Environmental, Social & Governance (ESG) Policy

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• Overview & Purpose
• Definitions
• Environmental Standards
• Packaging & Waste Reduction
• Hazardous Materials & E-Waste
• Carbon Footprint & Emissions
• Social Responsibility
• Labor Standards & Human Rights
• Supply Chain Transparency
• Governance & Ethics
• Reporting & Disclosure
• Enforcement & Compliance
• Contact Information

✓ Overview & Purpose

Upmos is committed to building a marketplace that promotes environmental sustainability, social responsibility, and ethical governance. This ESG Policy establishes minimum standards and aspirational goals for all sellers operating on the Upmos Marketplace and reflects our commitment to responsible commerce.

Upmos Entity: Upmos Inc., 9896 Bissonnet St, Houston TX 77036, USA

Contact: esg@upmos.com | (855) 637-2433 (855-MERCHED)

Regulatory Framework: This policy is informed by the EU Corporate Sustainability Reporting Directive (CSRD), California SB 253/SB 261, the UN Global Compact Principles, the ILO Fundamental Conventions, and the UN Guiding Principles on Business and Human Rights.

✓ Definitions

• ESG: Environmental, Social, and Governance — the three pillars of sustainable and ethical business practice
• Carbon Footprint: Total greenhouse gas (GHG) emissions caused directly and indirectly by a product, seller, or supply chain, measured in CO2 equivalent (CO2e)
• Scope 1 Emissions: Direct GHG emissions from owned or controlled sources (e.g., company vehicles, manufacturing facilities)
• Scope 2 Emissions: Indirect emissions from purchased electricity, steam, heating, and cooling
• Scope 3 Emissions: All other indirect emissions in the value chain, including shipping, packaging, and upstream/downstream activities
• Conflict Minerals: Tin, tantalum, tungsten, and gold (3TG) sourced from conflict-affected and high-risk areas, as defined by the Dodd-Frank Act Section 1502 and EU Conflict Minerals Regulation
• Circular Economy: Economic model aimed at eliminating waste through reuse, repair, refurbishment, remanufacturing, and recycling
• RoHS: Restriction of Hazardous Substances Directive (EU 2011/65/EU), restricting hazardous materials in electrical and electronic equipment
• REACH: Registration, Evaluation, Authorisation and Restriction of Chemicals (EC 1907/2006)
• Extended Producer Responsibility (EPR): Environmental policy requiring producers to take responsibility for end-of-life management of their products

✓ Environmental Standards

General Commitments

• All sellers must comply with applicable federal, state, and local environmental regulations, including the Clean Air Act, Clean Water Act, and Resource Conservation and Recovery Act (RCRA)
• Sellers are encouraged to adopt ISO 14001 (Environmental Management Systems) or equivalent environmental management frameworks
• Products must comply with EPA regulations and any applicable state environmental standards (including California Proposition 65)
• Sellers must disclose any environmental permits, violations, or pending enforcement actions upon request

Product Environmental Standards

✓ Packaging & Waste Reduction

Mandatory Requirements (Effective March 1, 2026)

• Right-Sizing: Packaging must be appropriately sized for the product. Excessive void fill (>50% air) is prohibited. Upmos may flag listings with customer complaints about overpackaging
• Prohibited Materials: Expanded polystyrene (Styrofoam) packing peanuts are prohibited for all shipments. Alternatives include recycled paper fill, biodegradable air pillows, or corrugated inserts
• Recyclable Materials: At least 80% of packaging materials by weight must be recyclable, compostable, or made from recycled content
• Labeling: All packaging must include recyclability symbols (How2Recycle label or equivalent) and material identification codes

Aspirational Goals (2027-2028)

• 2027: 100% of packaging materials should be recyclable, reusable, or compostable
• 2027: Minimum 50% recycled content in cardboard and paper packaging
• 2028: Elimination of single-use plastic packaging for categories where alternatives exist
• 2028: Implementation of returnable packaging programs for high-value items

GoCargo Fulfillment

Products fulfilled through GoCargo use Upmos-certified sustainable packaging: FSC-certified cardboard, recycled paper fill, water-activated paper tape, and biodegradable poly mailers. GoCargo packaging meets all mandatory and aspirational targets.

