Supplier Conduct

OUR SUPPLIERS MUST BE COMMITTED TO THE HIGHEST STANDARDS OF INTEGRITY WHEN DEALING WITH NEXTIER

NexTier is committed to always conducting our business with the highest degree of integrity and in full compliance with applicable laws and regulations.  We are proud that this commitment extends to how we do business with our suppliers, and we expect all of our suppliers to share and embrace the letter and spirit of NexTier’s commitment to integrity.

Business Conduct and Ethics

We understand that our suppliers are independent commercial enterprises, but the business practices and actions of a supplier may significantly impact and/or reflect upon our Company, the NexTier brand and our reputation, all of which are invaluable assets.  We have worked hard to earn the trust of our stakeholders, and maintaining this trust and the highest reputation for integrity is essential to NexTier’s success.  Our Corporate Code of Business Conduct and Ethics (also known as the “Code of Conduct”) helps us to do this.  We expect our vendors to adhere to NexTier’s Code of Conduct while conducting business with and/or on behalf of NexTier.  Our suppliers must be committed to safe, lawful and ethical business practices to protect the welfare of those with whom we conduct business and those who are affected by our businesses.

MATERIALS SOURCING AND OUR COMMITMENT TO A CONFLICT-FREE SUPPLY CHAIN

We are committed to the responsible sourcing of materials, parts and products from our suppliers to ensure our procurement practices do not contribute to violence and human-rights abuses.  We expect our suppliers to share this commitment.

NexTier has adopted a Conflict Minerals Policy, which demonstrates our commitment to a conflict-free supply chain.  We have established a Conflict Minerals Compliance Program & Due Diligence Framework to ensure compliance with the Conflict Minerals Policy by all NexTier companies and divisions.

We require the cooperation and support of our suppliers to utilize validated, conflict-free sources of conflict minerals.  We expect our suppliers to: 1) source conflict minerals from certified conflict-free smelters (such as those audited through the Electronic Industry Citizenship Coalition and Global e-Sustainability Initiative Conflict Free Smelter program), 2) perform due diligence on the source and chain of custody of any conflict minerals sourced for and supplied to NexTier, and 3) provide evidence of their due-diligence measures to us upon request.

NexTier’s Conflict Minerals Policy can be found in the Related Resources area to the right.

SUPPLIERS THAT HAVE ANY LEGAL OR ETHICAL CONCERNS ABOUT OUR EMPLOYEES, OPERATIONS OR BUSINESS DEALINGS ARE ENCOURAGED TO USE THE NEXTIER REPORTING HOTLINE

We ask our suppliers to help us ensure that the employees of both our companies abide by the NexTier Code of Conduct and act lawfully and ethically in our mutual business dealings.  NexTier relies on our business partners and representatives to raise concerns about potentially illegal or otherwise improper business practices or conduct by any employee or other party conducting business for or on behalf of NexTier. We, in turn, pledge to take appropriate action in keeping with our commitment to doing the right thing, and there will be no retaliation for a concern raised in good faith. The Company maintains a confidential, anonymous hotline to report concerns regarding illegal or unethical misconduct, such as violations of the Company’s Code.  The hotline is available 24/7 by phone at 1-844-630-0090 or online at www.lighthouse-services.com/keanegrp.  You may also report concerns to the Office of Ethics and Compliance at 3990 Rogerdale Road, Houston Texas 77042, to the attention of our General Counsel.