Supplier Code of Conduct

Cimarron Energy Inc.
and its Affiliates:

Flare Industries, Inc. d/b/a Aereon
and
HY-BON Engineering Co., Inc.

I. PREFACE

Cimarron is committed to the highest standards of product quality, safety and business integrity. We want to ensure that working conditions in our supply chain are safe, that workers are treated with respect and dignity, and that our manufacturing processes are environmentally friendly and safe. Therefore, Cimarron has created this Suppler Code of Conduct defining the basic requirements placed on our suppliers of goods and services concerning their responsibilities towards their stakeholders and the environment.

Scope and Responsibilities

In alignment with Cimarron’s mission and as a part of ongoing sustainability efforts, the Cimarron Supplier Code of Conduct (“Code”) has been developed to ensure that all of Cimarron’s contractors, suppliers, and manufacturers meet Cimarron’s basic expectations of doing business related to human rights, health & safety, labor, business integrity, ethical practices, and intellectual property management. These standards are based on well-respected and recognized international standards, including the International Labor Organization, United Nations Universal Declaration of Human Rights, and industry best practices.

Application of the Code

Compliance with these standards is an expectation of doing business with Cimarron. The Code defines the non-negotiable minimum standards that Cimarron’s contractors, suppliers, and manufacturers and their sub-tier suppliers or subcontractors (each, a “Supplier”) are expected to respect and adhere to.

The standards of this Code are in addition to, and not in lieu of, the provisions of any legal agreement or contract between a supplier and Cimarron and/or its affiliates. The following eight categories encompass the Code.

In addition to this Code, the Supplier is bound by any additional terms and conditions of any contract between Cimarron and Supplier. If any conflict exists between the Code and the terms and conditions of any contract between Cimarron and Supplier, the terms and conditions of the contract shall supersede.

1. HUMAN RIGHTS

Discrimination– Suppliers are expected to treat all workers fairly and with dignity and respect. Accordingly, Suppliers must not engage in unlawful discrimination, harassment or abuse based on race, color, religion, national origin, ancestry, familial status, age, veteran status, physical disability, mental disability, medical condition, gender, gender identity, sexual orientation, marital status, or any other legally protected status.

Harassment & Abuse– Suppliers shall provide a workplace free of harassment, corporal punishment, coercion, and abuse. Any threats or other forms of intimidation are prohibited.

2. HEALTH & SAFETY

Suppliers are expected to provide all workers with a clean, safe, and healthy work environment that complies with all applicable laws.

3. LABOR

Wages, Benefits, & Hours– Supplier must operate in full compliance with all applicable wages, work hours, vacation time, overtime, holidays, and benefits labor laws.

Child & Juvenile Labor– Supplier shall not employ any persons under the age of 16 or the applicable minimum legal age for employment. Supplier shall comply with all local child labor laws and applicable international standards.

Human Trafficking– Supplier will conduct business with respect for and adherence to human rights, including ensuring that Supplier and its supply chain are free from actual or suspected forced labor and ensure that any officers, directors, employees, or subcontractors of Supplier refrain from actions or activities that may contribute to human rights violations, including human trafficking.

Forced Labor– Supplier must ensure that no forced labor, including bonded, indentured, and involuntary prison or slaved labor, is used. Freedom of Association & Collective Bargaining – Supplier shall respect the right of employees to join, form, or not to join a labor union without fear of reprisal, intimidation, or harassment as permitted by and in accordance with all applicable laws and regulations.

4. BUSINESS INTEGRITY/ETHICS

Corruption & Bribery– Supplier must neither engage in nor tolerate association with any form of corruption, bribery, extortion, or embezzlement.

Conflict of Interest– Supplier will disclose to Cimarron any actual and potential conflicts of interest that come up from business or personal relationships with Cimarron’s existing and potential business counterparties, customers, employees, or competitors.

Gifts, Entertainment, & Travel– Supplier will not offer to, provide to, or accept from Cimarron employees, contractors, or business agents, extravagant or excessive gifts, entertainment, or travel, and Supplier will not offer to, provide to, or accept from other parties on behalf of Cimarron, extravagant or excessive gifts, entertainment, or travel.

Legal Compliance– Supplier is required to act in accordance with all applicable laws and regulations, including all applicable national, federal, state, provincial, and local laws and regulations.

Fair Competition & Marketing – Supplier is required to comply with applicable antitrust and competition laws that prohibit agreements between competitors that affect prices, costs, terms, or conditions of sale.

Immigration Laws Compliance– Supplier must only engage workers who have a legal right to work.

Environment/Sustainability– Supplier must fully comply with all applicable environmental laws and regulations and conduct business in a resource-conserving manner. Supplier shall identify the risks and environmental impact of the lifecycle of their products during the production, distribution, and transportation processes.

• Resource Efficiency– Supplier shall reduce energy, water and natural resource consumption by implementing conservation and substitution measures.

• Management of Wastewater and Emissions to Air– Supplier shall implement a systematic approach to identify, control and reduce wastewater and emissions to air produced by its operations.

