Human Rights Policy

POOLCORP is committed to fostering a strong culture with a deep respect for individuals and for human rights. We acknowledge the basic freedoms inherent to all people, including access to clean water. We recognize our ability to impact the human rights of our employees, customers, workers in the supply chain, and the people in the communities in which we operate. Our commitment to protect and promote human rights is informed not only by our own values but also by the United Nations Universal Declaration of Human Rights and the United Nations Guiding Principles on Business and Human Rights. We expect individuals at all levels of our company, as well as our suppliers and vendors, to adhere to the guidelines in this policy and those set forth in our Code of Business Conduct and Ethics for our directors and employees and our Supplier Code of Conduct.

We value open communication and feedback, and we encourage our employees and stakeholders to report concerns regarding a possible violation of our Human Rights Policy to our Human Resources Department or our Legal Department. Employees can also anonymously report suspected policy violations through the third-party EthicsPoint helpline at www.ethicspoint.com or via the toll-free hotline at 1-866-384-4277. We review and address concerns, as appropriate, through a robust internal process. No reprisal or retaliatory action will be taken against any employee for a good faith report of questionable behavior and/or misconduct.

Implementation and Oversight

We require all full-time employees to complete an annual harassment prevention training and periodic ethics training. We also include diversity, equity, and inclusion training in our leadership and management trainings. Further, we encourage our employees to complete additional training that we provide on topics such as unconscious bias, the value of inclusion, and fostering a safe and positive work culture.

Our Board of Directors has overall oversight of risk, including policies and initiatives related to corporate social responsibility, which encompasses human rights and ethical business practices.

Diversity and Inclusion

We value and foster the diversity and inclusion of the people with whom we work, and we believe that everyone should have access to the same rights and opportunities, including historically underrepresented groups and women. We base employment decisions on merit, qualifications, experience, skills, and achievements.

We are committed to equal opportunity and will not tolerate discrimination or harassment of any kind, including that based on race, color, ethnicity, age, religion, sex, sexual orientation, gender identity or expression, marital status, medical condition, disability, military or veteran status, or any status protected by applicable law.

Child, Forced Labor, and Human Trafficking

POOLCORP prohibits all forms of child or forced labor, slavery, or human trafficking in any of its global operations and facilities. We do not tolerate the exploitation of children or the trafficking, physical punishment, abuse, or involuntary servitude of any worker. We prohibit the hiring of individuals that are under 18 years of age for positions in which hazardous work is required. We expect our suppliers and contractors with whom we do business to uphold the same standards.

Compensation

We compensate our employees in accordance with market practice in a manner that supports their ability to meet their basic needs. POOLCORP will pay wages that meet or exceed the legally required wages or, where no wage law exists, the local industry standard. We also offer our employees the opportunity to improve their skills and capabilities.

Working Hours

POOLCORP complies with applicable industry practices and local, state, and national laws regarding working hours.

Occupational Health & Safety

POOLCORP is committed to providing a safe environment for our employees. Our goal is to ensure that every employee goes home every night in the same condition in which they came to work. In addition to minimizing work-related injuries and illness, we strive to provide a safe and healthy work environment that supports employee morale and retention and enhances the quality of our products and services. We treat all applicable health and safety regulations as minimum standards, and we have dedicated safety programs to reduce or eliminate workplace hazards. Further, we believe that ongoing employee input and education is essential to identifying and solving health and safety issues in the workplace. We believe that all injuries and occupational illnesses, as well as safety and environmental incidents, are preventable.

Suppliers and Contractors

We acknowledge our responsibility to collaborate with vendors who share our values, and our team communicates regularly with our suppliers, conducting due diligence before and during our business relationship. We expect our suppliers to respect internationally recognized human rights standards, and we require that our manufacturers produce our products under conditions that demonstrate respect for the people who make them while respecting the rights of people living in the communities around their facilities. This policy operates in conjunction with our commitment to safety as our top operating priority, our regulatory compliance program, our Supplier Code of Conduct, and our endorsement of and commitment to these documents.