Supplier Code of Conduct

January 2024

GAF Energy, a Standard Industries company, is a leading solar manufacturing company with a mission to bring energy to every roof by offering innovative and elegant solar roofing options.  GAF Energy prioritizes continual innovation, an unwavering focus on its customers, and a commitment to operate, transparently,  ethically and in accordance with law.  GAF Energy also strives to protect its people, its communities, and our planet for a more sustainable future.   

This Supplier Code of Conduct sets forth GAF Energy’s expectations for all Suppliers which provide products or services to GAF Energy.  We encourage and expect all Suppliers to adhere to all applicable laws and regulations and act in compliance with this Supplier Code of Conduct across their business and supply chain.  

If you observe or learn of any conduct in violation of this Supplier Code of Conduct, you should contact the Ethics Hotline overseen by GAF Energy’s parent company Standard Industries via its website or by telephone.  

Business Ethics

GAF Energy is committed to acting honestly, ethically, and in accordance with applicable law when conducting business, and expects Suppliers associated with GAF Energy to act in the same manner.    

Bribery, Corruption, and Sanction Laws

Suppliers must comply with applicable laws, such as the United States Foreign Corruption Practices Act (“FCPA”) and the UK Bribery Act of 2010, and must not offer, promise, give, request, or accept a bribe.  Suppliers are prohibited from conferring impermissible payments or illegal benefits upon any business partner, public authority, or Supplier to obtain an outcome favorable to themselves or to GAF Energy.   While unsolicited nominal gifts and business amenities may be exchanged, such gifts are not permitted where they are intended to influence business decisions or induce any party to act contrary to law.

Conflicts of Interest

Suppliers should disclose any conflict of interest to GAF Energy as soon as the Supplier is aware of the conflict of interest.  A conflict of interest exists when the nature of the work to be performed under a purchase order or agreement may give a Supplier an unfair advantage or when the Supplier has other interests (for example, a pre-existing relationship with a GAF Energy employee that has influence over the purchase agreement) that may impair its objectivity.  

Antitrust, Fair Competition, and Trade 

Suppliers must comply with all applicable antitrust and competition laws, and follow the principles of fair and open competition, any rules regarding the exchange of commercially sensitive information such as pricing, pricing strategies, terms and conditions, or market analysis.  All Suppliers must also adhere to applicable trade controls and export, re-export, and import laws and regulations.

Conflict Minerals

Suppliers must ensure that products or materials supplied to GAF Energy do not contain metals or raw materials derived from minerals or their derivatives originating from conflict regions that directly or indirectly influence, finance, or benefit armed groups and cause or encourage human rights abuses.  Suppliers must comply with all applicable sanctions and prohibitions on products sourced from such regions, including but not limited to the Uyghur Forced Labor Prevention Act.

Human Rights and Labor

Suppliers should treat everyone with dignity and respect at all times, and should respect and support human rights in accordance with local, national, and international standards, such as the UN Guiding Principles on Business and Human Rights. 

Diversity and Inclusion

Suppliers should provide an equitable, diverse, and inclusive working environment, and work diligently to eliminate barriers that prevent the full participation of any groups.   Suppliers shall not discriminate or harass anyone on the basis of race, color, religion, sex, age, national origin, genetic information, marital status, medical condition (as defined by applicable law), pregnancy, childbirth or related medical condition, gender identity or expression, sexual orientation, veteran status, or any other category protected by law.  Suppliers shall comply with the Equal Employment Opportunity (EEO) and Affirmative Action regulations if in the United States  or equivalent legislation outside the United States (as applicable).

Child Labor and Compulsory Labor

Child labor and all forms of compulsory labor shall not be permitted in any capacity, including forced labor, slavery, and trafficking.  Suppliers must comply with all applicable modern slavery laws and regulations, and shall not employ anyone under the minimum age as permitted by law in the jurisdictions in which the Supplier operates.  All work performed by workers of a Supplier must be voluntary and workers shall have the right to leave employment at any time, under their own volition. 

Freedom of Association 

Suppliers should establish favorable employment conditions, maintain effective employee communication, and provide a method for employees to raise grievances without fear of retribution.  If required by applicable law, Suppliers shall respect employees’ legal rights to organize, unionize, and collectively bargain, and shall not retaliate against employees who engage in these protected activities. 

Minimum Wage and Benefits

Suppliers must meet the requirements as set by local laws and regulations related to the payment of wages, overtime hours, piece rates, and other elements of compensation, and provide legally mandated benefits where applicable.

Environment, Health, and Safety

GAF Energy places the safety and well-being of its employees, contractors and partners first.  In addition to committing to continuous improvement of its health and safety management system and performance, GAF Energy also considers the long term impact of its business on the health of the planet, and operates in a manner that respects the environment and makes sustainability a priority.   

Occupational Health and Safety 

Suppliers should adopt proper procedures and controls to provide safe and healthy working conditions for all employees and contractors , including documented health and safety policies as well as plans and procedures for emergency situations in the workplace.  Such plans and procedures should be available in the primary language of all employees.

Product Safety 

Suppliers shall comply with product safety regulations and product labeling guidelines, and should clearly communicate product handling instructions and requirements by providing all necessary safety information for all hazardous substances in their products where required to do so, including product information and safety data sheets.  

Environmental Permits and Reporting

Suppliers must have required environmental permits and registrations in place and kept current in accordance with local laws and regulations. 

Pollution Prevention and Resource Efficiency

Suppliers shall have appropriate pollution prevention controls in place to regulate emissions and discharges of emissions.  Suppliers should monitor their use of natural resources including water, fossil fuels and minerals, and should consider practices to reduce the environmental impact of the products they sell us. 

Business Continuity

Suppliers should have appropriate business continuity plans in place for any operations that support GAF Energy’s business, in order to maintain resiliency in responding to a disruption of operations.  Such plans should include disaster recovery, crisis management and preventative measures to avoid and mitigate risks associated with a disruption of operations.

Information Security

GAF Energy expects all Suppliers to act in a manner that will safeguard data shared with the Supplier, to protect GAF Energy’s confidential and proprietary information, and to comply with all applicable data security and data protection laws.  If a Supplier experiences a data security breach, it must be reported to GAF Energy within 24 hours of learning of the breach, unless the Supplier’s contract with GAF Energy requires a shorter notice period.

Confidential Business Information

Suppliers should protect GAF Energy’s confidential information which includes, but is not limited to, confidential business information, strategic plans, financial data, technical and business information, information regarding our employees, intellectual property, patents, and trademarks.