Supplier Code of Conduct

The following are policies and practices that we expect our suppliers to adhere to in their normal business operations and performance of services for e.l.f. Beauty (“e.l.f.” or the “Company”).

Compensation and Working Hours

The supplier will fairly and competitively compensate their employees in compliance with local and national laws. The supplier will not allow workers to work more than the maximum number of daily or weekly hours as determined by local and national laws.

Child, Forced, and Prison Labor

The Company opposes the exploitation of children in the work force and the use of forced or prison labor. It is our policy to not purchase from any supplier known to employ child, forced, or prison labor. The supplier must maintain employment on a voluntary basis and not employ child, forced, or prison labor. The Company also opposes human trafficking and slavery, and will not purchase from any supplier known to be engaging in such activity.

The human rights and labor standards outlined in the Company’s Human Rights Policy and Labor Management Policy are also applicable to suppliers.

Discrimination/Human Rights

The supplier must have social and political commitments to basic principles of human rights and will not discriminate against their employees in hiring practices or any other term or condition of work on the basis of race, color, national origin, gender, religion, disability, or other similar factors.

Workplace Environment and Safety

The supplier must maintain a safe, clean, healthy, and productive workplace for its employees and the environment. The Company will not do business with any supplier that maintains an unhealthy or hazardous work environment.

The occupational health and safety standards outlined in the Company’s Occupational Health & Safety Policy are also applicable to suppliers.

Animal Testing

The Company does not accept products, or products containing ingredients or combinations of ingredients, that utilized any form of animal testing. The supplier may not perform such testing.

Ingredients

The supplier must ensure raw materials conform to appropriate standards and specifications. In particular, raw materials should be:

  • cosmetic grade
  • stored, handled, and labeled to prevent mistakes, contamination, and degradation
  • maintained in containers that are labeled with the identity, lot number, and control status
  • sampled and tested for conformity with specifications prior to usage

Formula Cards

It is the responsibility of the supplier to strictly follow the approved formula card issued by the Company for all production. Any deviations from the issued formula card must receive written approval from the Company’s R&D Department in advance.

Inventory

We encourage our suppliers to help compress lead-times. That said, the Company will only purchase goods based on our valid purchase orders.

U.S. Export Controls and Economic Sanctions

As a company headquartered in the United States, the Company requires compliance with all applicable U.S. export controls, economic sanctions and other applicable U.S. laws and regulations governing trade (collectively, “Trade Laws”), including but not limited to the International Traffic In Arms Regulations; the Export Administration Regulations (“EAR”); the U.S. anti-boycott regulations, including those under the EAR and U.S. Department of the Treasury regulations; and the various economic sanctions regulations of the U.S. Department of the Treasury, Office of Foreign Assets Control (“OFAC”).

In furtherance, and not in limitation of the foregoing, the supplier shall not do business in or with any countries comprehensively sanctioned by OFAC or with any entities or persons on OFAC’s Specially Designated Nationals (“SDN”) list or U.S. Consolidated Screening List. Doing business with any entity that is 50 percent or more owned (directly or indirectly), by persons or entities on the SDN List is also prohibited, even if the entity itself is not listed.

The current list of countries/regions subject to comprehensive embargos is as follows:

  • North Korea
  • Cuba
  • Iran
  • Syria
  • The Crimea region

The supplier is therefore prohibited from conducting any business on behalf of or related to the Company in any of these countries/regions. For clarity, this prohibition applies to sourcing any ingredient or component from, or having any manufacturing or labor performed in, any country/region listed above.

U.S. Foreign Corrupt Practices Act

The supplier shall comply with the U.S. Foreign Corrupt Practices Act (the “FCPA”).

The FCPA prohibits U.S. companies (including each Company) and their officers, directors, employees and agents, which includes the supplier, from:

  • giving, promising or offering anything of value, whether directly or indirectly,
  • to any foreign official (including an official of a public international organization),
  • with the intention of obtaining or retaining business or obtaining an improper business advantage.

When acting on behalf of, in connection with, or otherwise related to the Company or the Company’s business, the supplier and supplier’s employees shall not:

  • give, pay, offer, promise to pay, or authorize the giving or payment of money or other thing of value to any foreign official or to any person while knowing or being aware of a probability that the payment or promise to pay is being made to or will be passed on to a foreign official;
  • make, offer, promise, or authorize any payment or gift in violation of local law in any country; or
  • enter into any transaction that is intended or designed to circumvent the laws of any country.

Audits and Certification

The Company conducts audits to ensure suppliers are adhering to Company policies outlined in this statement. The Company also requires that all suppliers disclose any certifications the supplier has obtained. This helps the Company screen for suppliers that value environmentally and socially responsible business practices. As of March 2021, our Tier 1 third-party suppliers maintain the following certifications:

CertificationDescription% of Tier-1 Supplier Facilities certified(1)
ISO 9001:2015An internationally recognized standard for Quality Management Systems (QMS) Certified by independent third parties Certification is maintained through a program of annual surveillance audits, as well as recertification audits every three years93%
ISO 14001:2015An internationally recognized standard for environmental management systems (EMS) Certified by independent third parties Certification is maintained through a program of annual surveillance audits, as well as recertification audits every three years41%
SA8000An internationally recognized social certification standard that encourages organizations to develop, maintain and apply socially acceptable practices in the workplace Certified by independent third parties Certification is maintained through a series of required surveillance audits in the 3-year certification cycle, as well as recertification audits every three28%
SEDEX(2)A non-profit organization for businesses committed to continuous improvement of the ethical performance of their supply chains Certified by independent third parties Certification is maintained through a series of required surveillance audits in the 3-year certification cycle, as well as recertification audits every three years19%
(1) As of March 2021.
(2) The Supplier Ethical Data Exchange.

The Company plans to launch the EcoVadis program, a third-party certification tool to evaluate and monitor the sustainability performance of our suppliers. EcoVadis 360° ESG assessments are used to assess the environmental and social performance of our suppliers based on supplier documents related to four key areas: Enviornment, Labor and Human Rights, Ethics, and Sustainable Procurement.

Collectively, these efforts demonstrate the Company’s commitment to sustainable, ethical, and transparent supplier relationships.

Non-Conformance

The Company regularly monitors its suppliers’ performance and compliance. In the event that a supplier does not adhere to this policy, the Company reserves the right to conduct an investigation and terminate its relationship with the supplier.

Oversight

This policy is overseen by the Company’s Board of Directors and senior management.

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