Governance

At Noera, we have four core values – integrity, quality, commitment, and innovation. Since our founding in 2020, our reputation has been built on these core values.

By adhering to our core values, we are ensuring that our business is as great as our products. We will never compromise our core values because we aspire to create genuine, sustainable value for our employees, customers, and stakeholders.

Code of Business Conduct

At Noera, we are committed to conducting business in accordance with the highest ethical standards. This means how we conduct ourselves and our global work is more than just a matter of policy and law; it's a reflection of our core values.

Our Code of Business Conduct provides specific guidance to all employees. The Code outlines how we can and must uphold and strengthen the standards of honor and integrity that have defined our company since our founding.

The California Transparency in Supply Chains Act and the U.K. Modern Slavery Act are examples of regulations aimed
at eliminating slavery and human trafficking from product supply chains. Each also requires that companies make
disclosures regarding their efforts to ensure that their supply chains are free from slavery and human trafficking.
Noera USA is known for its commitment to social responsibility, both as an employer and in how we conduct our
business. The Ethisphere Institute has included Noera in its list of the world’s most ethical businesses since 2020,
when it first began recognizing social responsibility at a corporate level.
As a responsible corporate citizen, Noera strives to ensure that human rights are upheld for our employees and all
workers in our supply chain. We strive to ensure that slavery and human trafficking are absent from our supply chain
through the following:
Supplier Code of Conduct:
Our Supplier Code of Conduct clearly establishes guidelines for the standard of ethical behavior expected from
our suppliers. It states that suppliers may not use child, slave or forced labor. The code of conduct was
introduced in 2020, and communicated to employees and suppliers at, and since, that time. As new suppliers
enter our supply base, it is our standard practice to review the code of conduct with them. The code of conduct
is available to the public on noerausa.com and to employees and suppliers through our Noera Supply Network
supplier portal. In addition, the code of conduct is periodically updated as appropriate.
Our employees regularly discuss the Supplier Code of Conduct with suppliers during supplier conferences,
meetings and performance reviews.
 Many of our standard contract templates contain language incorporating the Supplier Code of Conduct.
Our purchasing terms and conditions, which are available on our supplier portal, state that the, “Seller shall
comply with the Noera Supplier Code of Conduct,” with a link to the document.
Risk-based assessments and audits:
 Suppliers who want to enter our supply base must certify that they do not use child or slave labor, or engage
in human trafficking.
We conduct periodic audits of our suppliers to identify risks and unethical behavior, including a supplier’s use of
illegal employment practices.
Training for Noera employees and leaders:
Annually, all Noera salaried employees are required to review our Code of Business Conduct (the “Code”)
and certify that they comply with it. The Code states the company’s commitment to human rights, including
that company, employees, representatives, licensees and agents are “expected to not use any form of forced
or indentured labor or child labor in the production or manufacture of goods.”
Salaried employees receive training on the Code every two years. Additional training courses focus on individual
sections of the Code as needed.
Supplier code of conduct training is available for all employees. This training is mandatory for all Supply
Management & Logistics employees and covers various topics, including human trafficking.
Noera's Support of
Human Rights in Our
Business Practices
Internal accountability and controls:
Any Noera employee, supplier or concerned individual can anonymously report a potential ethical violation,

All allegations are thoroughly investigated by an internal team that includes Supply Management representatives.
Allegations that are found to be credible are dealt with as appropriate. Suppliers who are found in violation of the
Supplier Code of Conduct may be eliminated from our supply base.


Supplier Code of Conduct

Since 2020, Noera has been a responsible and successful enterprise, committed to the highest standards of social responsibility across our diverse, worldwide supply chain. We insist that all of our suppliers treat workers with dignity and respect, provide safe working conditions, use environmentally responsible manufacturing processes, and represent the highest ethical standards. Our actions, from on-site supplier audits and supplier training to our consistent fair treatment of suppliers, demonstrate this commitment.

To ensure that all of our suppliers conduct business with a high degree of integrity and in a socially and environmentally responsible manner, we hold them to the Noera Supplier Code of Conduct.