Project Reef - Sustainability Standards

Purpose

Project Reef was founded in Hawaiʻi with a mission to create high-performance sun protection products while supporting the protection of our oceans and marine ecosystems.

This policy outlines the ingredient and formulation standards that guide the development of all Project Reef sunscreen products.

Our Commitment

Project Reef formulates all sunscreen products using non-nano zinc oxide as the active UV-filtering ingredient.

Our formulation standards are designed to align with Hawaiʻi’s leadership in coral reef protection, including Hawaiʻi Act 104 (formerly Senate Bill 2571), which
restricts the sale and distribution of sunscreens containing oxybenzone and
octinoxate.

Project Reef also supports Maui County’s ongoing efforts to protect coral reefs, nearshore ecosystems, and marine biodiversity through local conservation initiatives and environmental stewardship programs.

Formulation Standards

Project Reef sunscreen products:

• Utilize non-nano zinc oxide as the active
  sunscreen ingredient.
• Do not contain oxybenzone (Benzophenone-3).
• Do not contain octinoxate (Ethylhexyl
  Methoxycinnamate).
• Are developed in accordance with our
  mineral-first formulation philosophy.
• Are formulated to meet applicable regulatory requirements in the markets where our products are sold.

EWG Verification

Project Reef sunscreen products are developed to meet rigorous ingredient safety and transparency standards.

Project Reef maintains EWG Verified® certification for eligible sunscreen products, demonstrating compliance with ingredient screening, transparency, and
health-based criteria established by the Environmental Working Group.

Supplier & Manufacturing Requirements

Manufacturing partners are expected to maintain ingredient documentation sufficient to support:

• Regulatory compliance
• Product quality requirements
• Ingredient traceability
• Compliance with Project Reef formulation
  standards
• New products and reformulations must comply with this policy prior to
  commercialization.

Continuous Improvement

Scientific understanding, environmental research, and regulatory standards continue to evolve.

Project Reef periodically reviews ingredient standards, emerging research, and regulatory developments to ensure our formulations continue to meet our
quality, safety, transparency, and environmental objectives.

References

• Hawaiʻi Act 104 (formerly Senate Bill 2571) restricting the sale and distribution of sunscreens containing oxybenzone and octinoxate.
• Project Reef EWG Verified® product standards.
• Project Reef Supplier & Manufacturing
  Partner Code of Conduct.

Effective Date

June 2026

Review

This policy will be reviewed periodically and updated as necessary to reflect evolving regulations, scientific understanding, and Project Reef’s commitments.

Purpose

Project Reef recognizes that responsible sourcing plays an important role in supporting product quality, business integrity, and environmental stewardship.

We seek to build relationships with suppliers and manufacturing partners that share our commitment to ethical and responsible business practices.

Our Approach

Project Reef encourages suppliers and business partners to:

• Comply with applicable laws and regulations.
• Respect human rights and maintain fair labor practices.
• Operate safe and healthy workplaces.
  Conduct business ethically and transparently.
• Support environmentally responsible business practices.

Supplier Partnerships

Project Reef values long-term partnerships with suppliers that demonstrate a commitment to continuous improvement in quality, sustainability, and compliance.

While Project Reef does not own or operate supplier facilities, we encourage our business partners to maintain responsible practices throughout their operations and supply chains.

Continuous Improvement

We recognize that suppliers may be at different stages of their sustainability
journey and encourage ongoing progress toward more responsible sourcing
practices.

Effective Date

June 2026

Review

This policy will be reviewed periodically and updated as needed.

Purpose

Project Reef iscommitted to reducing environmental impacts associated with packaging while maintaining product quality, safety, and functionality.

This policy outlines our approach to packaging selection and continuous improvement.

Packaging Principles

When feasible, Project Reef seeks to:

• Reduce unnecessary packaging materials.
• Increase the use of recycled and responsibly sourced materials.
• Improve packaging efficiency to reduce waste.
• Support packaging solutions that balancedurability, performance, and environmental considerations.

Current Initiatives

Project Reef currently utilizes packaging solutions that may include:

• Ocean-bound recycled plastic.
• Post-consumer recycled (PCR) plastic.
• Recyclable materials where appropriate.
• Non-aerosol packaging systems for select products.

Packaging materials and formats may evolve as new technologies and opportunities become available.

Continuous Improvement

Project Reef regularly evaluates opportunities to improve packaging sustainability while maintaining product integrity and customer experience.

Effective Date

June 2026

Review

This policy will be reviewed periodically and updated as needed.

Purpose

Project Reef is committed to conducting business responsibly and ethically throughout its supply chain. We recognize that our products are manufactured and supplied by third-party
partners, and we seek to work with organizations that share our commitment to product quality, environmental responsibility, regulatory compliance, ethical business practices, and
respect for human rights.

