Supplier Code of Conduct

Last updated: September 2023

Apex Clean Energy Holdings, LLC (“Apex”) is a renewable energy company working to accelerate the shift to clean energy by developing, building, and operating clean energy facilities across the United States.

We seek to ensure that our suppliers comply with all applicable laws and regulations governing their business activities and are conducting their work on Apex’s behalf in accordance with our Environmental, Social, and Governance (ESG) principles. Apex’s Supplier Code of Conduct documents the company’s expectations and requirements in relation to these. This Code of Conduct will be updated once per year to ensure that Apex is taking all appropriate action to conduct its business in a manner consistent with its values and evolving ESG goals.

Apex Core Values

At Apex, our core values are the foundation upon which we operate and drive our commitment to accelerate the shift to clean energy. Entrepreneurship, safety, professionalism, integrity, and sustainability are the guiding principles that shape our everyday decisions, actions, and partnerships.


We are fueled by the spirit of entrepreneurship, constantly seeking innovative ways to advance renewable energy solutions. We believe in the power of creative thinking and adaptability to overcome challenges and seize opportunities in the dynamic clean energy landscape. Our commitment to entrepreneurship is evident in our approach to our core business and in our team’s passion, initiative, and empowered decision making.


Safety is paramount in everything we do. We recognize that a healthy and safe work environment is essential for our employees, partners, and communities. Apex employs a proactive, collaborative approach to prioritizing safety in every initiative; we refuse to wait for incidents to happen. We extend our safety commitment to our suppliers, insisting that they uphold our standards to ensure that every member of the Apex team returns home safely each day.


Professionalism is at the core of our interactions with all stakeholders. We hold ourselves to the highest ethical standards, emphasizing transparency and accountability in all our endeavors. Our commitment to professionalism extends to our suppliers and business partners, whom we expect to adhere to the same principles, ensuring that our collective actions reflect the integrity of our industry.


Integrity is the bedrock of our corporate governance and business ethics. We maintain unwavering integrity in our dealings with employees, customers, and investors. This commitment extends to our suppliers, whom we require to comply with all applicable laws and regulations. Our belief in transparency and ethical conduct extends throughout our supply chain, promoting trust and accountability.


Sustainability is not just a goal; it is our responsibility. We seek solutions that transcend our business model to lower our individual and collective environmental footprints. Our commitment to sustainability is evident in the way we site, construct, and operate our facilities, striving to minimize our impact and contribute positively to the communities where we operate. We expect our suppliers to share this commitment by reducing their environmental footprint, promoting resource efficiency, and protecting natural habitats and biodiversity.

Corporate Governance and Business Ethics

Integrity and accountability are core tenets of how Apex conducts business, and we seek to ensure that the highest ethical standards are also met by Apex’s suppliers and business partners.

Apex Corporate Governance and Business Ethics Requirements

Apex requires each supplier, as applicable, to:

  • Comply with the laws of the applicable legal system(s) in which such supplier works or provides goods and services
  • Maintain policies and procedures designed to ensure compliance by supplier and its officers, employees, and agents with the FCPA or the UK Bribery Act 2010
  • Notify Apex as soon as it becomes aware of any breach of applicable law

Employee Experience and Safety

Apex believes that operating in a healthy and safe work environment is key to its success as a company. Apex has established processes to identify physical, health, chemical, and environmental hazards that may be faced in the workplace; this includes a review of accident and incident reports and findings, near misses, and input from its employees. The information from this risk evaluation is then used to inform plant-specific safety programs, with iterative risk evaluations being used to further refine and supplement them.

Aside from reducing on-the-job injuries and illnesses and complying with regulatory standards, it is Apex’s belief that interactions developed through these safety programs also bring collateral benefits in the form of improved communication, documentation, and cost savings. Apex’s proactive health and safety programs enhance facilities by identifying and evaluating site-specific hazards and establishing proper controls for all work.
We believe that the success of this safety program is not dependent on our company alone, but requires participation from everyone with whom we associate. As such, Apex will ensure that all contractors are vetted by a third party for safety programs, incident history, and conformance to Apex’s standard for safety. Apex will also track incidents, near misses, safety observations, and training events for all contractors on Apex construction and operating sites.

Apex Employee Experience and Safety Requirements

Apex requires each supplier, as applicable, to:

  • Cooperate with the vetting process for safety programs, incident history, and conformance to Apex’s standard for safety
  • Provide information on incidents, near misses, safety observations, and training events to Apex

Environmental Protection

Apex is committed to fighting climate change and working toward environmental sustainability in all of our activities. Our goal in siting, constructing, and operating our facilities is to avoid and minimize environmental impacts and benefit the communities where our projects are located.

Apex expects suppliers to work to reduce their environmental impacts through resource and energy efficiency, sustainable sourcing, waste minimization and diversion, and protection of natural habitats and biodiversity. Apex expects suppliers to work to minimize adverse effects on the natural community while safeguarding the health and safety of the public.

Environmental Protection Requirements

Apex requires each supplier, as applicable, to:

  • Comply with all environmental laws, regulations, standards, policies, and reporting requirements
  • Maintain environmental-related documentation, including permits, licenses, emissions certificates, safe disposal certificates and other records, to the extent required by law
  • Respond to requests for data to support Apex’s environmental reporting obligations
  • Notify Apex if it becomes aware of any environmental accidents, near misses, and hazard observations to the extent they are associated with, or related to, its work for Apex or subsidiaries of Apex
  • Use natural resources, including raw materials, energy, and water, efficiently
  • Ensure that reasonable efforts are made to avoid and minimize environmental impacts, and to protect and conserve biodiversity

Encouraged Practices

Apex also encourages each supplier to:

  • Work toward reducing or eliminating waste
  • Manage and dispose of waste, when it cannot be eliminated/reused/recycled, in a responsible manner that protects the environment and the health and safety of employees and adjacent communities
  • Minimize the use of hazardous materials and utilize environmentally friendly substitutes (e.g., non-/less toxic, contains recyclable materials, minimizes waste, minimizes emissions, etc.) when feasible
  • Establish control mechanisms to prevent pollution
  • Track, document, and seek to minimize energy consumption and greenhouse gas emissions
  • Seek ways to improve energy efficiency and use less carbon-intensive sources of energy

Supply Chain, Environmental Impacts, Human Rights, and Working Conditions

Apex interfaces with its supply chain through a select group of contractors and equipment manufacturers that supply the equipment and materials for Apex’s renewable energy projects. Apex is committed to working with suppliers that provide equipment produced or manufactured without forced labor.

Apex Supply Chain Requirements

Apex requires each supplier, as applicable, to:

  • Comply with applicable U.S. and international labor and employment laws
  • Not enable a work environment that jeopardizes employee safety or freedoms
  • Establish a policy to ensure that the materials used by the supplier are produced and sourced in an ethical manner
  • Prohibit the use of forced labor, child labor, or trafficked labor in its direct and indirect supply chain and require recordkeeping documenting compliance

Encouraged Practices

Apex encourages each supplier to:

  • Conduct comprehensive supply chain due diligence to identify, prevent, and mitigate human rights and environmental concerns. This diligence should include supply chain tracing (demonstrating the chain of custody from mineral extraction to production of the finished product) and supply chain management measures (including vetting of all potential suppliers for forced labor concerns)
  • Diligence its supplier’s supply chain by reviewing ESG reports, when available
  • Work with subcontractors and suppliers to assess and address environmental and sustainability issues within their supply chains
  • Support Apex’s ESG priorities and goals and encourage subcontractors to do the same

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