Foreword

This code of conduct is based on the values of both companies. Its purpose is to ensure that all employees, managers and the management of Volz GmbH & Co. KG and AEE Aircraft Electronic Engineering GmbH live and act in accordance with the values and guidelines contained therein. The two companies, Volz GmbH & Co. KG and AEE Aircraft Electronic Engineering GmbH, will be referred to as “we” in the following.

The code is intended to provide a basic and clear understanding of the behaviour we expect from all our employees and at all places of work. This Code of Conduct will be reviewed regularly and adapted if necessary. In addition, each employee is required to read through, respect and sign the Code of Conduct.

We are committed to conducting our business in an ethical, legal and responsible manner. For this reason, we have imposed on ourselves this Code of Conduct on Social Responsibility. The companies are committed to ensuring that this Code is adhered to in all their locations, including global distributors. At the same time, we expect our suppliers or contractual partners to also behave in accordance with the requirements set out in these guidelines. In preparing this Code, reference has been made to recognized standards such as the United Nations Universal Declaration of Human Rights (UDHR) or the International Labour Organisation (ILO) Conventions. The principles set out below are based on these standards.

Compliance with Legislation

All business activities of the companies shall comply with all applicable legal requirements at national and international level as well as with the Volz Servos GmbH & Co. KG and AEE GmbH standards regarding employment and manufacturing. We further commit to comply with any applicable anti-bribery and anti-corruption laws and regulations in all our business activities.

Prohibition of Discrimination and Harassment

We will not allow or commit any discriminatory actions. Discrimination means any distinction, exclusion or preference which limits equal treatment or access to work and employment, and which may be based on colour, sex, religious belief, political opinion, age, national, social, or ethnic origin, family responsibilities or similar considerations of this kind. We are also committed to workplaces that are free from all forms of harassment and victimization.

Working Hours

We ensure that the applicable statutory working time restrictions are complied with. The maximum permitted working hours per week are regulated by national laws and are according to the conventions of the International Labour Organisation. The limitation of overtime is regulated in accordance with the regional legal or contractual obligations. Employees are entitled to at least one day off per week, except in exceptional circumstances and for a limited period of time. The work organisation shall provide for the necessary breaks from work so as not to endanger the safety and health of the employees.

Remuneration and Benefits

The companies guarantee not to pay wages below the legal minimum wage. We will not reduce or without pay for disciplinary reasons or as a condition of employment. The remuneration paid to employees must comply with all applicable laws on wages and salaries, including the provisions on minimum wages, overtime and benefits established by law.

Prohibition of Child Labour

We do not accept any employment of children under 16 years of age. General education or training programs taken up by children in schools or other institutions are not covered by this restriction. All young workers must be protected from doing any work which is likely to be hazardous or to interfere with the child’s education as well as jeopardize their health, physical, mental, social, spiritual, or moral development.

Prohibition of Forced Labour

We do not engage in forced or compulsory labour, which is defined as work or service performed under the threat of punishment or for which someone has not volunteered to perform. It is also forbidden to withhold personal identification documents from employees at their start of their employment.

Freedom of Association & Collective Bargaining

The company recognizes and respects the right of workers to freedom of association and their right to choose their representatives freely and independently and guarantees that these representatives will not be subject to any form of discrimination. The company also recognizes the right of workers to collective bargaining.

Health & Safety at Work

The companies shall ensure that the workplace and its environment (machinery, equipment and work process, chemical agents, etc.) do not endanger the physical integrity or health of workers. Appropriate measures to reduce the risk of accidents and improve working conditions are the aim of the regular optimization programs. Employees shall also receive training on occupational and workplace safety and health. Employees shall have guaranteed access to drinking water, sanitary facilities and social areas which have been constructed and shall be maintained in accordance with the applicable legal requirements for this purpose. The workplace and its surroundings must have suitable emergency exits, fire protection equipment and sufficient lighting. Adequate protection for non-smokers must also be provided.

Environment

In view of the current situation, both companies want to become more involved in environmental protection and pay particular attention to environmental friendliness in purchasing. Procedures and standards for waste treatment, for the handling and disposal of chemical and other hazardous materials, for emissions and for wastewater treatment, must at least meet or exceed the minimum legal requirements.