected].

What happens if a supplier does not comply with the Supplier Code of Conduct?

As a part of our supplier engagement program, we may audit suppliers to determine whether the requirements of the Code of Conduct are being met. If we uncover a deficiency, the supplier is expected to take corrective action. If the supplier is unable or unwilling to comply with the Code of Conduct, we may take any available action including termination of the supplier.

What obligates a supplier to meet the requirements of the Supplier Code of Conduct?

The requirement to comply with the Supplier Code of Conduct is detailed on our website, through various master agreements, and in our PO Terms and Conditions. Additionally, the Company will provide the Supplier Code of Conduct during the supplier onboarding process.

Do suppliers need to separately sign or agree to the terms of the Supplier Code of Conduct?

No, a separate signature or acknowledgement of this new Supplier Code of Conduct is not needed.

Will the Supplier Code of Conduct impact a supplier’s current contractual agreements and obligations?

For all suppliers, regardless of the form of agreement they are contracted on, it is the Company’s expectation that the supplier complies with this Supplier Code or maintains a code of business conduct substantially similar to the Supplier Code of Conduct.

How can a supplier report a concern or potential violation of the Supplier Code of Conduct?

Suppliers can report concerns or potential violations to the Responsible Sourcing Coordinator at [email protected].

If a concern or a potential violation is reported, will it be anonymous?

At this time, because information is collected through email, there is not a formal method for anonymous reporting. However, personal information will not be required when reporting any potential violation(s) or in any follow-up response to any report.

If I report a concern or a potential violation, will I be retaliated against?

Concerns or potential violations can be reported without fear of retaliation. We do not tolerate conduct, whether direct or indirect, that involves threats, harassment, retaliation or any type of discrimination or adverse action against a reporter because they make an honest and sincere complaint without malice known as a “good faith” complaint about suspected Company, employee or Supplier’s violations of law or violations of the Code or our policies.