Code of Ethics

Purchasing Policy

The following information is provided to assist suppliers in understanding some of Clean Harbors’ procedures, policies, and practices that are designed to lend continuity to our supplier/customer relationships. This brief outline is intended to be a general overview and not a complete summary. The purchasing staff is able to provide additional details where necessary.

I Product Quality: Quality is not negotiable. Clean Harbors expects suppliers to furnish quality products that conform to specifications and customer demands on a consistent and ongoing basis. This is of absolute necessity in supporting Clean Harbors’ position as a provider of the finest quality environmental services.

II Product Delivery: Lead-time for orders shall be agreed upon between Clean Harbors and its supplier. This includes but is not limited to all equipment, packaging, goods, & services. Any changes or anticipated changes to lead-times must be communicated to Clean Harbors’ Corporate Purchasing Department.

III New Product /Technologies: Clean Harbors encourages and expects suppliers to introduce new ideas, products, and technologies into our business. Through this creativity, Clean Harbors is able to offer the customer a unique and more advanced service relative to our competition. This premise is a foundation to our long-term supplier relationships.

IV Value Analysis: Our suppliers, both prospective and current, are encouraged to provide direction and input on Clean Harbors’ value analysis opportunities aimed at enhancing our position in the marketplace. Conversely, we are eager to work with suppliers in value engineering their products to create mutual benefits. Do not hesitate to present your ideas or ask for assistance in this regard.

V Pricing: Clean Harbors desires multiyear agreements that provide an assurance of continuous business. Our preferred suppliers are consequently well positioned to develop long term strategic plans for their business including R&D, facilities (including procurement, expansion, or improvement), and equipment investments. In exchange for volume consideration and long-term agreements, we expect our suppliers to commit to stable pricing and annual price reductions over the term of our agreement. When necessary, any proposed price increases are to be presented for review sixty (60) days prior to the effective date of change. Of course any price increase must be substantiated and "earned" through performance during the preceding period.

VI Return Policy: In the event that Clean Harbors must return goods and materials to a supplier, we will call for a Return Goods Authorization (RGA) number when one is required. Credit memos are required for all returned goods that have been invoiced, and the credit memo is to be sent to the same location that originally received the invoice.

VII Insurance: Suppliers are required to maintain adequate insurance with respect to the products supplied to Clean Harbors.

VIII Security: Clean Harbors’ business is heavily regulated by Federal, State and Local Laws. Accordingly, security is a primary issue as it relates to the safety and legal compliance of its operations.

IX Confidentiality: In so much as Clean Harbors is continually striving to stay ahead of the competition, it is essential that discussions of any nature be held in the strictest confidence. At times, depending on the circumstances, suppliers will be asked to sign a formal confidentiality agreement.

X Ethics: All purchasing personnel within the Clean Harbors organization, and the suppliers they deal with, are expected to conduct their business in accordance with the twelve "Principles and Standards of Purchasing Practice" as defined by the National Association of Purchasing Management (N.A.P.M.).

XI Supplier Visitations: Clean Harbors requests that suppliers meet with Corporate Purchasing at least annually to review usage, and the status of the materials, products, and services supplied. All visits must be prearranged and approved by Corporate Purchasing. Additionally, suppliers should plan to visit Clean Harbors’ facilities at least annually to review the same.

XII Disaster Recovery: It is necessary to have a disaster recovery program in place which includes: alternative warehousing/production locations; alternative delivery mechanisms; and information retrieval.

XIII Workforce Stability/Union Contract Negotiations: In the interest of ensuring a stable supply of products and services, all suppliers are to notify Clean Harbors in writing at least 90 days in advance of the expiration of any contracts under which the management or employees of that supplier perform their duties. In the event of a walk out, strike, or work stoppage at any of the supplier’s facilities, Clean Harbors must be notified in writing within 24 hours.