Effective date : DECEMBER, 19 2025

1.    PURPOSE AND SCOPE

This Supplier Code of Conduct (the “Code”) sets forth the minimum standards of business practices that you must comply with when providing goods or services to Free 2 Play Limited Partnership and its operating entities: Complexe de Soccer Saputo, Académie Impact de Montréal, Impact de Montréal F.C., and 10019259 Canada Inc. (hereinafter referred to as, “CF Montréal,” the “Club,” “we,” or “our”).

This Code applies to your conduct, decisions, actions, and interactions with CF Montréal, including with its employees, officers, directors, agents, representatives and subcontractors. As a supplier, you are responsible for ensuring that all individuals providing goods or services to CF Montréal through you—including your employees, suppliers, and subcontractors—comply with requirements, standards, and principles that are at least substantially similar to those set out in this Code. This Code may be updated or amended at anytime. It is your responsibility to periodically review this Code and any changes thereto ensure your ongoing compliance.

Compliance with this Code is an essential and determinative condition of any business relationship with CF Montréal.

2.    COMPLIANCE WITH LAWS AND REGULATIONS

Suppliers must comply with all applicable laws, regulations, and ordinances, including:

  • federal, provincial, and municipal laws in force in Canada, as well as those applicable in the country or province where the supplier operates;
  • applicable international conventions and standards, including those of the International Labour Organization (ILO) relating to human rights and labor;
  • laws relating to the protection of personal information and privacy;
  • laws applicable to the protection of the French language in Québec.

3.    FAIR BUSINESS RELATIONSHIP

Suppliers must, in particular:

  • adopt fair business practices in accordance with applicable competition and antitrust laws;
  • comply with all applicable laws aimed at preventing and combating corruption;
  • take all reasonable measures to avoid any actual, potential or apparent conflict of interest, in their dealings with CF Montréal and promptly disclose any conflict of interest to CF Montréal;
  • refrain from offering gifts, compensation, or other benefits to CF Montréal employees in order to improperly obtain an advantage or preferential treatment. All CF Montréal employees are required to comply with the CF Montréal Code of Ethics, which stipulates, among other things, that employees are not authorized to request gifts from suppliers.

4.    PROTECTION AND USE OF CF MONTRÉAL ASSETS AND INFORMATION

Suppliers must:

  • ensure the confidentiality, accuracy, and protection of any confidential or personal information obtained in the course of their relationship with CF Montréal;
  • implement appropriate administrative, technical and organizational security measures to prevent any data leak, loss, or unauthorized access;
  • not use or disclose to third parties, without CF Montréal’s prior written consent, any confidential or personal information, including information concerning the Club’s employees, athletes, partners, customers, or members;
  • comply with the Act respecting the protection of personal information in the private sector (Québec) and any other applicable laws;
  • refrain from publishing or communicating any defamatory, disparaging or negative statement regarding CF Montréal or its directors, officers, athletes or employees;
  • not use the name, trademarks or visual identity of CF Montréal, including its logo, or refer to it in any manner—including in advertising, websites, corporate documents, or public oral or written communications—without our prior express written consent;
  • not engage subcontractors or any other person or entity to fulfill contractual obligations to CF Montréal without our prior express written consent. Where such prior written consent is granted, by CF Montréal, you are responsible for ensuring that approved subcontractors comply with requirements, standards, and principles that are at least substantially equivalent to those set out in this Code.

5.    COMBATTING MODERN SLAVERY, FORCED LABOUR AND HUMAN TRAFFICKING

Suppliers must:

  • prohibit and prevent any form of forced labour, modern slavery, debt bondage, or human trafficking in their operations and those of their subcontractors;
  • ensure that all employees work on a voluntary basis with freely agreed and documented employment conditions;
  • refrain from any form of coercion, harassment, physical or psychological violence, or threats, in the management of personnel;
  • implement effective mechanisms for reporting and promptly correcting violations.

6.    NON-DISCRIMINATION AND DIVERSITY

Suppliers must:

  1. prohibit all discrimination based on race, nationality, ethnic origin, colour, religion, sex, gender, sexual orientation, marital status, age, disability, or any other status protected by law;
  1. promote diversity, equity and inclusion in their workplace.

7.    HEALTH AND SAFETY AT WORK

Suppliers must:

  • provide a safe working environment;
  • protect the safety, health, and physical integrity of their employees;
  • implement measures to prevent accidents, injuries, and occupational illnesses;
  • comply with all applicable occupational health and safety laws.

8.    ENVIRONMENTAL RESPONSIBILITY

Suppliers undertake to conduct their activities in compliance with applicable environmental laws, to adopt responsible business practices, and to strive for continuous improvement in their environmental performance.

Suppliers must:

  • use natural resources sustainably from economic, social, and environmental perspectives;
  • implement solutions to reduce energy and water consumption, minimize all forms of waste, and seek ways to reduce greenhouse gas (GHG) emissions;
  • pay particular attention to the environment in the planning and supervision of their business activities as well as any other activity that may impact the environment, in accordance with applicable laws.

9.    AUDITS AND INSPECTIONS

CF Montréal reserves the right to examine and verify supplier compliance with this Code at any time. You must cooperate with such examination or verification and provide access to any reasonably required information. If corrective measures are required, you must implement a corrective action plan with a timeline to effectively and promptly remedy non-compliance.  If applicable, we also reserve the right to terminate our relationship at our sole discretion if you fail to comply with the provisions of this Code or any required corrective action plan.

10.    REPORTING

You are required to promptly report any actual or suspected violation of this Code, including any applicable law, to our internal auditors at the following email address: legal@cfmontreal.com. This includes violations by any employee, agent, or subcontractor acting on your behalf or on behalf of CF Montréal. All reports will be treated confidentially.