WE REQUIRE SUPPLIERS TO ADHERE TO HIGH STANDARDS

Supplier Code Of Conduct Statement

Banc of California is committed to sourcing products and services from third-party providers who respect human rights ethics and have responsible policies and practices wherever possible.

PURPOSE

This Supplier Code of Conduct (Code) sets out the minimum principles that we expect You to follow while providing products or services to Banc of California, Inc., Banc of California (together with Banc of California, Inc., the “Company”), to any of our affiliates or on behalf of the Company to our customers. You or Your means a supplier, whether as an individual or as a company, including the supplier’s officers, directors, employees, contractors or subcontractors. You and Your team engaged in providing products and services are expected to read, understand and act in accordance with this Code.

The Company is committed, wherever possible, to source products and services from suppliers who respect human rights ethics and have responsible policies and practices. The Company expects You to conduct operations in accordance with this Code and to enact and enforce policies and practices in support of these principles. The Company reserves the right to screen and to carry out assessments of the practices of our suppliers to ensure alignment with this Code. This may include a self-assessment by You or a request for additional information or site visits. If You violate this Code, the Company shall have the right to require You to complete a corrective action plan until a satisfactory level of improvement is reached, or the Company will have the right to terminate its relationship with You immediately at the Service Agreement or schedule level.

SECTION 1: REQUIREMENTS FOR DOING BUSINESS WITH THE COMPANY

Gifts
The Company does not condone acts that would or could be perceived as influencing actions or to gain an advantage with the Company. You should not give or offer anything of value to employees; Company employees are prohibited from soliciting or encouraging gifts from You.

Gifts from You for the benefit of those associated with the Company are permitted only under the following limited circumstances:
- Gifts based on a family relationship or gifts of a reasonable value based on a personal relationship where that relationship is the obvious motivating factor for the gift
- Advertising or promotional material with a value of less than $100
- Gifts with a value of less than $100 related to commonly recognized events such as a promotion,
  religious holiday, wedding or retirement
- Offering customary hospitality (business luncheons, dinners, golf outings, ball games, etc.) where it is directly related to business activities and provided that the expense would be paid for by the Company if not paid for by another party. Any entertainment beyond that scope or of a frequent nature (more than twice a year by the same party) must be pre-authorized by the General Counsel of the Company
- Discounts or rebates on merchandise or services that do not exceed those available to other
  customers of Yours
- Awards for recognition of service or accomplishment from civic, charitable, educational or religious organizations
Cash, gift cards, lines of credit, instruments of ownership (e.g., stock certificates) or any other thing of value redeemable for cash are never permissible as a gift.
Conflicts of Interest
You must exercise reasonable care and diligence to prevent any actions or conditions that could result in a conflict of interest. If a conflict of interest exists, You must notify your Company business contact. A “conflict” means any situation where Your interests may conflict, or be perceived to conflict, with the interests of the Company.
Political Activities and Lobbying
You will not make any political contributions or present any gifts in the name of the Company to any candidate for public office or elected officials, and You will ensure that any recipient of Your own political contributions (including any affiliated political action committees) does not represent an endorsement from the Company. Unless given prior written approval, You may not undertake activities on the Company’s behalf that would require registration as alobbyist.

SECTION 2: YOUR COMMITMENTS TO COMPANY AND THIRD PARTIES

Privacy; Confidential Information
To protect the Company’s confidential information, You shall use the same care and precaution as You would in protecting Your own highly confidential, proprietary information and trade secrets, and no less than a reasonable standard of care. It is the policy of the Company that You adhere to all appropriate privacy, information security, and data security laws and regulations and ensure customer information is held in the strictest confidence in compliance with such laws and regulations.
Honesty, Fair Dealing and Bribery, and Anti-Corruption
You will always endeavor to deal fairly, in good faith and in a nondiscriminatory manner with Company customers, suppliers, competitors, business partners, regulators and employees. You are not to make any facilitation payments to influence or to obtain any advantage for the Company.

The Company does not tolerate bribery or corruption in any form. You will comply with all anti-money laundering, anti-bribery and anti-corruption laws. You will not give or offer anything of value to anyone, whether a government official or corporate representative, to influence actions or to obtain an improper advantage for the Company, itself or any third party.
Compensation, Working Hours and Conditions
You are required to comply with all applicable wage and hour labor laws and regulations governing employee compensation, reimbursements, taxes and working hours, including all laws that address child labor, forced labor, slavery, and human trafficking.
Health and Safety
You are required to provide a nonviolent and safe work environment, free of threats, intimidation and physical harm, which also supports accident prevention and minimizes exposure to health risks. You are required to comply with all applicable occupational safety and health laws and regulations in the jurisdictions in which you operate.
Discrimination and Diversity
You are required to comply with all applicable laws concerning discrimination in hiring and employment practices, including equal pay and nondiscrimination. The Company encourages you to provide an inclusive and supportive working environment, free of harassment and discrimination, in which all employees are valued and empowered to succeed (including the use of minority-owned and other diverse businesses).

The Company has a Supplier Diversity Policy. Any representations you make to the Company related to your status as a “diverse supplier” must be accurate and truthful, and you agree to inform us if that status changes at any time.

SECTION 3: YOUR OBLIGATIONS USING SOCIAL MEDIA (External and Internal)

For the purposes of the Code, social media is defined as interactive online communications in which users can generate and share content through text, images, audio, video and/or other multimedia and technologies accessed through any technological platform (such as desktop computer, laptop, smartphone and tablet) that enable social interaction.

You must not publicly communicate anything related to the Company’s business or speak to the press or any media outlet about Company without Company’s specific prior written authorization. You may not make any public announcements about your provision of goods or services to the Company. Use of the Company or affiliates’ names or trademarks in connection with any advertising or promotional materials or activities, in a website, in a press release, on social media or in other written communications, or services, materials or products provided to other third parties is strictly forbidden, unless specifically authorized in the Service Agreement.

SECTION 4: RAISING CONCERNS OR REPORTING QUESTIONABLE BEHAVIOR

To report questionable behavior or a possible violation of this Code, you are encouraged to work with your primary contact at Company in resolving the concern. If that is not possible or appropriate, please send an email to Procurement@bancofcal.com.