At Advanced Drainage Systems, Inc., along with our directly and indirectly controlled affiliates, subsidiaries and joint ventures (collectively “ADS” or the “Company”), we understand the importance of solving modern water challenges. From the moment rain enters the drain until we safely return it to the environment, we are responsible for managing this precious resource. ADS engineers industry leading sustainable and resilient products. Environmental stewardship is at the core of our suite of solutions that provide opportunity to create broader access to clean water and sanitation, and importantly, it begins with our Suppliers. We strive to continually assess and better our supply chain that provides solutions vital to global infrastructure, working alongside sustainable suppliers. 

Purpose + Scope 

ADS is committed to conducting business fairly, honorably, with integrity and transparency, and in compliance with all applicable laws at all times throughout our supply chain. That fundamental commitment is reflected in our Code of Business Conduct and Ethics.  

ADS considers open communication and strong business relationships with our Suppliers an integral part of our commitment to conducting business with integrity and transparency. As such, ADS expects our Suppliers to share our ethical values and adhere to this Supplier Code of Conduct (the “Code”). ADS defines Suppliers as any organization or entity that directly provides goods and/or services to ADS, including its directly and indirectly controlled affiliates, subsidiaries and joint ventures.     

This Code provides the framework by which Suppliers are expected to maintain the highest ethical standards in conducting business and is an integral part of implementing our vision of maximizing value in an ethical environment. Accordingly, this Code references the Ten Principles of the United Nations (“UN”) Global Compact that ADS strives to uphold. 

Please review the Code regularly, as you are expected to adhere to it and ensure that your employees, agents, and subcontractors adhere to it, both in form and in spirit. The provisions of the Code are in addition to any agreement or contract between the Supplier and ADS and should also be read in conjunction with the ADS Code of Business Conduct and Ethics, Global Anticorruption Policy, and other applicable policies. If you have any questions or concerns, please reach out through appropriate ADS channels, listed at the bottom of the Code, to address them. 

ADS considers collaboration in the supply chain an integral part of our success and strives to operate as an integrated team with Suppliers. We look to select Suppliers based upon their ethical standards in conducting business, as well as on the quality and competitiveness of their products and services. We look for strong progressive social and environmental programs in addition to pervasive business ethics. ADS’s Supplier Code of Conduct assists us in choosing and maintaining business partners who share similar principles and values. Our requirements in the Code are borderless and global in nature; however, if a local law or regulation is inconsistent with a contained policy, the Supplier should adhere to the local law or regulation. Suppliers are expected to be familiar with the business practices of their suppliers and subcontractors, and ensure they operate according to the Code. ADS reserves the right to terminate its relationship with a Supplier that fails to comply with this Code. 

Policy 

Environment – Sustainability 

As one of the top plastics recyclers in the United States and a leading water management company, we are guided by our commitment to preserve and protect water.  ADS expects our Suppliers to share our commitment to reduce consumption, reuse consumer products and preserve precious resources in order to protect the environment. ADS does not tolerate violations of laws, rules, or regulations on environmental safety and precautions. Suppliers must store, handle, and dispose of hazardous materials in accordance with applicable law.  

ADS seeks strong business relationships with Suppliers willing to go beyond regulatory requirements to protect the environment, through efforts of recycling and conserving energy and natural resources. ADS encourages Suppliers to consider new ways to protect our environment through innovation, implementation, and promotional activities. 

Climate 

ADS has committed to setting science-based targets for Greenhouse Gas Emissions (GHGs) in line with the Paris Agreement and limiting the global temperature increase to 1.5°C.  Our GHG emissions reduction goal once approved by the Science Based Targets initiative will include reductions in GHGs from the fuel we burn in our operations and fleet (scope 1) as well as the energy we purchase (scope 2) and will also include a scope 3 reduction target. Based on our analysis, most of our scope 3 emissions can be attributed to our Suppliers.  Therefore, we expect all our Suppliers to focus on reducing GHG emissions within their respective footprints as well.   

Water is Precious 

As an ADS Supplier, you must strive to preserve and protect water through reducing water consumption, minimizing wastewater and water pollution, and sustainably managing stormwater in your own operations. Our commitment to developing innovative solutions that protect water is core to what we do every day, and we expect you to share this commitment.  

Minimize Consumer Product Waste and Energy 

As an ADS Supplier, you must strive to reduce consumer product waste impact by using reusable products and resources, reduction of unnecessary one-time use products, and energy reduction in your operations. Our commitment goes beyond reduction through reuse of plastic waste in manufacturing, and it extends into the workplace. We expect you to share this commitment. 

Labor - Valuing your People 

ADS is committed to creating a diverse, inclusive, safe and fair working environment, and we expect the same of Suppliers. Suppliers should be an equal opportunity employer that encourages different ideologies and promotes conversation and be committed to creating a workplace where each person feels valued, heard, and respected. We believe that a diverse employee family enables our success, and accordingly, Suppliers should strive to ensure their compensation and benefits reflect the value of a diverse family. 

We strive to create an environment where everyone can bring their whole self to work, feels empowered to influence others to drive positive impact, and understands how we collectively contribute to tomorrow. 

Compensate Fairly 

Suppliers must comply with all applicable wage and hour laws, where it pays all workers no less than minimum wage, provides at least the required benefits, limits hours to industry standard, and compensates employees for overtime. Where laws and regulations may not govern wages or hours, we expect Suppliers to compensate their employees fairly and limit their working hours to industry standards. 