This Supplier & Manufacturing Partner Code of Conduct outlines the standards and expectations Project Reef encourages its suppliers, manufacturers, co-packers, contractors, and business partners to uphold.

Scope

This Code of Conduct applies to all suppliers, manufacturers, co-packers, contractors, logistics providers, ingredient suppliers, packaging suppliers, and other business partners
that provide products or services to Project Reef.

Legal Compliance

Project Reef expects suppliers and manufacturing partners to comply with all applicable local, state, national, and international laws and regulations governing their operations, including those related to labor, workplace safety, environmental protection, product
quality, and ethical business practices.

Human Rights & Labor Practices

Project Reef seeks to partner with organizations that respect human rights and maintain fair and lawful labor practices.

Suppliers and manufacturing partners are encouraged to:

• Prohibit forced labor, bonded labor, prison labor, and human trafficking.
  
• Comply with applicable minimum age and child labor laws.
  
• Promote equal opportunity and non-discrimination in employment practices.
  
• Maintain workplaces free from harassment, intimidation, abuse, and discrimination.
  
• Provide wages and benefits in accordance with applicable laws and regulations.
  
• Comply with legal requirements regarding working hours and overtime.

Health & Safety

Project Reef encourages suppliers and manufacturing partners to provide safe and healthy working environments for their employees and contractors.
This includes:

• Maintaining safe facilities and equipment.
  
• Providing appropriate workplace safety training.
  
• Identifying and mitigating workplace hazards.
  
• Maintaining emergency preparedness procedures.
  
• Complying with applicable occupational health and safety regulations.

Environmental Responsibility & Sustainability

Environmental stewardship is an important part of Project Reef’s mission.
We encourage suppliers and manufacturing partners to operate responsibly and continuously seek
opportunities to reduce environmental impacts associated with their operations.

Suppliers and partners are encouraged to:

• Comply with all applicable environmental laws and regulations.
  
• Reduce waste generation and promote responsible waste management practices.
  
• Improve efficiency in the use of energy, water, and raw materials.
  
• Minimize pollution and environmental impacts where feasible.
  
• Support responsible sourcing and sustainable material selection.
  
• Promote transparency regarding environmental and sustainability initiatives.
  
• Pursue continuous improvement in environmental performance over time.

Project Reef recognizes that suppliers may be at different stages of their sustainability journey and encourages
ongoing collaboration and progress toward more responsible
business practices.

Product Quality & Safety

Project Reef expects suppliers and manufacturing partners to maintain quality standards and procedures designed to support the production and delivery of safe, compliant, and
high-quality products and services.
Partners should promptly communicate any quality, safety, regulatory, or compliance concerns that may impact products or services provided to Project Reef.

Ingredient & Product Standards

Project Reef is committed to developing products that meet our internal standards for safety, quality, and environmental responsibility.

For sunscreen products manufactured on behalf of Project Reef:

• Oxybenzone (Benzophenone-3) is not permitted.
  
• Octinoxate (Ethylhexyl Methoxycinnamate) is not permitted.
  
• Manufacturing partners should maintain ingredient documentation sufficient to
  support regulatory compliance and product quality requirements.
  
• Suppliers are encouraged to provide accurate and transparent information
  regarding ingredients, materials, and product specifications.

Ethical Business Practices

Business Integrity
Project Reef expects suppliers and business partners to conduct business honestly, ethically, and transparently.

Anti-Corruption
Bribery, corruption, extortion, embezzlement, fraud, and other unethical business practices are inconsistent with Project Reef’s values and are strongly discouraged.

Fair Competition
Suppliers and partners should comply with applicable competition and antitrust laws.

Confidentiality
Confidential information shared by Project Reef should be protected and used only for authorized business purposes.

Compliance & Transparency

Project Reef encourages suppliers and manufacturing partners to maintain records and documentation necessary to support compliance with applicable laws, regulations, and contractual obligations.

Partners should promptly communicate any material quality, safety, environmental, regulatory, or compliance concerns that could affect products, services, or business continuity.

Suppliers and manufacturing partners are encouraged to support reasonable requests for documentation related to product quality, safety, ingredient information, regulatory
compliance, and sustainability initiatives.

Continuous Improvement

Project Reef values long-term partnerships and encourages suppliers and manufacturing partners to continuously improve their environmental, social, ethical, and operational performance.

We recognize that organizations may be at different stages in their sustainability and compliance journey and encourage ongoing progress, transparency, and collaboration.

Effective Date

June 2026

Review

This Code of Conduct will be reviewed periodically and updated as needed to reflect evolving regulations, industry best practices, and Project Reef’s commitments.