Human Rights Policy Statement

Quanex Building Products Corporation (“Quanex” or the “Company”) acknowledges and respects the principles contained in the United Nations Declaration of Human Rights, which are consistent with the Company’s core values. We are led and sustained by these core values, a set of fundamental standards that form our moral compass and guide us in the conduct of our business around the world. Quanex endeavors to manage its business operations in a manner that seeks to promote and enhance human rights for its stakeholders and others within its sphere of influence. The Company’s executive leadership team is responsible for day-to-day implementation of the Company’s efforts with regard to the protection of human rights.

The Quanex CREED

In considering the importance of human rights in the context of conducting our business, Quanex emphasizes the core values set forth in the Quanex CREED:

Continuous Improvement and Innovation
Respect with Open and Honest Communication
Excellent Customer Service
Exemplify Safe and Healthy Living
Do the Right Thing

These core ethical standards are vital not only to our day-to-day work, but also to our ongoing efforts to help ensure that human rights are respected throughout the world by our employees, suppliers, customers, and others. Continuous improvement and innovation will allow us to develop, extend and improve our management of human rights issues. Respect with open and honest communication is a necessary precondition to ensuring that we understand potential human rights issues so that we can proactively and positively address them. Likewise, a necessary aspect of providing excellent customer service is an ability to ensure that we have done what we can to help protect human rights for our own employees and throughout the supply chain. Supporting it all is our foundational commitment to doing the right thing and promoting safe and healthy living for all of our employees and other stakeholders.

Safe and Healthy Workplace

We believe that our workers are our most important asset. Our commitment is to provide a safe and healthy working environment for all of our employees and contractors, and to comply with all applicable safety and health laws and regulations. We work to provide and maintain a safe, healthy and productive workplace, in consultation with our employees and contractors, by addressing and remediating, minimizing or eliminating any identified risks of accident, injury or negative health impact.

Ethical Business Conduct

We are committed to maintaining a high standard of business ethics and to continually demonstrating integrity and honesty in full compliance with all applicable law. The Company’s Code of Business Conduct and Ethics contains stringent rules and guidelines, and serves as a reminder of the Company’s policies and its commitment to do what is right and ethical for Quanex and its stakeholders. On an annual basis, all salaried employees must complete a questionnaire verifying their compliance with the Code of Business Conduct and Ethics, and confirming that they have not witnessed any unreported violations. These questionnaires will then be reviewed by our chief compliance officer, who will direct any necessary investigations and/or corrective actions.

Diversity and Inclusion

We are committed to equal opportunity and are intolerant of discrimination and harassment in all its forms. We seek to maintain a working culture that supports the well-being and inclusion of all employees and is committed to encouraging a positive working environment which meets legal requirements. We strive to maintain workplaces that are free from discrimination or harassment on the basis of race, sex, color, national or social origin, ethnicity, religion, age, disability, sexual orientation, gender identification or expression, religious beliefs, union organization, political opinion or any other status protected by applicable law. Decisions related to recruitment, hiring, placement, development, training, compensation and advancement at Quanex are based solely on a person’s qualifications, performance, skills and experience.

Child Labor/Forced Labor/Human Trafficking

We will not tolerate the use of child or forced labor, slavery or human trafficking in any of our operations or facilities, or those of our suppliers or vendors. We will not tolerate the exploitation of children or the trafficking, physical punishment, abuse or involuntary servitude of any worker. We support the elimination of forced labor, indentured labor and exploited bonded labor.

Freedom of Association, Working Time and Wages

Quanex and its subsidiaries are committed to open and direct communication and engagement between workers and management as the most effective means of addressing and resolving workplace issues. In accordance with applicable national, state and local laws and regulations, we also 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. We strive to ensure that our employees may openly communicate and share ideas and concerns with management regarding working conditions and management practices without fear of discrimination, retaliation, or intimidation, and we are committed to complying with applicable labor and employment laws wherever we operate.

We believe that all employees have the right to fair pay and a living wage. We seek to compensate employees regularly and in a timely manner in accordance with all applicable laws and regulations, and to ensure that the working time required of our employees does not exceed the limits set by any applicable law or regulation.

Conflict Minerals

We are committed to avoiding the purchase of any materials that contain gold, tantalum, tin, or tungsten (3TG minerals) which might have helped to finance armed groups or otherwise contributed to conflicts within the Democratic Republic of Congo and its surrounding areas. To that end, our Supplier Code of Conduct requires that our suppliers comply with all rules and regulations applicable to the sourcing and provision of 3TG minerals, and we annually conduct an extensive due diligence process to verify that any such minerals used in our supply chain do not originate from smelters or other sources that might contribute to conflicts or support armed groups within the covered countries.

You can find more information around our efforts with regard to conflict minerals in our Conflict Minerals Report, located on our website at https://www.quanex.com/who-we-are/conflict-minerals.

Security of our Facilities and Employees

We believe that every employee, contractor, and visitor to our company has a right to a secure workplace that is free from threats of violence, theft, or other crimes. We have a zero-tolerance policy for any violence or criminal activity within our plants, and we have installed appropriate security measures at all of our facilities to help ensure that our employees and visitors remain safe and secure. These measures may differ from plant to plant based on each facility’s characteristics.

Employee Development and Training

As part of our commitment to the well-being of our employees, we believe it is important to provide training and development opportunities. To this end, we offer tuition reimbursement programs in certain circumstances, and we sponsor employees for attendance at continuing education events and membership in various professional organizations. We also maintain subscriptions to multiple online training programs, through which we provide various training sessions for employees at all levels of the organization.

Policy Training, Input, Guidance and Reporting for Employees

We strive to create a workplace in which open and honest communication is valued and respected at all levels, and we welcome any input from our employees with regard to the content or implementation of this Human Rights Policy and any of our other policies. To the extent any person (a) believes there is a conflict between the language of any policy and the Company’s actions; (b) has any questions regarding any policy or its maintenance or implementation; or (c) would like to confidentially report a potential violation of any policy, such person may raise these questions and concerns with the local management team or Human Resources department, or by contacting the Quanex Alert Line at (888) 475-0633, or via the web at https://quanex.alertline.com.

We also believe it is important that our employees understand the tenets set forth in this policy statement and the significance of respecting human rights. As such, we will provide appropriate training with respect to such issues on a periodic basis.