SUPPLIER CODE OF CONDUCT

80 Acres Urban Agriculture, Inc., its subsidiaries and affiliates (collectively, “80 Acres”) will only do business with Suppliers[1] that comply with applicable and controlling laws, regulations, and rules, including international laws and industry standards as applicable, (collectively, “Applicable Law”). Suppliers are also expected to act in accordance with international principles and guidelines aimed at promoting and protecting human rights. This Supplier Code of Conduct outlines the minimum expectations for 80 Acres’ Suppliers. All Suppliers must be able to demonstrate compliance upon request and take action to correct any noncompliance.

• Supplier shall use only voluntary labor and not any form of human trafficking involuntary labor through threat, force, fraudulent claims, abduction or other coercion.
• Supplier shall not use any form of forced labor including prison, indentured, bonded, military, or slavery. Supplier’s workers shall not be held in debt bondage or forced to work in order to pay off a debt.
• Supplier shall not retain a worker’s government-issued identification, passports or work permits as a condition of employment and shall allow workers to resign from their positions at any time.
• Supplier shall not use child labor as defined by the International Labour Organization.
• Supplier’s employee working hours must be in compliance with all Applicable Law and regulations. Workers shall not be made to work overtime under the threat of penalty, dismissal, as a disciplinary measure, or for failure to meet production quotas. All overtime shall be voluntary and paid in accordance with local and national laws or regulations.
• Supplier must respect their workers’ rights to freedom of association and collective bargaining.
• Supplier’s workers’ freedom of movement shall not be unreasonably restricted. Workers shall not be physically confined to the workplace or related premises; nor shall any other coercive means be used to restrict workers’ freedom of movement.
• Supplier’s workers shall not be charged any fees or costs for recruitment, directly or indirectly, in whole or in part, including costs associated with travel to the receiving country, and processing official job-related documents and work visas in both home and host countries.
• Supplier shall maintain a workplace free of unlawful discrimination, which includes, but is not limited to, nationality, legal status, race, gender, domestic partnership status, sexual orientation, gender identity, gender expression, age, pregnancy, caste, disability, union membership, ethnicity, religious belief, or any other factors protected by Applicable Law.
• The use or threat of physical or sexual violence, harassment intimidation against a worker, his or her family, or close associates, is strictly prohibited. Disciplinary procedures shall be clearly defined and communicated to all workers and shall not include sanctions that result in wage deductions, reductions in benefits, or compulsory labor.
• Supplier shall provide safe and healthy working environment. Suppliers shall fully comply with all regulations and practices including those applicable to the areas of safety, emergency preparedness, occupational injury and illness, physically demanding work, machine safeguarding, and sanitation.
• Supplier must provide options for its employees to report concerns or violations of this Code of Conduct without fear of retaliation.
• Supplier shall comply with and adopt policies with respect to applicable antibribery, anti-corruption, and anti-money laundering laws and regulations.
• Supplier must not do business with sanctioned persons, entities, or countries.

[1] Supplier means any company or other entity that sells or seeks to sell goods or services to 80 Acres, as well as their suppliers and sub-contractors.