The O.C. Tanner Approach to Environmental, Social, and Governance Factors

Here at O.C. Tanner, our mission is simple and clear: we help people everywhere thrive at work. To do that, we put ethics first. We care about humankind, equity, fairness, and our planet. And to live by these values, we hold ourselves and the companies we do business with to the highest possible sustainability expectations. Ultimately, we view it as our responsibility to make the world a better place.

We serve more than 13.5 million users in 180 countries around the world and delight our clients with the highest quality products and best customer service imaginable. Our clients can trust our capabilities to help them appreciate and recognize the great work of the people in their organizations.

Our Code of Conduct

Great companies are more than employers—they are responsible citizens. O.C. Tanner is committed to employing the most ethical and socially responsible supply chain in the recognition industry. This standard of excellence reaches beyond our walls, extending to our partners and suppliers.

As an organization, we’re committed to:

• Quality production
• Responsible sourcing practices
• Fair labor practices
• Diversity and inclusion
• Social responsibility
• Environmental stewardship
• Transparency and trust
• Giving back to the community

Our values never change, but our products, services, processes, and policies must continually evolve to keep pace with a world that demands it. We must maintain our position as a credible, responsible leader in the industry.

Our founder, Obert C. Tanner, always said he wanted his company to “touch the fringes of perfection.”

Today, O.C. Tanner, the company, continues to reach for that benchmark. We strive toward perfection in all business areas, whether building a recognition solution for a client or purchasing materials from a vendor. We produce quality, and we demand it.

Supplier Standards

Through rigorous employee training, thorough process documentation, and a systematic approach that applies continuous improvement practices and principles company-wide, we build partnerships with suppliers to create a more transparent, responsible supply chain. We expect our partners and suppliers to commit to these same high-quality standards and agree to the following quality initiatives:

Value alignment: A potential supplier must submit an evaluation survey before establishing a relationship with O.C. Tanner. The survey includes questions about the suppliers’ environmental and social initiatives, quality standards, warranty expectations, anticipated delivery timetables, and stock requirements.

Supplier reviews: Once a partnership is established, a scorecard is run on all suppliers at a frequency based on dollar spend. The scorecard evaluates lead time, inventory turnover, quality, on-time delivery, and performance. If a supplier fails to meet standards, we work with them to clearly define a corrective action plan to meet expectations before we terminate the relationship.

Quality control: O.C. Tanner diligently resolves quality-related issues across the supply chain. We track vendor-related quality issues daily. Purchasing managers also meet as needed to discuss improvements and resolutions reached with suppliers. Product audits are conducted and resolved on a case-by-case basis to determine product disposition and resolve quality-related issues.

Lean methodology: O.C. Tanner strives to adopt Lean manufacturing techniques throughout our entire company and collaborates with our people to bring new ways of thinking and operating to the table. As we continue to improve, we also encourage our suppliers to adopt continuous improvement techniques and processes.

Supplier Auditing Program

Our audit program ensures quality. For example, a third-party auditor conducts audits on direct suppliers from China to determine if an O.C. Tanner supplier follows our social and environmental standards and our customs, trade, and import standards. Our suppliers must also comply with standards regarding security around their factories, at shipping docks, and when transporting materials.

Audits are announced and scheduled so that we can build trust and long-term relationships with our supplier partners. At its core, our audit program helps ensure that our suppliers are in the business of valuing and appreciating their people.

When a supplier violates O.C. Tanner’s Quality, Environmental, and Social Standards, we will work with factory representatives or intermediaries to resolve the problem. If a supplier fails an audit, a secondary third-party audit will occur within six months of the initial review. Consultation calls and specific requirements from O.C. Tanner management may become a part of the resolution process.

Compliance issues will be resolved on a case-by-case basis as they arise. If the supplier does not meet the requirements within the allotted period, the relationship with that supplier will be terminated. Suppliers are reviewed annually, and audits are performed by the 2nd quarter of the following year.

We hold a high standard for ourselves—and for every supplier

O.C. Tanner takes pride in our reputation and doing right by clients, vendors and suppliers. We’re conscious not only of what we buy, but also how those goods are produced. This responsibility is fundamental to our continued success, and we will not do business with any supplier or partner that cannot meet our quality, social, and environmental guidelines:

• Any violation of a child labor law is not tolerated.
• Suppliers must abide by minimum wage, time, and overtime laws established in their respective countries. Working conditions and equality standards must meet guidelines set by local government authorities. These standards include discrimination in hiring, remuneration, access to training, promotion, termination, or retirement based on race, caste, national origin, religion, disability, gender, sexual orientation, union membership, political affiliation, or age.
• Companies must not engage in or support the use of corporal punishment, mental/physical coercion, or verbal abuse.
• O.C. Tanner will not purchase or sell conflict diamonds and carefully monitors all diamond acquisitions. Our diamond suppliers must comply with all international requirements. In addition, they are required to provide written certification and warranties with each shipment that the diamonds they provide to us are “conflict-free.”
• O.C. Tanner operates in compliance with the Dodd-Frank Wall Street Reform and Consumer Protection Act that regulates the purchase and use of “conflict minerals.” Dodd-Frank Section 1502 defines “conflict minerals” as cassiterite, columbite-tantalite, gold, and wolframite, their derivatives, and other minerals the U.S. Secretary of State designates in the future. O.C. Tanner only purchases “conflict minerals” from suppliers that have certified that they also operate in compliance with Dodd-Frank Wall Street Reform and Consumer Protection Act. O.C. Tanner keeps certification documents on file from all suppliers that provide O.C. Tanner with “conflict minerals” used in our manufacturing processes.