• Disposal of Waste Material – Supplier shall implement a systematic approach to identify, manage, reduce and responsibly dispose of or recycle hazardous and non-hazardous material.

• Prevention of Pollution – Suppliers shall minimize hazardous substance consumption by implementing reduction / substitution measures and preventing pollution.

• Safe Handling of Materials – Suppliers shall have systems in place to ensure safe handling, use, storage, transport and disposal of all materials.

• Permitting – Supplier shall obtain, keep current and comply with all required environmental permits.

• Safety and Health Risks for Local Residents – Supplier shall systematically and regularly evaluate the impact of their activities on local residents including transportation of goods.

Supplier Diversity/Inclusive Supply Chain– Supplier is to demonstrate a diverse workforce composition by actively embracing workforce age, gender, race, national or ethnic origin, religion, language, political beliefs, sexual orientation, and physical ability and by promoting supply chain inclusion throughout their own supply chains.

Financial Reporting– Supplier shall maintain accurate and transparent books, records, and accounts that accurately and completely reflect all transactions involving Cimarron and provide that information to Cimarron, its auditors, advisors, and regulatory/government authorities, upon request.

5. PROTECTION OF INFORMATION

Confidentiality – Supplier must protect the privacy and confidentiality of Cimarron’s customers, employees, and contractors, in accordance with the terms of the agreement between Supplier and Cimarron.

Data Protection/Privacy – Supplier shall comply with applicable privacy and information security laws and associated regulatory requirements as well as with Cimarron’s privacy and security policies when personal information is collected, stored, processed, disclosed, transferred, and/or shared.

Supplier shall institute appropriate data and system protections to mitigate the risk of data damage and compromise by outside threat actors. Supplier will promptly notify Cimarron in the event of a material breach of those defenses resulting in potential or actual damages.

Compliance – Supplier shall implement effective management systems and a governance structure to facilitate compliance with all applicable laws and promote continuous improvement with respect to the expectations set forth in this Code.

6. AUDITS & ASSESSMENTS

Cimarron reserves the right to audit compliance with this Code. Audits may include facility inspections that include worker interviews and a review of Supplier records and business practices. Such audits are conducted by Cimarron or its appointed third party. If an audit identifies a violation of this Code, Supplier must act promptly to correct the situation to Cimarron’s satisfaction, with a corrective action plan. Failure to rectify compliance gaps may result in termination/discontinuation.

7. DUTY TO REPORT

Supplier is directly responsible for promptly reporting to Cimarron any actual, attempted, or apparent violation of law. To report an actual or suspected violation of law or this Code, you must contact Cimarron at Supplychain@cimarron.com

8. Compliance Declaration:

The supplier declares herewith:

• Legal compliance

- to comply with the laws of the applicable legal systems,

- to develop, implement and maintain methods and processes appropriate to its products and services to minimize the risk of introducing counterfeit parts and materials into deliverable products,

- to establish effective processes to detect counterfeit parts and materials and, if detected, quarantine the materials and notify the OEM customer and/or law enforcement as appropriate,

- to accurately record, maintain and report business documentation including, but not limited to, financial accounts, quality reports, time recording, expense reports and submissions to customers and regulatory authorities, when appropriate,

- to maintain books and records in accordance with applicable law and generally accepted accounting principles.

• Labor and Human Rights

- to respect the personal dignity, privacy, and human rights of each individual,

- not to use forced or involuntary labor,

- to uphold equal opportunities for and treatment of its employees irrespective of skin color, nationality, race, disabilities, political or religious conviction, sexual orientation, age, sex or social background,

- to refuse to tolerate any unacceptable treatment of employees, such as mental cruelty, sexual harassment, or discrimination,

- to honor the right to reasonable compensation and guarantee the applicable national statutory minimum wage,

- to respect the maximum number of working hours determined in the applicable laws,

- to acknowledge, as far as legally possible, the right of free association of employees and to neither favor nor discriminate against members of employee organizations or trade unions,

- to employ no workers under the age of 16 years.

• Corruption, Extortion, Bribery

- to tolerate no form of corruption, extortion, and bribery,

- not to offer or take receipt of any gift, loan, fee, reward or other advantage to or from any person as an inducement to do something which is dishonest, illegal or a breach of trust.

• Health and Safety

- to take responsibility for the health and safety of its employees,

- to provide training and ensure that employees are educated in health and safety issues,

- to establish reasonable occupational health and safety management rules,

- to control hazards and take the best reasonably possible precautionary measures against accidents and occupational diseases.

• Environment

- to act in compliance with the applicable statutory and international standards of environmental protection,

- to minimize environmental pollution and make continuous improvements in environmental protection,

- to avoid or continuously reduce all forms of waste.

• Supply Chain

- to promote the compliance with the principles of this Code of Conduct among its suppliers,

- to consider the compliance with these principles when selecting suppliers,

- to have implemented a conflict-free sourcing policy to ensure that so-called “conflict minerals” are not used by their suppliers and sub-suppliers throughout the whole supply chain.