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Overhead Door Corporation (and its divisions and subsidiaries, including GMI Holdings, Inc. d/b/a The Genie Company, collectively “Overhead Door”) strives to achieve and maintain high standards of corporate integrity and ethical behavior. Overhead Door expects that its suppliers will conduct their businesses not only in a lawful manner but also in compliance with the same high standards of integrity and ethics. Suppliers must not support, promote or engage in the practice of slavery or human trafficking, and Overhead Door expects suppliers to comply with the laws regarding slavery and human trafficking of the country or countries in which they do business.

Overhead Door is currently developing a supplier code of conduct and compliance manual (“Code of Conduct”), to be issued to suppliers, setting forth and highlighting important legal, ethical, behavioral and other requirements. Overhead Door employees whose duties involve the Overhead Door supply chain will receive training on Overhead Door’s Code of Conduct, including standards related to prevention of slavery and human trafficking.

Overhead Door employees will conduct announced inspections and audits of suppliers’ places of business to ensure compliance with Overhead Door’s Code of Conduct. These employees will be trained to recognize indicators of slave labor and human trafficking, and will be required to report and document any potential violations of Overhead Door’s Code of Conduct for further investigation. If a supplier is in violation of the Code of Conduct, the supplier will be required to promptly submit a corrective action plan, and Overhead Door will follow up to ensure efforts are made to correct the violations. Overhead Door will reserve the right to terminate any supplier found to be in violation of slavery and human trafficking laws.

In a further effort to confirm compliance with the Code of Conduct, Overhead Door will require all suppliers to certify that the products sold to Overhead Door comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business. Suppliers shall be required to ensure compliance with the same standards by any subcontractors and sub-suppliers involved in the incorporation of materials into suppliers’ products.