Our Social Responsibility

Obert C. Tanner believed business was all about creating jobs, and life was all about beauty. He wanted to create a space for people to thrive and extend that feeling to every supplier we work with and employees we help recognize. That vision continues today, and we’re committed to fostering an environment where every employee can build a meaningful career and be their best self.

We value soul over skill sets

We believe work is not a transaction—O.C. Tanner is a place to connect and grow. We expect employees to be stellar corporate citizens and model the utmost respect and demeanor with each other, our guests, and our clients. We approach every person, task, and partnership with integrity, which creates a ripple effect that extends into a virtuous cycle through our homes and communities.

Diversity is about more than culture—it’s critical to success

O.C. Tanner recognizes and values individual differences and believes that different perspectives lend vitality, creativity, new ideas, and growth to our business. We’re committed to creating an environment that appreciates and values those differences. Our diverse staff represents 62 countries and 64 different languages. We partner with employees, their families, and the local community to improve quality of life. O.C. Tanner employees enjoy freedom of association, safe working conditions, and competitive wages.

Our employees have a history of resilience

O.C. Tanner is committed to supporting refugee communities through education and employment opportunities in partnership with One Refugee. Through the One Refugee Education Initiative and the One Refugee Careers Initiative, One Refugee provides a holistic experience to help refugees in our home state, Utah, from the beginning of their higher education journey to successfully landing a valued position at a good company. The program matches refugees with potential employers from a network of organizations across the state and in several industries.

We believe in equitable opportunity for all

Equal opportunities are key in the execution of O.C. Tanner’s social standards. We are committed to partnering with Minority and Women-Owned Business Enterprise (MWBE) companies and work to utilize them in all areas of procurement.

We pair high standards with cultural sensitivity

O.C. Tanner expects suppliers to behave ethically and with sensitivity toward social, cultural, economic, and environmental issues. We foster long-term relationships with like-minded companies that positively impact society and make a positive contribution to bottom-line results. We work with our suppliers to address social responsibility while respecting cultural and legal differences in other economies.

Our sense of fairness runs deep

O.C. Tanner applies fair standards to all manufacturers, vendors, and suppliers. We expect partners of finished goods to maintain fundamental labor and human rights standards. We have a zero-tolerance policy towards modern slavery. As a manufacturer of finished goods, O.C. Tanner operates in compliance with the California Transparency in Supply Chains Act of 2010, or S.B. 657. It requires our supply chain to refrain from the direct or indirect use of forced labor or any form of human trafficking. By agreeing to a statement in the O.C. Tanner Supplier Set-up Survey, all new suppliers agree to operate in compliance with S.B. 657 and the Modern Slavery Act of 2015.

Our Environmental Stewardship

O.C. Tanner’s environmental philosophy is that growth and opportunity are possible, but not at the expense of the environment. We aim to be responsible, global corporate citizens and comply with all applicable environmental governing requirements.

The environmental pillar of sustainability is rooted in environmental stewardship, which includes voluntary reporting and actions beyond applicable governing requirements. For example, O.C. Tanner completes the Carbon Disclosure Project (CDP) Climate Change questionnaire annually and EcoVadis questionnaire at least annually. One of the two 2023 CDP scores received improved by one-half letter grade while the other remained the same. The EcoVadis score improved by 6.82% from 2023 to 2024 and the official scorecard may be requested through the EcoVadis platform.

Environmental Targets

O.C. Tanner has two continuous targets for environmental compliance: zero violations or citations, especially as recorded in EPA’s ECHO database, and full compliance with current environmental permit(s).

There are two environmental sustainability targets shown in the table below. As part of our commitment to continuous improvement, voluntary emissions reporting has expanded to include global operations beginning for reporting year 2023. Target 2: Water Use only includes O.C. Tanner locations in the United States at present but is planned to expand globally in 2025.

Emission and water use reduction take place mainly through efficiency improvements and equipment replacement/upgrade. Examples include upgrades for ventilation scrubbing system, light system motion sensors, HVAC equipment, air compressors, and water heaters.

Environmental Life Cycle Considerations for Materials and Products

Upstream environmental considerations:

• Materials purchased for manufactured products like wood, paper, acrylic, and minerals/metals may be considered by source, geographic location (transportation), environmental certification, and/or end-of-life recyclability and reusability.
• The paper supplier for in-house printed awards, stickers, and custom packaging inserts is FSC certified.
• Our largest wood supplier sources domestic (United States) hardwood only from mills that are NHLA members.
• Our Domestic Supplier Assessment (United States-based) now includes questions regarding environmental practices/reporting, as added in mid-2023.

