Vendor Code of Conduct

Enterprise Financial Services Corp (“EFSC”) is committed to conducting our business in accordance with the highest ethical standards and in compliance with all applicable laws, rules and regulations. We expect our vendors to share our principles and uphold our standards and for each to develop policies and programs as appropriate to ensure that all employees and subcontractors understand and adhere to these standards. We expect our vendors to operate in compliance with the principles outlined in this Vendor Code of Conduct (“Code”). The term “Vendors” (individually, a “Vendor”), as used in this Code, is defined as an external third-party that has entered into a business or contractual relationship to provide business goods, services, functions or activities to, or on behalf of, EFSC and its wholly-owned subsidiaries, including Enterprise Bank & Trust (“Bank”) (collectively, known as the “Company”). 

The provisions of this Code are in addition to those specified in any agreement between a Vendor and the Company. Where this Code may conflict with the terms of a Vendor contract, the contract terms will prevail. 

Vendors are expected to self-monitor their compliance with this Code while conducting business with or on behalf of the Company, and to inform the Company in a timely manner of any non-compliance. The Company reserves the right to monitor compliance with this Code using a reasonable and risk-based approach and framework that is suitable for a range of vendor compliance programs. This may include verification through self-assessment/questionnaires, on-site audits and/or other means of due diligence. If requested, vendors are expected to provide written information, including policies, procedures and data regarding the topics included in this Code. Any vendor that does not comply fully with this Code is expected to remediate any lapses to the Company’s satisfaction in a timely manner. Failure to comply with the terms of this Code may jeopardize a Vendor’s relationship with the Company.

Business Ethics

• Business Integrity: Vendors shall exercise high standards of integrity in business interactions, and all of their business dealings shall be accurately reflected in their books and records in accordance with applicable laws. Vendors shall implement appropriate procedures designed to prevent bribery, corruption, kickbacks and embezzlement.
• Intellectual Property and Software: Vendors shall respect all intellectual property rights and software licensing obligations and use technology only in a manner that protects, and is in compliance with, the owner’s intellectual property rights.
• Privacy: Vendors shall comply with privacy and information security laws and regulatory requirements relating to the collection, storage, processing, transfer and sharing of personal information. Vendors shall safeguard the privacy of the personal information of their customers and employees.
• Whistleblower Protection and Anonymous Complaints: Vendors shall protect the confidentiality of their whistleblower employees, prohibit retaliation, and, where legally permitted, provide an anonymous complaint mechanism for their employees to report grievances.
• Gifts, Meals and Entertainment: Vendors shall not provide any gift, meal or entertainment to a Company associate in any situation which might improperly influence, or appear to improperly influence, such associate’s decision in relation to a Vendor.

Employment & Labor

• Freedom of Association: Where legally authorized, Vendors shall respect their employees' rights to join or form trade unions and to bargain collectively, or to conduct similar activities.
• Anti-discrimination/Diversity: Vendors shall provide a workplace free of harassment and discrimination, in which their employees are treated fairly and respectfully. Vendors are expected to strive for a workforce that is inclusive and representative of the communities in which they operate. In the United States, Vendors are expected to take proactive steps to provide a full spectrum of businesses — based on the ownership structure (e.g. women-owned, locally owned) or scale (e.g. small or medium enterprise) — with the opportunity to compete on a fair and equal basis for business. Vendors will not retaliate against employees who report abuse, discrimination, ethical concerns or violations of law.
• Employment Practices: Vendors shall not (i) use any form of slave, forced, bonded, indentured or involuntary labor, and shall fully comply with all laws that prohibit the use thereof, as and when applicable, (ii) engage in human trafficking or exploitation, (iii) import goods tainted by slavery or human trafficking, or (iv) retain employees’ government-issued identification, passports or work permits as a condition of employment.
• Underage Labor: Vendors shall not use underage labor as defined by applicable law regulating the minimum legal age to work. Workers below the age of 18 shall not be employed in jobs that are likely to jeopardize the health and safety of young workers.
• Employment Status: Vendors shall employ only workers who are legally authorized to work in their location. Vendors are responsible for validating employees' work eligibility status.
• Compensation and Working Hours: Vendors shall provide all workers with accurate information about their wages, mandated benefits and any other basis of their compensation. Vendors shall comply with applicable labor laws governing working hours and employee compensation in all locations in which they operate.

Health and Safety & Environment

• Health and Safety: Vendors shall: (i) provide their employees with a safe workplace, (ii) have reasonable procedures to detect, prevent and handle potential risks to the health, safety and security of employees, and (iii) follow all applicable laws relating to health and safety in the workplace.
• Environment: Vendors shall operate in an environmentally responsible manner, strive to minimize adverse impact on the environment and comply with all environmental laws in the countries in which they operate. Where feasible, vendors should take steps to incorporate how they will mitigate the impact of climate change into their strategies and business resiliency plans, through establishing greenhouse gas (GHG) emission reduction targets, selecting low-GHG products and services, and other initiatives, where relevant.

Reporting Concerns

If a Vendor becomes aware of or suspects misconduct relating to services rendered to or on behalf of the Company, or a violation of this Code, then Vendor will report it to the appropriate Company contact. If a Vendor suspects that a Company associate has been acting in less than full compliance with law and ethical business practices, the Vendor should contact (anonymously, if so desired) the Ethics & Compliance Hotline by phone at: (844) 864-6369 or online at www.reportlineweb.com/enterprisebank; or by mailing a note with relevant documentation (if available) to Enterprise Financial Services Corp, Attn: Internal Audit, 150 N. Meramec Ave, Clayton, MO 63105.