Supplier Code
of Ethics

Our relationships with vendors, contractors and suppliers are critical to achieving responsible and ethical corporate performance. The Supplier Code of Ethics (“Supplier Code”) provides the foundation for relationships built on lawful and fair practices.  For the purposes of this Supplier Code, “supplier” refers to any company, corporation or other entity or person that provides, or seeks to provide, goods or services to Ensign, and includes the supplier’s employees, agents, workers, representatives, contractors and subcontractors.

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Compliance with the Supplier Code of Conduct

Suppliers should carefully review the Supplier Code. Suppliers are responsible for ensuring that they comply with Ensign’s standards of conduct. Suppliers must never act in any way that undermines compliance with Supplier Code. The Supplier Code also outlines important mechanisms for mutual accountability, including the requirement that Ensign and its suppliers promptly report all ethical concerns involving Ensign and cooperate in any investigation of alleged violations of its code of ethics.

Ensign expects its employees and business partners to respect one another and the unique character and contribution they bring to our operations. Treating each other with dignity, respect and fairness is the foundation of good business conduct.

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Health Safety & Environmental

Suppliers must share Ensign’s commitment to providing a safe and healthy workplace and conducting operations in an environmentally responsible manner. Suppliers are responsible for observing all Health Safety and Environmental (“HSE”) laws, regulations, rules and permit requirements that apply to their operations. They must also take precautions to protect the environment, health and safety of their employees, Ensign employees, business partners and members of the communities in which we operate.

Suppliers must promptly report and take immediate steps to correct all accidents, injuries, unsafe or unhealthy conditions, and potential violations of health, safety or environmental laws, regulations or Ensign policies. Requests to violate established health, safety or environmental procedures in connection with Ensign-related activities must never be acted on and must always be reported. In addition, each supplier has the obligation to stop work activities that may represent a threat to safety or the environment. Suppliers are expected to uphold Ensign’s Health, Safety and Environmental Policy.

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Dignity, Respect and Fairness

Suppliers must cooperate with Ensign’s commitment to an inclusive workforce free of unlawful discrimination. Ensign requires that suppliers not engage in discrimination in any employment practice, including recruiting, hiring, compensation, benefits, transfer, termination, training or social or recreational programs, on the basis of race, color, religion, gender, sexual orientation, gender identity, age, national origin, military or veteran status, disability or any other legally protected characteristics.

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Harassment, Violence and Weapons

Harassment and violence have no place in the workplace or off-site. They are strictly prohibited in connection with Ensign-related activities and will not be tolerated. Suppliers are expected to cooperate with Ensign’s commitment to prohibit harassment and threats of violence. Ensign prohibits the possession of firearms, guns, explosives and any other weapons, as well as ammunition, while on Ensign premises unless otherwise precluded by the laws of a particular jurisdiction.

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Drugs and Alcohol

Suppliers are expected to be free from the influence of alcohol, drugs and improperly used prescription medicine when conducting Ensign’s business, whether on or off Ensign’s premises.

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External Communications

Suppliers are prohibited from engaging in any communication representing Ensign’s opinion in any forum without prior written approval.

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Antitrust Laws

Suppliers are expected to comply with applicable antitrust and fair competition laws and to not participate in any activity that could be considered a violation of antitrust laws.

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Anti-Corruption Laws

Suppliers must comply with all applicable anti-corruption laws, including the U.S. Foreign Corrupt Practices Act, which makes it a criminal offense to bribe or offer to bribe a foreign governmental or political official to obtain or retain business. No supplier may participate in bribes or kickbacks of any kind, whether in dealings with public officials or individuals in the private sector. Suppliers must not give, promise to give or offer to give anything of value, directly or indirectly, to a governmental official or employee, government agency, political party, public international organization or any candidate for political office in order to improperly influence any act or decision or otherwise improperly promote the business interests of Ensign.

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Anti-Boycott Laws

Suppliers must not participate or support any international boycott that is not sanctioned by the United States government or applicable laws.

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Trade Laws

Suppliers must comply with applicable trade controls.

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Accounting and Disclosure Practices

Suppliers are expected to honestly and accurately record and report all matters related to business with Ensign. Books, records, accounts and financial statements should be maintained in reasonable detail, appropriately reflect all transactions with Ensign and conform to generally accepted accounting principles, applicable legal requirements and a system of internal controls. Suppliers shall make their books, records, accounts and financial statements available to Ensign upon written request and or as stated and agreed upon within any Agreement by and between Suppliers.

