Responsible Business Conduct and Ethics

BUSINESS ETHICS

At Mercer, we are committed to ethical business conduct, transparency, and responsible corporate governance. Our approach to business ethics, data security, and ESG risk management ensures we uphold the highest legal, regulatory, and ethical standards across our operations, supply chain, and stakeholder engagements.

Mercer defines business ethics as “doing the right thing” in every aspect of our operations, from complying with laws and regulations to fostering trust, respect, and accountability within our workforce, communities, and partnerships. We expect all employees and leaders to demonstrate integrity, align with our core values, and lead by example.

We adhere to all relevant laws, industry regulations, and governance requirements in the regions where we operate. We maintain open communication with stakeholders, including shareholders, investors, employees, and communities, to ensure ethical decision-making and engage proactively with government agencies, environmental organizations, and certification bodies to maintain our social license to operate.

COMPANY-WIDE CODE OF BUSINESS CONDUCT AND ETHICS

Mercer’s Code of Business Conduct and Ethics provides clear guidelines on ethical behavior, legal compliance, and responsible decision-making. Our Code applies to all officers, directors and employees. Additionally, Mercer maintains a whistleblower hotline and reporting website to ensure employees can report ethical concerns confidentially and without retaliation. Whistleblower resources are prominently displayed at all Mercer facilities. Regular internal communications and training reinforce awareness of reporting mechanisms.

DISCRIMINATION AND HARASSMENT POLICIES

At Mercer, fostering an inclusive, respectful, and equitable workplace is a fundamental part of our corporate culture. We are committed to ensuring that all employees experience a professional environment free from discrimination, harassment, and any form of intimidation. Our policies align with legal frameworks and best practices, reinforcing our dedication to upholding human rights and workplace integrity. We strictly prohibit any form of workplace harassment.

Mercer provides equal employment opportunities regardless of age, race, color, religion, disability, marital status, sex, sexual orientation, national origin, or other legally protected characteristics. We promote a diverse and inclusive work environment where employees are valued for their unique backgrounds and contributions.

REPORTING AND ENFORCEMENT

Mercer encourages employees to report any concerns in good faith through internal reporting mechanisms, including direct supervisors, HR representatives, or the Integrity Hotline. Complaints are handled confidentially and investigated thoroughly to ensure fairness and protection for all parties involved. Retaliation against individuals who report concerns or cooperate with investigations is strictly prohibited.

By maintaining these high standards, Mercer ensures a workplace where employees can thrive, collaborate, and contribute to a sustainable and ethical corporate culture.

DATA PRIVACY AND CYBERSECURITY

As part of our commitment to responsible business conduct, Mercer has strengthened data privacy and cybersecurity policies to protect sensitive corporate, employee, and customer information. This year, we updated supplier terms and conditions to include cybersecurity and data protection requirements. Suppliers are expected to comply with Mercer’s security protocols to safeguard data integrity and privacy.

Our logistics and supplier network is monitored using a third-party risk assessment tool that evaluates cybersecurity threats, ethical risks, and ESG compliance. The system provides real-time monitoring and flags potential vulnerabilities within our value chain.

Employees receive regular training on cybersecurity best practices to minimize risks related to phishing, data breaches, and cyber threats.

ALL MERCER EMPLOYEES AND LEADERS ARE EXPECTED TO:

Treat colleagues with dignity and respect at all times.
Remain aware of behaviors that may be perceived as harassment or discrimination.
Take prompt action to address and report inappropriate conduct.