Effective Date: August 23, 2023

Capstone has a responsibility to do its best to protect the environment.  Even as an asset-light business, we are focused on monitoring our environmental impact, and taking action wherever possible to reduce our footprint.  We seek to be a force for good in the environment through the following efforts:

• Compliance with all applicable environmental laws and regulations.
• Commitment to a continual improvement process in environmental management.
• The reduction of waste through source reduction, reuse, and recycling where possible.
• Evaluation of environmental impacts of Capstone’s operations and facilities, including emissions, and striving to reduce them.
• The preservation of natural resources through efforts such as recycling, innovation, and pollution prevention.
• Improvement of Associate environmental performance through detailed procedures and training.
• Focusing on environmental responsibilities as part of our daily operations and business decision-making processes.
• Promotion of effective environmental performance by our suppliers and contractors.
• Participation in the support of sound environmental policy within the logistics sector.
• The promotion of awareness regarding environmental policies for Associates and the public.

Responsible and Sustainable Procurement Policy

It is the policy of Capstone Logistics, LLC, along with its affiliates and subsidiaries (together, “Capstone”) to understand and take appropriate responsibility for any adverse environmental, social, and economic impacts of its purchasing.  In doing so, Capstone shall a consider impacts on a life-cycle basis and prioritize actions according to: alignment with Capstone’s values, magnitude of impact, and compliance with any applicable regulations.

This Policy is adopted in order to align Capstone’s purchasing with its corporate social responsibility and environmental stewardship values and goals. This Policy applies to all types of Company-funded procurements and to all of the Company’s affiliates, subsidiaries, divisions and Associates.

For any of the following core strategies, it is understood that they shall be undertaken in conjunction with traditional purchasing considerations, such as budget, product/service performance requirements, and availability. Prior to making new purchases, Associates are also expected to consider: the need for the purchase; opportunities to extend the life of the existing item or material; and meeting the operational need through a different means (e.g. renting vs. purchasing). 

In making a purchase or engaging a service provider, Capstone Associates shall only engage with businesses that:

• Comply and adhere to all applicable environmental laws in respective countries/jurisdictions.
• Undertake initiatives to promote greater environmental responsibility such as: (a) responsible waste management and disposal; (b) reduction of greenhouse gases and other emissions harmful to the environment; and (c) conservation of nonrenewable natural resources. 
• Obey all relevant international and domestic laws regarding ethical business practices.
• Comply with all applicable laws, in accordance with the principles of the International Labor Organization, the UN Global Compact, and the UN Universal Declaration of Human Rights.
• Prohibit slavery and the use of forced, bonded, or child labor across the supply chain.
• Prohibit unlawful discrimination and harassment to provide a safe and inclusive work environment.
• Provide employees with a living wage, at a minimum.

It is the responsibility of each Capstone associate to ensure that its suppliers/service providers comply with that Policy.  Accordingly, when negotiating a purchase or service contract, Capstone Associates shall request that the following provision be added to the relevant agreement:

[Provider] has been presented with Capstone’s Responsible and Sustainable Procurement Policy, and understands that [Provider’s] compliance with that policy is a material term of this Agreement.

Any questions regarding this Policy should be directed to Capstone’s General Counsel.

Chemicals and Hazardous Waste Management and Disposal Policy

It is the policy of Capstone Logistics, LLC and its subsidiaries and affiliates (collectively "Capstone" or the "Company") to ensure that every effort is made to minimize the generation of hazardous waste, and that all hazardous waste is properly managed and disposed of in accordance with all applicable federal, state, and local regulations. 

According to the EPA, hazardous waste is ignitable (flash point of < 140 F) or corrosive (pH of < 2 or > 12.5). Reactive chemicals, radioactive materials, poisonous materials, carcinogens, biohazards, compressed gasses, toxic chemicals, infectious items, and other specifically listed materials by the EPA are considered toxic or toxic waste. Hazardous wastes may include byproducts from chemical reactions or unwanted commercial products. 

Every Capstone associate is responsible for proper inventory, handling, storage or disposal of chemicals or chemical/hazardous waste.  The Director of Field Safety provides guidance for handling and proper disposal, and any questions regarding such should be directed to them.

Any suspected violations of this Policy should be directed to the Director of Field Safety.  Should you wish to report a suspected violation anonymously, you can do so via Capstone’s Associate Hotline: 855-607-8699, or via the web at www.capstonelogistics.ethicspoint.com.

Changes to this Policy 

This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. If we make any changes to this Policy, we will post the changes to our Site.