✓ Hazardous Materials & E-Waste

Seller Obligations

• Sellers must maintain current Safety Data Sheets (SDS) for all products containing hazardous chemicals and provide them to Upmos upon request
• All hazardous materials must be shipped in compliance with DOT (49 CFR), IATA, and applicable carrier regulations
• Electronics sellers must comply with state e-waste laws (California SB 20, New York ECL, Washington E-Cycle) and participate in or fund take-back/recycling programs where required
• Products containing mercury, cadmium, hexavalent chromium, PBBs, PBDEs, or DEHP/BBP/DBP/DIBP above RoHS thresholds are prohibited unless expressly exempted

Extended Producer Responsibility (EPR)

• Sellers operating in EPR-regulated jurisdictions (California, Colorado, Maine, Oregon, Washington) must register with the appropriate state program and fund end-of-life product management
• Sellers must provide EPR registration numbers to Upmos upon request and maintain compliance documentation for a minimum of 5 years
• Upmos reserves the right to require proof of EPR compliance before listing products in regulated categories

✓ Carbon Footprint & Emissions

Disclosure Requirements

Upmos Platform Commitments

• Carbon Calculator: Free carbon estimation tool available to all sellers through the Bloom Dashboard, based on shipping distances, packaging materials, and product categories
• Carbon-Neutral Shipping: Upmos offsets 100% of Scope 3 shipping emissions for GoCargo-fulfilled orders through verified carbon offset projects (Gold Standard or Verified Carbon Standard)
• Green Badge Program: Sellers meeting sustainability benchmarks receive a “Green Seller” badge on their storefront and product listings, increasing visibility and buyer trust
• Annual Sustainability Report: Upmos publishes an annual marketplace-wide sustainability report detailing aggregate emissions, waste reduction, and progress toward goals

Reduction Targets

• Upmos is committed to reducing platform-wide Scope 1 and 2 emissions by 50% by 2030 (baseline: 2025) and achieving net-zero by 2040
• Sellers accounting for more than $500K/year in GMV are encouraged to set Science-Based Targets (SBTi) and report progress annually

✓ Social Responsibility

Community Impact

• Upmos allocates 1% of net marketplace revenue to community impact programs, including small business grants, digital literacy training, and disaster relief
• Sellers are encouraged to participate in Upmos community programs, including the Seller Gives Back initiative (voluntary donation of 0.1% of sales to verified nonprofits)
• Upmos prioritizes platform features and support resources for minority-owned, women-owned, veteran-owned, and small businesses

Diversity & Inclusion

• Upmos does not discriminate against sellers based on race, color, religion, sex, national origin, age, disability, sexual orientation, gender identity, or veteran status
• Sellers must not engage in discriminatory practices in their product offerings, pricing, shipping, or customer service
• Upmos maintains a Supplier Diversity Program that tracks and reports on the diversity of the seller base

Product Safety & Consumer Protection

• All products must comply with applicable consumer protection regulations (CPSC, FTC Act, state consumer protection statutes)
• Sellers must promptly report any product safety issues, recalls, or consumer injuries to Upmos and relevant regulatory authorities
• Products marketed as “organic,” “natural,” “eco-friendly,” or similar environmental claims must be substantiated with third-party certifications to avoid greenwashing

✓ Labor Standards & Human Rights

Zero Tolerance Policies

• Forced Labor: Sellers shall not use forced labor, bonded labor, indentured labor, involuntary prison labor, or any form of human trafficking in their operations or supply chains. This includes the withholding of identity documents or wages as a means of coercion
• Child Labor: Sellers shall not employ children under the age of 15 (or the applicable local minimum age, whichever is higher). Workers under 18 shall not perform hazardous work. Compliance with ILO Conventions 138 and 182 is required
• Modern Slavery: Sellers with annual revenue exceeding $1M must provide an annual Modern Slavery Statement in accordance with the UK Modern Slavery Act 2015 and California Transparency in Supply Chains Act (SB 657)

Fair Labor Practices

• Wages: All workers must be paid at least the applicable legal minimum wage, with overtime compensation in accordance with local labor laws
• Working Hours: Working hours shall not exceed limits set by applicable law. Workers shall receive at least one day off in every seven-day period
• Freedom of Association: Workers’ rights to freedom of association and collective bargaining shall be respected in accordance with applicable laws
• Non-Discrimination: Sellers shall not discriminate in employment practices based on race, color, religion, sex, national origin, age, disability, sexual orientation, or gender identity
• Health & Safety: Sellers shall provide a safe and healthy workplace in compliance with OSHA standards and applicable state/local regulations

Conflict Minerals

• Sellers of products containing tin, tantalum, tungsten, or gold (3TG) must exercise due diligence on the source and chain of custody of these minerals
• Upon request, sellers must provide a Conflict Minerals Reporting Template (CMRT) or equivalent disclosure using the Responsible Minerals Initiative framework
• Sellers shall not knowingly source 3TG minerals from mines or smelters that finance or benefit armed groups in conflict-affected regions

