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Supply Chain Ethics Policy

Wayne Dalton, a division of 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. Wayne Dalton 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 Wayne Dalton expects suppliers to comply with the laws regarding slavery and human trafficking of the country or countries in which they do business.

Wayne Dalton 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. Wayne Dalton employees whose duties involve the Wayne Dalton supply chain will receive training on Wayne Dalton’s Code of Conduct, including standards related to prevention of slavery and human trafficking.

Wayne Dalton employees will conduct announced inspections and audits of suppliers’ places of business to ensure compliance with Wayne Dalton’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 Wayne Dalton’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 Wayne Dalton will follow up to ensure efforts are made to correct the violations. Wayne Dalton 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, Wayne Dalton will require all suppliers to certify that the products sold to Wayne Dalton 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.

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