NuScale Power, LLC
Third Party Code of Conduct
At NuScale Power, LLC ("NuScale"), one of our most important and valued assets is our reputation for ethical, honest, and fair behavior and business conduct. The success we intend to achieve is unattainable if we do not live up to this reputation in our daily activities. We must be honest and transparent in our dealings, both inside and outside of the company, and always act with the upmost integrity.
NuScale’s "code of conduct" is embodied in our Compliance and Ethics Manual. We expect our business partners, vendors, contractors, agents, and representatives (our "Collaborators") to comply with the commitments of this Third Party Code of Conduct, and ensure that all of their employees and sub-contractors who engage in activities on behalf of NuScale do the same.
Every day, the actions we take to advance our Mission and Vision are performed in conformance with NuScale’s core Values:
• SAFETY: We will build and sustain a safety conscious work force in order to assure the safety of the products we produce, as well as the safety of our employees and our partners.
• EXCELLENCE: We will earn the respect of our stakeholders by delivering on our promises and demanding excellence of ourselves in the work we produce.
• INTEGRITY: We are committed to earning the trust of our stakeholders and teammates through transparency, respect and honesty in our relationships.
• TEAMWORK: We treat all people with dignity, respect each other’s perspective and work collaboratively to achieve excellence, and deliver value to our customers, partners and stakeholders.
• INNOVATION: We solve complex problems and seek creative new ways to deliver solutions that will dramatically improve access to clean, safe, affordable nuclear energy.
Health, Safety, and the Environment
Our Collaborators must be committed to creating safe working conditions and a healthy work environment for all of their workers, and should identify, anticipate, and assess emergency
NuScale Power, LLC Third Party Code of Conduct 2015 2
situations and events, and minimize their impact through the implementation of emergency plans and effective procedures.
NuScale has adopted the key principles for a strong nuclear safety culture, as set out in the Institute of Nuclear Power Operations (INPO) booklet "Principles for a Strong Nuclear Safety Culture." Our Collaborators in the nuclear industry are expected to adhere to the traits, principles, and behavioral attributes set forth in "Traits of a Healthy Nuclear Safety Culture," INPO 12-012, and "Principles for Excellence in Nuclear Supplier Performance," INPO 14-005.
Furthermore, Collaborators shall conduct their operations in an environmentally responsible manner and in accordance with all applicable environmental laws and regulations.
Human Rights and Employment Practices
Our Collaborators shall uphold the human rights of workers, and treat them with dignity and respect at all times. Collaborators shall conduct their operations in a socially responsible, non-discriminatory manner and in accordance with all applicable laws and regulations, including, but not limited to, those associated with equal opportunity, child labor, forced or compulsory labor, working hours, wages and benefits, freedom of association, data privacy, and a harassment- free work environment.
Financial and Operational Controls
The records that our Collaborators prepare for NuScale, such as reports, receipts, or invoices, shall be accurate and reliable and kept in accordance with generally accepted accounting principles and contractual obligations with NuScale. Collaborators shall also create, maintain, and dispose of business records in accordance with all applicable legal and contractual requirements.
Conflicts of Interest, Gifts, and Business Courtesies
Whenever a gift or type of entertainment is offered in the context of a business relationship (whether actual or implied), there is a risk that it may influence, or appear to influence, a business decision. The exchange of gifts or business courtesies is never required for doing business with NuScale.
Our Collaborators, their employees and subcontractors, and their family members must not receive gifts or benefits through their relationship with NuScale. Business courtesies, such as meals or other courtesies that are customary, usual, and of insignificant dollar value, may be accepted by NuScale or provided by NuScale to Collaborators on a case by case basis. However, NuScale strictly prohibits the giving or receiving of cash or the equivalent of cash of any kind.
A conflict of interest exists when a Collaborator faces a choice between what is in its own best interest, and what is in the best interest of NuScale. Our Collaborators should disclose any
NuScale Power, LLC Third Party Code of Conduct 2015 3
potential conflicts of interest to NuScale’s Chief Compliance Officer prior to entering into a business transaction.
All forms of illegal activity, including, but not limited to, corruption, misrepresentation, extortion, embezzlement, and bribery are strictly prohibited and will not be tolerated.
NuScale has a zero tolerance policy for bribery. Bribery is the act of directly or indirectly giving, or promising to give, something of value in order to influence the actions of a third party. Bribes may include offering to provide money, gifts, travel expenses, entertainment, hospitality, vacations, expenses, below-market loans or products, reciprocal favors, political or charitable contributions, or any direct or indirect benefit or consideration.
Our Collaborators shall abide by all economic or trade embargoes that the United States has adopted, whether they apply to foreign countries, political organizations, or particular foreign individuals or entities.
Our Collaborators must be aware of, and comply with, all import and export control laws, economic sanctions, and anti-boycott laws applicable to their work with and for NuScale, and must never partake in boycotts or other restrictive trade practices prohibited or penalized under the United States or other applicable law.
Collaborators shall report any apparent conflict between the laws of the United States and applicable local law requirements to NuScale’s Chief Compliance Officer. If there appears to be a conflict of laws between the United States and other countries in regard to trade compliance, such conflicts should be addressed and managed by both the Collaborator and NuScale, working with the appropriate agency of jurisdiction within their respective countries.
Our Collaborators are required to abide by all restrictions, denial orders, and debarments issued against companies, entities, or individuals that may restrict or prohibit trade. Collaborators shall institute a program of due diligence in doing business on behalf of their work for NuScale, which includes ensuring that no work is conducted with any denied, debarred or otherwise restricted parties or entities, or with parties requiring an export license, deemed export license, or authorization, without it first being obtained.
Money Laundering Prevention
Our Collaborators shall follow all applicable United States and international laws that prohibit money laundering, and are required to report cash and other suspicious transactions.
Collaborators must ensure that all banking transactions are conducted in accordance with the U.S. Office of Foreign Assets Controls regulations, which prohibit transactions with banking
NuScale Power, LLC Third Party Code of Conduct 2015 4
institutions known to have affiliations or activities involving money laundering, or other criminal activity.
Our Collaborators shall respect NuScale’s intellectual property rights and safeguard customer information and confidential information. Collaborators shall manage technology and know-how in a manner that protects NuScale’s intellectual property rights with the utmost care and in accordance with applicable laws, regulations, contractual requirements, and NuScale policies.
Fair Competition and Business Integrity
NuScale believes in fair and honest competition. Our Collaborators shall compete honestly and fairly, and shall comply with all anti-trust and fair competition laws and regulations of the countries in which it operates, including the Foreign Corrupt Practices Act (FCPA), and must never partake in anti-competitive practices, such as price fixing or bid rigging.
Our Collaborators who work on projects where government entities or agencies are involved shall follow any specific rules to which they are obligated by the terms of their contracts with such entities or agencies.
Report a Concern
Reporting an unlawful or unethical concern is the right thing to do. Our Collaborators and their employees and subcontractors should promptly report any unlawful or unethical business conduct or concern involving or affecting NuScale, whether or not the concern involves the Collaborator, by contacting any of the following:
• NuScale’s Chief Compliance Officer at email@example.com, or anonymously by calling NuScale’s Compliance & Ethics Hotline at 888-245-9049;
• NuScale’s Vice President of Supply Chain at firstname.lastname@example.org; or
• NuScale’s Legal Department at email@example.com.