CODE OF CONDUCT

AHEAD represents and warrants that we shall comply with all governmental regulations and laws, EICC Code of Conduct and all Laws relevant to health, safety, human rights, regulations associated with human trafficking and slavery, labor, ethics and the environment (including but not limited to ROHS, WEE and Reach).

Integrity

We believe in ethical leadership and doing the right thing.   We believe in treating our customers, suppliers, and others fairly.

Anti-Harassment Policy

AHEAD is committed to providing a workplace that is free of harassment, discrimination, bullying, and other offensive behaviors. All employees are expected to support this commitment by treating everyone they interact with through work, both internally and externally, in a way that is consistent with both the intent and spirit of this policy.

EEO

AHEAD provides equal employment opportunities (EEO) to all employees and applicants for employment without regard to race, color, sex (including pregnancy, childbirth, and related medical conditions), religion, national origin, ancestry, creed, age, disability (physical or mental), genetic information, protected veteran or military status, sexual orientation or gender identity, order of protection status, marital status, homelessness status, arrest records, unfavorable discharge from military service, citizenship status, or any other characteristic protected by federal, state or local law.

Human Rights Policy

AHEAD fully supports the United Nations Framework and Guiding Principles on Business and Human Rights and expects the supplier to respect all human rights, including labor rights, throughout its business activities. California Supply Chain Transparency Act – AHEAD supports this act which was created to help eradicate human trafficking and slavery worldwide. We require direct suppliers to certify that materials incorporated into their product comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business. Forced Labor – AHEAD expects our suppliers will under no circumstances use, or in any other way benefit from, forced labor. Forced labor refers to any form of indentured servitude such as the use of physical punishment, confinement, or threats of violence as a method of discipline or control, such as Rev 1.3 retaining employees’ identification, passports, work permits, or deposits as a condition of employment. Wages and Benefits – AHEAD’s employees are provided with wages and benefits that, at a minimum, comply with national laws or industry standards, whichever is higher, including those pertaining to overtime work and other premium pay arrangements. In any event, wages should always be enough to meet basic needs for employees and their entitled official dependents and to provide some discretionary income. Employment Practices – AHEAD shall only employ workers who are legally authorized to work in their facilities and are responsible for validating employees’ eligibility to work through appropriate documentation. All work shall be voluntary, and workers shall be free to leave work or terminate their employment at will. To every extent possible, all work performed will be on the basis of a recognized employment relationship established through national law and practice. Minimum Age for Employment – The use of child labor by AHEAD is strictly prohibited, in line with Minimum Age local, federal, national, or international laws. Conflict Minerals – AHEAD requires our suppliers to provide documentation (CMRT) due diligence with their relevant suppliers consistent with OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.

Anti-Counterfeit

AHEAD requires that its suppliers must meet or exceed the DoD Counterfeit Prevention Policy. This is accomplished by qualifications of suppliers to industry standards for supply chain security, and ISO 9001:2015 requirements for part marking and traceability, and disposition of nonconforming materials.

Anti-Bribery

AHEAD will never, directly or through intermediaries, offer or promise any personal or improper advantage in order to obtain or retain a business or other advantage from a third party, whether public or private. AHEAD will not pay or accept bribes, arrange or accept kickbacks and shall not take any actions to violate, or cause its business partners to violate, any applicable anti-bribery laws and regulations including the U.S. Foreign Corrupt Practices. AHEAD prohibits any and all forms of bribery, corruption, extortion, and embezzlement.

Environment

AHEAD complies with all applicable legal environmental requirements and demonstrates continuous improvement of its environmental performance.

Health and Safety

AHEAD complies with applicable OSHA standards and recognizes management systems such as OHSAS 18001 and ILO Guidelines on Occupational Safety and Health wellness.

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