Supplier Code of Ethics

Hagerty Brothers Company, and its respective affiliates, subsidiaries and divisions (Hagerty Supply / Hagerty Contract Distribution, Inc. (CDI)) conduct business with social, environmental and ethical responsibility and accountability. These core values of business are the foundation of our family company. Accordingly, Hagerty Supply / CDI will only do business with likeminded suppliers, contractors, and consultants, their employees, sub-suppliers and any other parties involved that demonstrate ethical compliance with all applicable laws, regulations in regards, but not limited, to the following:

·        Forced Labor, Human Trafficking and Slavery

·        Child Labor

·        Working Hours

·        Freedom of Association and Collective Bargaining

·        Nondiscrimination

·        Conflict Minerals

o   Supplier shall abide by Hagerty Supply / CDI’s Conflict Minerals Policy, here.

·        Safe Working Environment

·        Environmental Sensitivity  

·        Anti-Bribery and Anti-Corruption

In addition to the above social, environmental and ethical standards Hagerty Supply / CDI are continuously committed to providing the best service and products at the best price. Strong supplier relationships are the only way to accomplish this and we strive for the best and strongest relationships in the industry. Our suppliers are part of our family business as much as anybody else.

In the event Hagerty Supply / CDI determines that a Supplier’s efforts to comply with the above have been deficient and the Supplier fails to cooperate in developing and implementing reasonable remedial steps, Hagerty Supply / CDI reserves the right to take appropriate actions up to, and including, discontinuing purchases from the Supplier.

Nothing in this Code is intended to, in any way, grant any additional rights or expectations to a Hagerty Supply / CDI Supplier or, in any way, modify or otherwise limit any of Hagerty Supply / CDI’s contractual or legal rights.


Conflict Minerals Policy Statement

DODD-FRANK ACT:

As a result of the Dodd-Frank Wall Street Reform and Consumer Protection Act and the Conflict Minerals rules that the U.S. Securities and Exchange Commission adopted, many companies must make public disclosures regarding whether “conflict minerals” used to manufacture their products originated in the Democratic Republic of Congo (“DRC”) or adjoining countries(collectively, together with the DRC, the “Covered Countries”).  These “conflict minerals” consist of columbite-tantalite, also known as coltan (the metal ore from which tantalum is extracted); cassiterite (the metal ore from which tin is extracted); gold; wolframite (the metal ore from which tungsten is extracted); or their derivatives; often referred to collectively as 3TG.

These rules do not apply to Hagerty Brothers Company ( HAGERTY SUPPLY / HAGERTY CONTRACT DISTRIBUTION, INC. (CDI)), however, they apply to customers of  HAGERTY SUPPLY / CDI, and those customers have asked  HAGERTY SUPPLY / CDI to assist them in their efforts to comply with their SEC obligations.  

OUR COMMITMENT TO RESPONSIBLE SOURCING:

  HAGERTY SUPPLY / CDI are committed to supporting responsible sourcing of its materials from suppliers that share our values around human rights, ethics, and environmental responsibility.

Although HAGERTY SUPPLY / CDI do not purchase any of the conflict minerals (3TG) directly, we require our suppliers of materials which contain any conflict materials that are necessary to the functionality or production of said materials to only use DRC Conflict Free sources.

SUPPLIER EXPECTATIONS:

HAGERTY SUPPLY / CDI has set forth expectations of our suppliers in the “Supplier Code of Ethics”   and requires suppliers to adhere to  Hagerty Brothers Company’s code of conduct, which includes the responsible sourcing of materials.

In order to support a conflict-free supply chain and comply with the applicable rules and regulations, HAGERTY SUPPLY / CDI require that:

  • Suppliers should not include in any products sold to  HAGERTY SUPPLY / CDI any Conflict Minerals that are not DRC Conflict Free
  • Suppliers should develop Conflict Minerals policies and management systems to ensure compliance with the aims and objectives of the U.S. legislation on the supply of Conflict Minerals
  • Suppliers should perform due diligence on the sources of Conflict Minerals in their supply chains and make their findings available to us.

Suppliers of certain materials will be required to provide written confirmation of DRC Conflict Free status.  Suppliers who do not reasonably comply with this policy will be reviewed for transition of business to sources that do comply.

Thank you.

Please direct questions and comment to acoffeen@hagertybrothers.com