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Records Retention

Suppliers shall create, retain and dispose of business records in compliance with all applicable legal and regulatory requirements. Further, suppliers must cooperate with Ensign’s business record retention needs if the supplier is advised or otherwise should recognize that a business record may be relevant to an audit, investigation or pending or threatened legal or regulatory proceeding.

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Political Activities

Without prior written approval, suppliers may not use Ensign funds or resources for political activities, make any political contributions or present any gifts on behalf of Ensign to any candidate for public office or elected official, or represent Ensign or authorize any third party to represent Ensign in making contacts with any federal, state or local government official (or member or employee of a legislative body or government agency) to influence policy, legislation, agency rules, regulations or any other official action.

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Charitable Giving

Suppliers shall not make or promise charitable contributions on Ensign’s behalf or take advantage of their relation- ship with Ensign to inappropriately solicit Ensign employees, suppliers or other business partners for contributions or to become involved in a nonprofit organization.

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Building and maintaining relationships with our stakeholders through integrity and ethical practices is critical to our long-term success. All Ensign suppliers must conduct all business activities in accordance with the following requirements:

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Fair Dealing

Suppliers must deal fairly with Ensign’s customers, suppliers, contractors, royalty owners, competitors, employees and other stakeholders. Suppliers must not take unfair advantage of anyone through manipulation, abuse of privileged or confidential information, misrepresentation, fraudulent behavior or any other unfair practice.

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Protection of Confidential Company Information and Personal Data

Suppliers must strictly adhere to all confidentiality obligations as agreed upon and written in any Agreement by and between Ensign and Supplier. Suppliers may not access, use, remove, copy or share confidential company information or personal data without a legitimate business purpose and prior written approval from Ensign. Confidential information includes proprietary information regarding business activities and financial performance, as well as any nonpublic information that might be of use to competitors or harmful to Ensign or its business partners if disclosed. Suppliers must be familiar with and abide by laws and regulations that govern the collection, use and disposal of personal data, including wage, salary, benefit and other confidential information related to Ensign employees, contractors, directors, shareholders, royalty owners, customers and other business partners. Suppliers must ensure the confidentiality of this information and return all confidential information and personal data after their relationship with Ensign ends or as stated and agreed upon within any Agreement by and between Suppliers.

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Insider Trading

Suppliers may not use or share insider information concerning Ensign for the purpose of trading in Ensign or other securities. Insider information includes material nonpublic information about matters such as significant contracts, claims, liabilities, major litigation, potential sales, mergers or acquisitions, development plans, activities, earnings, forecasts and budgets.

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Protection of Ensign Assets

Suppliers are expected to protect Ensign asset’s; (i) If Supplier has control of Ensign Equipment or Assets, or (ii) has been contracted by Ensign to do so; against theft, loss and misuse. Ensign assets include tangible items like buildings and equipment, as well as intangible items like business plans and potential prospects. When operating a vehicle on Ensign business, suppliers are expected to do so in a safe manner.

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Conflicts of Interest

Suppliers must avoid actual conflicts of interest or the appearance of conflicts of interest in business transactions and relationships involving Ensign. A conflict of interest exists when private interests, financial or otherwise, interfere with Ensign’s interests. Conflicts of interest commonly arise when:

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• A supplier uses Ensign resources, such as facilities, equipment, materials, computers, office supplies, information or other assets, for personal gain or inconsistently with Ensign’s best interests;

• A supplier takes personal advantage of a business opportunity or investment opportunity made available as a result of their relationship with Ensign; or

• A supplier has a family member or friend employed by Ensign.

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Business Gifts and Entertainment

Suppliers are expected to understand and comply with Ensign’s policies governing business gifts and entertainment; Ensign Suppliers must never offer or provide personal incentives, rewards or bribes to any Ensign employee, contractor or supplier in an effort to influence a business decision or gain an unfair advantage. Suppliers may offer reasonable gifts and entertainment consistent with customary business practices and in compliance with applicable law and company policy as long as they do not influence or appear to influence a Ensign employee to act in a manner contrary to Ensign’s interests. Any item of value provided by a supplier is considered a gift even if it is provided in conjunction with ordinary business activities. Suppliers are expected to make available upon request records detailing all gifts and entertainment provided to Ensign employees or contractors.

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