Operational environmental considerations:

• Precious metal scrap (especially gold) is currently recovered on site, refined, and reused in product.
• Batteries, paper, wood pallets and manufacturing scrap, larger pieces of acrylic, electronic waste, organic waste, and plastics 1 and 2 are all reused or recycled from one or more O.C. Tanner facilities.
• In July 2024, a new single stream recycling training rolled out to approximately 1,100 O.C. Tanner headquarter and main campus employees in the United States.
• Materials during sourcing are also considered for environmental regulatory and/or permit impact(s) for O.C. Tanner’s direct operations.

Downstream environmental considerations for customers:

• Our United Kingdom and European catalog has a sustainable merchandise section customers may select from within certain geographic areas, which accounts for about 33% of that catalog.
• The United States catalog has an “Eco Friendly” section featuring items which can be used multiple times, items made of recycled material, or giving to environmental causes.
• Approximately 70% by weight of outer packaging, shipping containers, and inserts used globally for O.C. Tanner manufactured products are recyclable. By the end of 2025, O.C. Tanner will use 100% recyclable packaging for in-house manufactured items. Twice the count of the 100% recyclable packaging will be able to fit in the same size transport container as current due to redesign, which will lessen transportation emissions.
• O.C. Tanner requests customers and end-users handle waste in a legal and responsible manner. We highly encourage recycling or reuse of end-of-life products.

Risk Management & Data Protection

O.C. Tanner built our business on transparency and trust. The personal data of O.C. Tanner clients and their recipients must never be compromised. We use all recipient information exclusively for the management of our client programs, and the delivery of awards and merchandise to the employee recipient.

O.C. Tanner’s data protection & privacy standards.

• No recipient data retained for marketing purposes.
• No recipient data retained or sold for third-party marketing purposes.
• No recipient data collected or retained for “upselling” or upgrading awards or merchandise.

Vendor classification

O.C. Tanner classifies vendors who receive transactional customer and corporate data for order fulfillment purposes such as printing, shipping, and drop-shipping as Tier III vendors. The Information Security and Compliance team is responsible for vetting all vendors to verify that they provide adequate levels of data protection. This vetting process is done using the SSAE 18/ISAE 3402/ISO/IEC 27001 publication or other applicable industry standards as a framework for auditing information security management systems.

Evaluations & Assessments

Before onboarding a vendor, the parties responsible for introducing the vendor into our environment are required to have the O.C. Tanner Information Security team assess the risks the vendor may potentially introduce into our business environment. The Information Security team vets all vendors to verify that they provide adequate levels of data protection. This vetting is done using applicable industry standard frameworks for auditing information security management systems. Where practical, the team conducts an onsite review. If an onsite review is not feasible, the review is performed via video conferencing or phone, if needed. Findings from the vetting process are addressed on a case-by-case basis depending on the nature of the risks posed.

Tier III vendors that may receive limited transactional client data from O.C. Tanner are reassessed at least every three years, while Tier I and II infrastructure and technology service providers are reassessed annually. The evaluation determines ongoing compliance and whether the vendors are correctly categorized.

Due diligence

O.C. Tanner utilizes a survey to meet the due diligence required to ensure ongoing compliance no less than every three years, and annually for Tier I and II vendors. If the controls or responses to the questions have not changed, we may accept an attestation from the vendor certifying their compliance with these controls along with updated and required supporting documentation.

Economic Impact

We hold ourselves to the highest standards of economic justice. Fair pay practices, charitable giving, and economic opportunities are critical as we work to ensure everyone we work with has access to a better financial future. O.C. Tanner requires fair wage practices from all suppliers and partners. We hold ourselves to high standards of economic stability for our employees.

Charitable giving

Our founder measured the company’s success by asking his accountant, “What’s our give-ability this month?” His intention echoes in our hearts and halls today. It’s why we donate our time to organizations in need and make an effort to improve our communities, in all our global locations, and give 10% of company profits to philanthropic causes.

O.C. Tanner’s charitable strategy is to support the environment, arts, education, children, and organizations meaningful to our employees—all things that are important to the organization and what we stand for.

O.C. Tanner has also established a way for us to care for our own people in times of personal crisis. The Tanner Cares fund, established in 2011, offers financial support to O.C. Tanner employees in times of extreme need. For every dollar employees donate to the United Way or Utah Food Banks, O.C. Tanner matches that dollar twice—once to the United Way/Utah Food Banks and once into our own Tanner Cares employee crisis fund. It’s our way of making sure we stand shoulder to shoulder, heart to heart, when it matters most.

True to our purpose. To our people. To our planet.

Our people are our heart and soul—and our values prove it. We are united toward the same goals and committed to helping each other thrive—on good days and bad days. We know that our business succeeds when our employees succeed.

We extend this sense of caring to our vendors and suppliers, and when we do, we create a shared sense of responsibility. We treat everyone fairly and operate with honesty and integrity in all our dealings—from our largest customers to our smallest suppliers.

When we come together with our valued partners and suppliers, we can build something beautiful: more ethical workplaces, more fair labor standards, and a better world.

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Please reach out to your O.C. Tanner representative or contact info@octanner.com with questions.