Supplier Code of Conduct

1. Compliance with laws and regulations

Suppliers will comply with all applicable laws and regulations including those related to labor, health and safety, non-discrimination, ethics, environmental, and data privacy and security laws. This includes compliance with the International Labour Organization’s (ILO) standards and the Fair Labor Standards Act of 1938 as amended. Suppliers must also ensure that their employees, agents, subcontractors, and supply chain comply with these laws and regulations. In the event of any violation, suppliers must take immediate corrective action and inform IonQ, Inc. of the violation and corrective action in a timely manner. IonQ, Inc. and its affiliates reserve the right to terminate any relationship with a supplier found to be in violation of any laws or regulations.

2. No forced labor

Suppliers will not engage in any form of slavery, forced labor, involuntary servitude, or human trafficking. This includes debt bondage and the recruitment, transportation, transfer, harboring, or receipt of persons by means of threat, coercion, or deception for the purpose of exploitation. Suppliers must ensure that all employees and contractors are working voluntarily, and that they are free to leave their position at any time. Suppliers will also ensure that their supply chain is free from any form of slavery, forced labor, involuntary servitude, or human trafficking, and complies with all applicable laws and regulations.

3. No child labor

Suppliers will not employ any person under the minimum age for employment in the relevant country and will comply with all applicable laws and regulations related to child labor including those related to limitations of hours worked and prohibitions against certain types of work. Suppliers will also ensure that their supply chain is free from any form of child labor and complies with all applicable laws and regulations.

4. No discrimination

Suppliers will not discriminate against any employee based on race, religion, gender (including pregnancy, childbirth, and related medical conditions), age, disability, genetic information, sexual orientation, gender identity, veteran status, or any other legally protected characteristic. Suppliers will also ensure that their supply chain does not discriminate against any legally protected characteristic and complies with all applicable laws and regulations. Employees and/or job candidates must be evaluated solely based on their ability to perform the job they are applying for or currently engaged in performing. This provision applies to all employment decisions, including recruitment, hiring, training, promotion, and termination.

5. Fair wages and benefits

Suppliers will provide their employees with fair wages and benefits that comply with applicable laws and regulations including the Fair Labor Standards Act of 1938 as amended. This includes ensuring that employees are paid at least the minimum wage and that they are provided with legally mandated benefits such as social security and health insurance.

6. Working hours

Suppliers will comply with all applicable laws and regulations related to working hours including the Fair Labor Standards Act of 1938 as amended. This includes ensuring that employees do not work more than the maximum number of hours allowed by law, and that they are provided with adequate rest periods.

7. Freedom of association

Suppliers will respect the right of their employees to form, join, or refrain from joining, a labor union or other lawful worker organizations of their own selection. Suppliers must respect workers’ rights to freedom of association and collective bargaining. Workers must not be penalized or subject to intimidation, harassment, or reprisal for the non-violent exercise of these rights.

8. Health and safety

Suppliers will provide a safe and healthy working environment for their employees and contractors. This includes implementing appropriate safety measures, providing protective equipment, and ensuring that employees and contractors receive training on potential workplace hazards. Suppliers are required to implement a regular machinery maintenance program. Production and other machinery must be routinely evaluated for safety hazards. Where appropriate, Suppliers are required to provide properly maintained machinery controls (e.g., physical guards, interlocks, barriers) when machinery presents an injury hazard to workers. Suppliers will provide high-quality, safe products and services that meet IonQ’s requirements and industry standards.

9. Ethical behavior

Suppliers will conduct their business in an ethical manner, including complying with anti-corruption and bribery laws, avoiding conflicts of interest, maintaining accurate and truthful records (including proving accurate chain of custody records for goods and component materials), and protecting the confidentiality of IonQ Inc.’s and its affiliates’ information. Suppliers must protect worker whistleblower confidentiality and prohibit retaliation against worker whistleblowers, who in good faith report improper conduct (for instance, related to environmental or human rights violations, workplace grievances, and unethical business practices). Suppliers are required to comply with all applicable import, re-import, sanctions, anti-boycott, export, and re-export control laws. Suppliers must not provide any goods or services to IonQ, Inc. or its affiliates if their receipt is restricted or prohibited, including any goods or services originating from a country or manufactured or provided by an individual, corporation, organization, or entity under sanctions, embargoes, or any other restrictions administered by the United Nations, the United States, the European Union, or any other applicable government authority.

10. Environmental responsibility

Suppliers will minimize their environmental impact by adopting sustainable practices, reducing waste, and conserving resources. Suppliers will take measures to prevent pollution and minimize emissions of greenhouse gasses, PFAS, and other harmful substances. Suppliers will identify the origin of designed materials used in products consistent with recognized due diligence frameworks, and Suppliers will source from smelters and refiners that have successfully completed a recognized third-party responsible minerals audit.

11. Data privacy and security

Suppliers will implement appropriate data privacy and security measures to protect personal, confidential, and sensitive information. Suppliers must comply with applicable privacy and information security laws and regulatory requirements when personal information is collected, stored, processed, transmitted, and shared. Upon request, Suppliers will disclose use and management of data and information within the scope of the Supplier relationship. Suppliers will not act arbitrarily to interfere with a worker’s privacy.

12. Business continuity

Suppliers will have plans in place to ensure continuity of supply in the event of disruptions, such as natural disasters, pandemics, epidemics, or other emergencies. Suppliers are required to identify and plan for emergency situations by implementing response systems and emergency plans and training their workers on them at least annually. Suppliers should maintain a process for timely remediation of nonconformance identified by internal or external assessments, inspections, investigations, reviews, and reports.

13. Monitoring and reporting

Suppliers will permit IonQ, Inc. and its affiliates to request and monitor information related to their compliance with this code of conduct and report any violations. Suppliers will report non-compliance with this code of conduct to IonQ. Inc. in a timely manner and take immediate corrective action. Suppliers must designate representatives responsible for implementing management systems and programs that oversee compliance with applicable laws, conformance with this Code of Conduct. Suppliers must also establish a due diligence program to identify, prevent, address, mitigate, and account for the environmental, human rights, health, safety, and ethical risks associated with their business practices. Suppliers’ senior management must routinely review and assess the quality and efficiency of the management systems and programs.