Code of Conduct – Traquair Data Systems, Inc.

Traquair is committed to responsible behavior, both as a business and as a supply chain participant within the electronics industry. In this respect, Traquair has found that its own values align with those of the Responsible Business Alliance, as currently defined Version 7.0 of its code of conduct, effective January 1st, 2021.

The standards set out in the Responsible Business Alliance Code of Conduct references international norms and standards including the Universal Declaration of Human Rights, ILO International Labor Standards, OECD Guidelines for Multinational Enterprises, ISO and SA standards, and many more. Traquair supports these standards and is committed to complying with the principles outlined in the RBA Code, and expects the same of its suppliers and business partners.

Traquair is committed to respecting and upholding all labor and employment regulations and RBA Code of Conduct guidelines, and upholding the human rights and dignity of its workforce. This applies to all workers including temporary, migrant, student, contract, direct employees, and any other type of worker. Traquair meets or exceeds all labor and human rights guidelines as set out in the RBA Code of Conduct.

In accordance with the RBA Code of Conduct, work weeks at Traquair should not be more than 60 hours, including overtime, except in emergency or unusual situations, and all overtime must be voluntary (i.e. not required by Traquair). Traquair tracks the cumulative hours worked that are in excess of the 60 hour limit as follows:

2017, 2018, 2019, 2020, 2021, 2022: Zero excess hours (over 60 hour work week limit)

The gender breakdown for employees and board members is as follows:

2017, 2018, 2019, 2020, 2021, 2022: Employees plus board members: 50% / 50% (male/female)

Traquair recognizes that in addition to minimizing the incidence of work-related injury and illness, a safe and healthy work environment enhances the quality of products and services, consistency of production and worker retention and morale. Traquair also recognizes that ongoing worker input and education are essential to identifying and solving health and safety issues in the workplace.

The number of work related injuries and illinesses at Traquair (logged using OSHA form 300) are as follows:

2017, 2018, 2019, 2020, 2021, 2022: Zero work related injuries and illnesses

Traquair recognizes that environmental responsibility is integral to producing world-class products. Although Traquair is not a manufacturer, we do expect our suppliers to identify and minimize adverse effects on the community, environment, and natural resources within their manufacturing operations, while safeguarding the health and safety of the public.

At Traquair, our goal is to pursue reduced greenhouse gas emissions. One way we pursue this is through the use of solar generated electricity. The proportion of solar utilization (*) at Traquair is as follows:

2022: solar electricity utilization: 84%
2021: solar electricity utilization: 78%
2020: solar electricity utilization: 81%
2019: solar electricity utilization: 100%
2018: solar electricity utilization: 81%
2017: solar electricity utilization: 93%

* utilization factors is in excess solar generated electricity that is supplied to the local electricity grid.

Traquair recognizes that the exploitation and trade of conflict minerals and cobalt in the Democratic Republic of the Congo and adjoining regions helps finance extreme levels of violence in these areas. Although Traquair is not a manufacturer, we do expect our suppliers and business partners to have in place conflict minerals and cobalt sourcing policies and practices, to conduct annual due diligence reviews of their own supply chain, and to not knowingly procure materials containing conflict minerals or cobalt from these areas of conflict.

Traquair is committed to adhering to the highest standards of ethics and integrity in every aspect of its business operations and interactions. We further expect our suppliers, business partners, and anyone else connected with Traquair to also adhere to standards of ethics and integrity which are consistent to those maintained by Traquair and the RBA Code of Conduct.