✓ Supply Chain Transparency

Disclosure Requirements

• Country of Origin: All products must accurately list the country of origin on product listings and shipping labels (19 U.S.C. § 1304, FTC Made in USA standard)
• Supplier Mapping: Sellers with annual revenue exceeding $500K must maintain and provide to Upmos upon request a list of Tier 1 suppliers (direct suppliers) including name, location, and primary goods/services provided
• Factory Audits: Sellers with annual revenue exceeding $1M with private-label or contract-manufactured products must conduct or provide evidence of social compliance audits at manufacturing facilities at least every 2 years (BSCI, SMETA, or SA8000 standards accepted)

Sustainable Sourcing

• Sellers are encouraged to prioritize suppliers with environmental certifications (ISO 14001, B Corp, Fair Trade, Rainforest Alliance)
• Products containing palm oil, soy, wood, or paper should source from certified sustainable sources (RSPO, FSC, PEFC) where available
• Sellers of seafood products must comply with the Marine Stewardship Council (MSC) or equivalent certification standards

✓ Governance & Ethics

Anti-Corruption

• Sellers must comply with the Foreign Corrupt Practices Act (FCPA), UK Bribery Act, and all applicable anti-bribery and anti-corruption laws
• Sellers shall not offer, pay, promise, or authorize any bribe, kickback, or improper payment to any government official, Upmos employee, or third party to obtain or retain business
• Gifts to Upmos employees are limited to nominal value (<$50) and must be reported. Cash gifts are prohibited

Whistleblower Protection

• Upmos maintains an anonymous ethics hotline for reporting suspected violations of this ESG Policy, the MPA, or applicable laws
• Reports can be submitted via ethics@upmos.com or through the anonymous reporting portal in the Bloom Dashboard
• Upmos prohibits retaliation against any individual who reports a suspected violation in good faith

Data Privacy & Digital Ethics

• Sellers must handle customer data in accordance with the Upmos Privacy Policy, Data Processing Agreement, and applicable privacy laws (GDPR, CCPA, VCDPA, CPA)
• Sellers must not use dark patterns, deceptive design, or manipulative UX practices in product listings or communications
• AI-generated product descriptions, images, or reviews must be disclosed as AI-generated where required by applicable law or FTC guidance

✓ Reporting & Disclosure

Annual ESG Questionnaire

All sellers are required to complete an annual ESG self-assessment questionnaire through the Bloom Dashboard. The questionnaire covers:

• Environmental practices (packaging, emissions, waste management)
• Labor standards (wages, working conditions, supply chain audits)
• Governance (anti-corruption, data privacy, ethical practices)
• Product safety and compliance certifications

ESG Scoring

Public Transparency

• Sellers scoring “ESG Leader” or “ESG Committed” may opt into having their ESG score displayed on their seller storefront
• Upmos publishes aggregate marketplace ESG metrics in its annual sustainability report (no individual seller data disclosed without consent)

✓ Enforcement & Compliance

Progressive Enforcement

Audit & Verification

• Upmos reserves the right to audit seller ESG practices, request documentation, and conduct third-party inspections with 30 days’ notice
• Sellers must cooperate with ESG audits and provide requested documentation within 15 business days
• Findings are communicated through the Bloom Dashboard with remediation timelines and required actions

✓ Contact Information

ESG & Sustainability Team

• ESG Inquiries: esg@upmos.com
• Ethics Hotline: ethics@upmos.com
• Vendor Support: vendors@upmos.com
• Phone: (855) 637-2433 (855-MERCHED)

Related Documents

• Marketplace Participation Agreement (MPA)
• Vendor Code of Conduct (VCoC)
• Product Safety Policy
• Service Level Agreement (SLA)

Synopsis — Key ESG Commitments

• ✅ 80% Recyclable Packaging: Minimum packaging recyclability requirement for all sellers
• ✅ Zero Tolerance: Forced labor, child labor, and modern slavery result in immediate termination
• ✅ Carbon Transparency: Tiered disclosure requirements based on seller revenue
• ✅ Green Badge Program: Recognition and visibility boost for ESG-leading sellers
• ✅ Conflict Minerals Due Diligence: Required for products containing 3TG
• ✅ Annual ESG Questionnaire: All sellers complete sustainability self-assessment
• ✅ Net-Zero by 2040: Upmos platform commitment to carbon neutrality
• ✅ Anti-Corruption: Full FCPA/UK Bribery Act compliance required