Code of Ethics

Supplier and Vendor Code of Ethics, Anti-Corruption, and Trade Compliance Policy

1. Purpose

This Supplier and Vendor Code of Ethics, Anti-Corruption, Trade Compliance, and Transparency Policy (the “Policy”) sets forth the ethical, legal, and operational expectations that Nutraceutical Corporation, doing business as Better Being Co., its subsidiaries, and affiliates (collectively, the “Company”) require of all third-party partners, including suppliers, vendors, consultants, contractors, distributors, and any other third parties acting on the Company’s behalf (collectively, “Suppliers and Vendors”).

Adherence to this Policy is a condition of doing business with the Company. Suppliers and Vendors must conduct business with integrity, in compliance with all applicable laws and regulations, and in a manner that promotes ethical business practices, responsible sourcing, and respect for human rights.

2. Compliance with Laws and Company Policies

Suppliers and Vendors must comply with all applicable international, national, state, and local laws, including but not limited to:

Anti-corruption and anti-bribery laws (e.g., U.S. Foreign Corrupt Practices Act, U.K. Bribery Act)

Trade control and export compliance regulations
Child labor and forced labor laws
Fair competition and antitrust laws
Data protection and privacy laws (e.g., GDPR, CCPA)

Suppliers and Vendors must also comply with the standards outlined in this Policy.

3. Anti-Corruption and Bribery

Suppliers and Vendors are prohibited from engaging in any form of corruption or bribery, including:

Offering, giving, or promising anything of value to a government official or third party to gain a business advantage
Making or accepting facilitation payments or kickbacks
Providing or accepting gifts, hospitality, or entertainment that may improperly influence business decisions

All transactions must be accurately recorded in the supplier’s books and records, and all financial documentation must be transparent and auditable.

4. Trade Compliance

Suppliers and Vendors must comply with all applicable sanctions, export controls, and trade restrictions administered by relevant authorities including:

U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC)
U.S. Department of Commerce, Bureau of Industry and Security (BIS)
European Union and HM Treasury of the United Kingdom
The Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES), where applicable.

Suppliers and Vendors must:

Not engage in transactions with restricted or sanctioned entities, individuals, or jurisdictions, including any that appear on applicable restricted party or sanctions lists.
Avoid sourcing products or services from sanctioned countries without prior written approval and proper licensing.
Comply with all CITES requirements when sourcing, harvesting, transporting, or trading any raw materials derived from species listed in CITES Appendices I, II, or III, including obtaining any necessary permits and maintaining accurate records.
Cooperate with Better Being Co. to provide documentation verifying trade and CITES compliance upon request.

5. Human Rights and Labor Standards

Better Being Co. is committed to protecting and promoting fundamental human rights throughout its global supply chains. Our approach is guided by internationally recognized standards, including the United Nations Guiding Principles on Business and Human Rights (UNGPs) and the International Labour Organization (ILO) core labor standards, such as the Forced Labour Convention and the Worst Forms of Child Labour Convention.

a. Prohibition of Forced Labor, Child Labor, and Human Trafficking

Suppliers and Vendors must not use any form of forced, bonded, indentured, trafficked, or involuntary labor.
Suppliers and Vendors must comply with all applicable minimum age requirements under national laws and relevant ILO Conventions.
Working conditions must be lawful, humane, and respectful of human dignity, consistent with internationally recognized human rights frameworks.
Suppliers and Vendors must conduct ongoing human rights due diligence to identify, prevent, and address any actual or potential adverse human rights impacts in their operations and supply chains.
These requirements align with our obligations under the California Transparency in Supply Chains Act of 2010 (SB 657) and other applicable laws.

b. Verification

Better Being Co. conducts risk-based assessments to verify and evaluate potential risks of human trafficking and forced labor in its supply chains. These assessments may include country- and sector specific risk analysis, onboarding due diligence, and the use of third-party risk tools.

c. Audits

The Company reserves the right to audit suppliers — announced or unannounced — either internally or through qualified third parties to assess compliance with these human rights and labor standards.

d. Certification

Suppliers must certify that all materials incorporated into products supplied to Better Being Co. comply with the labor laws of the countries in which they operate and with applicable international standards. This includes certification that supply chains are free from slavery, forced labor, and human trafficking, as required under the California Transparency in Supply Chains Act.

e. Accountability

Any violation of these standards may result in corrective actions, including termination of business relationships. Better Being Co. will enforce internal and external accountability measures for noncompliance.

f. Training

Better Being Co. provides training to employees and supply chain managers responsible for supply chain management on how to identify, prevent, and mitigate risks of forced labor, human trafficking, and child labor. Suppliers and Vendors are expected to maintain similar awareness and training within their own organizations.

g. California Transparency in Supply Chains Act Disclosure

In compliance with the California Transparency in Supply Chains Act of 2010 (SB 657), Better Being Co. publicly discloses its efforts to eradicate slavery and human trafficking from its direct supply chain. This includes:

Verification of supply chains to evaluate and address risks.

Auditing suppliers for compliance.
Requiring supplier certifications.
Maintaining internal accountability standards.
Providing relevant training.

This disclosure is updated as needed and made available to the public.

6. Compliance with Supply Chain Standards

All employees, contractors, and suppliers are expected to uphold the highest human rights and labor standards throughout our global operations and supply chains. This includes strict adherence to our Supplier Code of Conduct, which prohibits forced labor, child labor, human trafficking, and any form of exploitation. These requirements align with our commitments under the California Transparency in Supply Chains Act (S.B. 657). Any known or suspected violations must be reported immediately to the Company’s Legal Department via email at legal@betterbeing.com.

7. Confidentiality and Data Protection

Suppliers and Vendors must protect all confidential and proprietary information entrusted to them by the Company and its customers.

Suppliers and Vendors must:

Only use confidential information for legitimate business purposes with the Company.
Protect personal data in compliance with all applicable data privacy laws, including GDPR and CCPA.
Report any suspected data breaches or unauthorized disclosures immediately to the Company.

8. Fair Dealing and Conflicts of Interest

Suppliers and Vendors must:

Conduct all business dealings fairly and transparently.
Avoid conflicts of interest that could interfere with their responsibilities to the Company.
Disclose any actual or potential conflict of interest to the Company immediately.

9. Recordkeeping

Suppliers and Vendors must:

Maintain accurate and complete records of transactions related to their dealings with the Company.
Cooperate fully with Company audits or inquiries related to compliance with this Policy.

10. Reporting Violations

Suppliers and Vendors are required to report any known or suspected violations of this Policy, applicable law, or unethical conduct related to the Company's business.

Reports can be made confidentially by contacting the Company’s Legal Department via email at legal@betterbeing.com.

The Company strictly prohibits retaliation for good faith reporting.

11. Compliance Certification and Audits

The Company may require Suppliers and Vendors to certify their compliance with this Policy periodically and reserves the right to audit compliance. Failure to comply with this Policy may result in termination of the business relationship and/or legal action.

12. Amendments

The Company reserves the right to amend or update this Policy at its discretion. Suppliers and Vendors will be notified of significant changes as appropriate.