GLOBAL SUPPLIER CODE OF CONDUCT

Purpose and Scope
At Covetrus, Inc. (“Covetrus” or the “Company), we believe acting ethically and responsibly is best for our business and our business partners.

Covetrus has developed this Global Supplier Code of Conduct (“Supplier Code”) to clarify our expectations in the areas of business integrity, labor practices, employee health and safety and environmental management. This Supplier Code is intended to complement Covetrus’ Code of Business Conduct & Ethics (available under the Legal section of our website at www.covetrus.com) and Covetrus’ other policies and standards referenced therein.

Suppliers, vendors, and other providers of goods and services who do business with Covetrus entities globally (“Suppliers”) are expected to follow this Supplier Code.

Business Conduct Principles
Covetrus expects its Suppliers to conduct business responsibly, with integrity, honesty and to adhere to our values and the following principles:

  1. Maintain awareness of, and comply with, all applicable laws and regulations.
    Suppliers shall maintain awareness of, and comply with, all applicable laws and regulations. Suppliers providing pharmaceutical products, ingredients, or related services to Covetrus must comply with all applicable laws and regulations, including pharmaceutical and animal health laws. They must maintain and provide, as requested, necessary licenses, registrations, and permits, ensure accurate and compliant product labeling and marketing, and adhere to DEA and DSCSA requirements (U.S.-sourced suppliers). Suppliers must have systems to detect and handle suspect products and promptly report any regulatory non-compliance to Covetrus.
  2. Compete fairly for business, without paying bribes, kickbacks or giving anything of value to secure an improper advantage.
    Covetrus is committed to conducting business legally and ethically within the framework of a free enterprise system. Corrupt arrangements with customers, suppliers, government officials, or other third parties are strictly prohibited. “Corruption” generally refers to obtaining, or attempting to obtain, a personal benefit or business advantage (for oneself or third parties) through dishonest or illegal means.
  3. Provide a workplace free from discrimination, harassment, or any other form of abuse.
    Suppliers shall create a work environment that is free from harassment, including unwelcome verbal, visual, physical or other conduct of any kind that creates an intimidating, offensive, or hostile work environment. Suppliers shall not discriminate in employment, including with regard to hiring, compensation, advancement, discipline, termination and retirement, in violation of the laws and regulations, including on the basis of alienage or citizenship, age, color, creed, disability, gender identity, genetic characteristics, marital status, domestic violence victim status, conviction record, military status, national origin, pregnancy, childbirth-and pregnancy-related medical conditions, race, religion, sex/gender, sexual orientation, veteran or other protected status.
  4. Treat employees fairly, including with respect to wages, working hours, and benefits.
    Suppliers shall comply with all applicable laws and regulations and will generally apply sound employee relations practices. Working hours, wages and benefits will be consistent with laws and industry standards, including those pertaining to minimum wages, overtime, other elements of compensation, and legally mandated benefits.
  5. Prohibit all forms of forced or compulsory labor.
    Suppliers shall maintain and promote fundamental human rights. Employment decisions will be based on free choice and may not involve forced or prison labor, physical punishment or threats of violence or other forms of physical, sexual, psychological or verbal abuse as a method of discipline or control. Compliance with the Uyghur Forced Labor Prevention Act (UFLPA) is mandatory and suppliers may not source materials shall from the Xinjiang Uyghur Autonomous Region (XUAR) of the People’s Republic of China or other regions prohibited by US or International Law.
  6. Prohibit use of Child Labor.
    Suppliers shall adhere to the minimum employment age limit defined by applicable laws or regulations and comply with applicable International Labor Organization standards. In no instance shall a Supplier permit children to perform work that exposes them to undue physical risks that can harm physical, mental or emotional development or improperly interfere with their schooling needs.
  7. Import/Export Laws.
    Suppliers shall comply with all applicable trade laws of the countries where they conduct business, and countries in which they engage with Covetrus and its entities. This includes, but is not limited to, timely provision of all information necessary to comply with the import requirements of the destination country; and not exporting or re-exporting any information or products received from Covetrus and its entities to any prohibited or sanctioned countries. Suppliers must ensure that all product markings and documentation are true and accurate, and that appropriate records are maintained to validate the information provided on all documents.
  8. Respect employees’ right to freedom of association and collective bargaining, consistent with applicable laws and regulations.
    Consistent with applicable laws and regulations, Suppliers shall respect employees’ rights to join or refrain from joining associations and worker organizations. Supplier will permit workers to openly communicate and share grievances with management about working conditions and management practices without fear of reprisal, intimidation or harassment.
  9. Provide safe and healthy working conditions.
    Suppliers shall proactively manage health and safety risks to minimize occupational injuries and illnesses. Suppliers must implement management systems and controls that identify hazards and assess and control risk related to their specific industry. Suppliers shall maintain records of work-related accidents, injuries or sicknesses, and corrective actions.
  10. Carry out operations with care for the environment and comply with all applicable environmental laws and regulations.
    When making business decisions, Suppliers are to consider the potential environmental impact of their activities along with opportunities for conservation of natural resources, recycling, source reduction, and pollution control to ensure cleaner air and water, and to reduce landfill wastes.
  11. Conflict Minerals.
    Suppliers are expected to ensure that products supplied to Covetrus do not contain metals derived from minerals(or their derivatives originated from) conflict regionsthat directly or indirectly finance or benefit armed groups (including from the Democratic Republic of the Congo or an adjoining country).
  12. Maintain accurate financial books and business records.
    Suppliers shall maintain accurate financial books and business records in accordance with all applicable laws and regulations and accepted accounting practices.
  13. Deliver products and services meeting applicable quality and safety standards.
    Suppliers shall have adequate controls in place to ensure the integrity, quality and safety of their products and services provided by Supplier to Covetrus.
  14. Support compliance with this Supplier Code by establishing appropriate management processes and cooperating with reasonable assessment processes requested by Covetrus.
    Suppliers shall establish appropriate management processes and maintain records to comply with this Supplier Code. With prior notice, Covetrus may conduct reasonable audits to verify the Supplier’s compliance with this Supplier Code.
  15. Observe Covetrus’ policies regarding gifts and entertainment and conflicts of interest when dealing with Covetrus employees.
    Suppliers are prohibited from providing or offering gifts to Covetrus employees that could inappropriately influence Covetrus’ business decisions or gain an unfair advantage. This includes, but is not limited to, meals, travel, entertainment, donations, or anything else of value that could be perceived as an improper inducement. Suppliers must not offer or give anything of value to Covetrus employees, their family members, or guests in exchange for favorable treatment or to influence a business decision. All interactions must be transparent, lawful, and aligned with Covetrus’ commitment to ethical business practices. Covetrus reserves the right to require suppliers to complete anti-bribery training or certifications and to conduct due diligence to ensure compliance with these standards.
  16. Report suspected violations of this Supplier Code.
    Suppliers’ employees or agents may report suspected violations of this Supplier Code to the Covetrus
    IntegrityCounts Hotline, which is available worldwide, 24 hours a day, 7 days a week by telephone at 1-866- 921-6714 (toll-free in the United States; additional country-specific telephone numbers are available online), by email at covetrus@integritycounts.ca, or online at https://www.integritycounts.ca/org/covetrus. All such reports are treated as confidential, where permitted by law, and the reporter may remain anonymous, where permitted by law. We note that anonymous reports or calls may be more difficult to investigate.

COMP.275.0.EN
Global Supplier Code of Conduct
Effective Feb. 7, 2019
Last Rev. Jun. 26, 2025