Code of Supplier Conduct

As a condition of doing business, Quanex Building Products Corporation (“Quanex” or the “Company”), for itself and on behalf of each of its subsidiaries, expects that each of its suppliers and their affiliated entities will comply with the ethical principles and requirements set forth in this Code of Supplier Conduct. Quanex further expects that its suppliers and their affiliated entities will in turn ensure that all of their own employees, contractors, and suppliers will abide either by this Code or by a similar ethical code that adequately addresses the matters discussed herein. By providing any good or service to Quanex or any of its subsidiaries, you are confirming that you will abide by the ethical standards set forth below.

Human Rights and Labor Management Standards

1. Avoidance of Child Labor. Suppliers shall not use any sort of child labor and shall ensure that its labor force remains consistent with the International Labor Organization’s (ILO’s) core labor standards regarding the abolition of child labor.

2. Freely Chosen Employment. Suppliers will not tolerate slavery, servitude, or human trafficking at any level of the supply chain, and will abide by the ILO’s core labor standards regarding forced and compulsory labor.

3. Freedom of Association and Right to Collective Bargaining. Quanex and its subsidiaries believe that open and direct communication and engagement between workers and management are the most effective means of resolving workplace issues. However, Suppliers are expected to recognize and respect the right of workers to freely associate, to form and join workers’ organizations of their choosing, and to bargain collectively, or to refrain from doing so, in Quanex Building Products Corporation Code of Supplier Conduct accordance with applicable national laws and regulations. Suppliers must ensure that workers may openly communicate and share ideas and concerns with management regarding working conditions and management practices, without fear of discrimination, retaliation, or intimidation.

4. Working Time, Wages, and Benefits. Working time for suppliers’ employees shall not exceed the maximum set by any applicable law or regulation. Compensation shall be paid to employees regularly, in a timely manner, and in accordance with all applicable laws and regulations.

5. Discrimination. Quanex and its subsidiaries will not tolerate any form of discrimination from its suppliers based on legally protected personal characteristics. Suppliers will not discriminate against any person based on national origin, color, race, ethnicity, gender, sexual orientation, age, religion, veteran status, political opinion, or disability.

6. No Harassment or Violence. Suppliers will treat all employees with respect and dignity and will protect them from intimidation, harassment or violence of any form in the workplace.

Environmental, Health and Safety Standards

7. Environmental. Suppliers will comply with all applicable laws and regulations regarding protection of the environment, and shall endeavor wherever reasonably possible to minimize their waste, energy use, wastewater outflows, and impact on the environment. Suppliers shall ensure the safe and compliant handling, storage, transportation, disposal, recycling, reuse and management of hazardous and non-hazardous waste, air emissions and wastewater discharges. Suppliers shall respect the fundamental human right to safe water and sanitation, and shall take all steps necessary to ensure that they do not pollute any drinking water sources, waterways, freshwater ecosystems, or other important sources of clean water.

8. Health and Safety. Suppliers will comply with all applicable laws and regulations regarding the provision of a safe and healthy workplace. Suppliers will endeavor at all times to provide adequate protection of their employees against chemical, biological and physical hazards. Suppliers shall ensure that safety programs remain in place for managing and maintaining production processes in accordance with applicable safety standards. Suppliers must comply with all applicable product safety and product labeling regulations, and must adequately communicate all product-handling requirements wherever necessary.

Business Ethics Standards

9. Competition Law. Suppliers will comply with all applicable anti-trust and fair competition laws and regulations in the countries where they operate.

10. Anti-Corruption and Anti-Bribery. Suppliers will operate in accordance with all applicable national and international laws and regulations relating to corruption, bribery, and money laundering, including but not necessarily limited to the United States Foreign Corrupt Practices Act and the UK Bribery Act 2010.

11. Gifts and Hospitality. Suppliers should avoid offering gifts, favors, gratuities or hospitality to employees of Quanex or its subsidiaries; provided, however, that Suppliers may offer such items if such offer (a) occurs infrequently; (b) arises in the ordinary course of business, (c) is reasonable in size and scope; and (d) involves gifts or events that are appropriate and fitting in light of their business purposes.

12. Conflict Minerals. Suppliers will comply with all applicable laws and regulations concerning the sourcing of tin, tantalum, tungsten and gold from the Democratic Republic of Congo or any surrounding country. Suppliers will use their best efforts to avoid sourcing any such mineral from any mine or smelter that benefits any armed group or otherwise contributes to any conflict within such countries. Upon request, suppliers must provide documentation tracing the origins of any such minerals that are necessary to the functionality of the supplier’s product.

13. Trade Sanctions. Suppliers shall comply with international trade law, and shall respect and abide by any applicable trade sanctions or other trading prohibitions. Supplier shall not adopt or support any effort to boycott sales to any country that is not itself the object of any sanction by the United States.

14. Confidentiality and Data Security. Suppliers must respect and protect all private and/or confidential information received from Quanex or any of its subsidiaries, including any personally identifiable information relating to any employee or other natural person associated with Quanex or any of its subsidiaries. Suppliers must not use or disclose any of the Company’s confidential information to the Company’s detriment, and must not disclose or use any such information in
violation of any contractual agreement with Quanex or its subsidiaries. Suppliers must ensure that they have developed and implemented reasonable and appropriate security measures required to protect their computer systems and electronic data.

15. Risk Management and Business Continuity. Suppliers shall implement mechanisms to regularly identify, evaluate and manage risks across all areas of the supply chain. Suppliers are further encouraged to implement reasonable and appropriate business continuity plans for operations that supply any good or service to Quanex or its subsidiaries.

16. Good Faith, Transparency, and Honesty. In any business dealing involving Quanex or its subsidiaries, suppliers must at all times work in good faith and communicate clear, correct and truthful information.

17. Supplier Audits. Quanex may review each supplier’s compliance with the ethical principles set forth in this Code of Supplier Conduct. The Company reserves the right, upon reasonable advance notice and during normal business hours, to conduct an audit of any supplier location that is providing goods or services to Quanex or its subsidiaries to verify compliance with the ethical commitments set forth herein.