Hiring + Employment Practices + Freedom of Association 

Suppliers must be an equal opportunity employer and strive to maintain a workspace free of any type of discrimination or harassment, including race, color, veteran status, religion, national origin, ancestry, pregnancy status, gender, sex, age, marital status, disability, medical condition, sexual orientation, gender identity, or any other characteristics protected by applicable law. Suppliers’ workers are free to join associations of their own choosing and have the freedom to collectively bargain where the local law confers such rights. 

Zero Tolerance for Forced Labor + Child Labor 

Suppliers must not benefit directly or indirectly from human trafficking, forced, involuntary, or slave labor. Suppliers must not participate in or work with companies that use slave labor. Discovered human trafficking and forced labor should be reported, and handled, by Suppliers in accordance with all applicable laws and regulations, including, without limitation, all applicable local laws and regulations.  

Suppliers must not engage in or support child labor practices. All employees or contracted labor must meet the greater of (1) the minimum age standards set forth in the UN Global Compact’s Ten Principles and (2) the minimum age requirements set by applicable law. 

Health + Safety is Paramount 

Suppliers have the responsibility to treat the work environment with respect and care. Suppliers shall ensure a healthy and safe workplace by implementing procedures and safeguard to prevent workplace hazards, accidents, and injuries. Suppliers are to follow applicable codes and regulations of the local area and must continuously evolve their health and safety codes to ensure a healthy and safe working environment.  

No Tolerance for Workplace Harassment 

Suppliers are expected to be equal opportunity employers while creating an environment free from discrimination and harassment. Suppliers must strictly prohibit discrimination or harassment of any kind including discrimination or harassment on the basis of race, color, veteran status, religion, national origin, ancestry, pregnancy status, gender, sex, age, marital status, disability, medical condition, sexual orientation, gender identity, or any other characteristics protected by applicable law. Suppliers must prohibit all forms of harassment, whether verbal, physical, visual or otherwise, on the part of all of their employees.  

A Diverse + Inclusive Workforce is Good Business 

Suppliers must be dedicated to fostering an inclusive culture and empowering employees and communities by embracing the dynamics of different backgrounds, experiences and perspectives. ADS Suppliers should be committed to creating an environment where employees feel valued, respected and fully engaged in contributing to the future success of their company. 

Human Rights 

ADS supports and respects all human rights and is not complicit, or directly or indirectly assist in violations. Suppliers must not benefit from human rights violations internally or through another company. Remaining silent on human rights violations takes the side of the oppressor, and ADS reserves the right to reevaluate its relationship with a Supplier if found to be in violation or complicit. 

Human Rights are Universal 

In support of the UN Global Compact, ADS is committed to respecting human rights as set forth in the Universal Declaration of Human Rights, as well as in accordance with the Guiding Principles on Business and Human Rights.  We expect Suppliers to meet these same commitments. 

No Participation in Unsanctioned Boycotts 

Suppliers must not participate in or cooperate with unsanctioned foreign boycotts prohibited or penalized by U.S. Antiboycott laws and regulations, including the Arab boycott of Israel.   

Anticorruption - Business Ethics 

ADS is committed to doing business with the utmost integrity and transparency. As an ethical company we hold ourselves to the highest of standards in conducting business, and as an ADS Supplier, you must do the same. We do not tolerate in any form, even where the cultural norm, corrupt behavior, including bribery and extortion. Bribery is an offer, promise, payment, gift, solicitation, or receipt of anything of value to persuade a person to do something which is dishonest or illegal, in the conduct of the Company’s business. Extortion can take many forms, but broadly defined, it is the solicitation of bribes accompanied by the threat of bodily harm.  

No Bribery or Corruption - No Improper Payments 

Suppliers must not, either directly or indirectly, improperly give or receive, or promise to give or receive, anything of value to any third party, such as foreign or domestic government officials in exchange for securing a business benefit.  Such corrupt payments may be considered bribes or kickbacks, and they are prohibited by law, including the U.S. Foreign Corrupt Practices Act and laws of other countries. Suppliers are also prohibited from making corrupt payments to commercial third parties such as agents, representatives, or business partners that do direct or indirect business with the Supplier. 

Compete Fairly and Legally 

Suppliers should compete in the marketplace in a fair and honest manner, gaining their competitive advantages through superior performance and execution, rather than through unethical or illegal practices. Suppliers are prohibited from making deliberate misrepresentations, or creating or assisting the creation of, any false or misleading records. 

Abide by International Trade Law + Sanctions 

Suppliers must follow applicable trade laws and control regulations, including sanctions and customs regulations to avoid transacting business with individuals and entities subject to restrictions or prohibitions. It is the Supplier’s responsibility to be aware of and comply with applicable trade embargoes and economic sanctions programs.   

Transparency of Books and Records 

Supplier books and records must be accurate regarding its business operations, and it should not make deliberate misrepresentations, falsifications or misleading entries related to ADS business. Supplier books and records should be transparent, and ADS may, at its own discretion, request documentation or conduct onsite audits to ensure transparency of its supply chain and compliance with the Code. 

References + Resources 

ADS Resources 

If you have any questions or concerns, or you would like to request hard copy versions of the Supplier Code of Conduct, please reach out to sustainability@adspipe.com. 

ADS Ethics Hotline – If you suspect any wrongdoing, ADS maintains an independent confidential whistleblower hotline that you may contact via phone (1- 888-234-4790) or online (https://ads-pipe.ethicspoint.com/). 

References 

• UN Global Compact 
• Foreign Corrupt Practices Act (FCPA) 
• UK Modern Slavery Act  
• Office of Antiboycott Compliance – Bureau of Industry and Security (BIS) 
• Office of Foreign Assets Control (OFAC) Sanctions List Search  

Revision #: 0
Issuance Date: 5/1/2023