Last modified 02/03/2026
Introduction
JetZero is committed to achieving the highest standards of ethics, integrity, and performance to provide the products and solutions necessary for our customers' success. This document sets forth fundamental and basic expectations for our Supplier and Trading Partners ("STPs") to comply with at all levels of operations (including their employees and subcontractors). We conduct our operations with integrity and respect and require our STPs to uphold the same standards to maintain lawful, ethical, and fair workplaces.
Supply Chain Flow Down
STPs should establish or incorporate these requirements into their own procurement processes as well as ensure sub-tier suppliers and subcontractors comply with this Supplier Code of Conduct. STPs are expected to monitor these compliance expectations and implement corrective action when requirements are not met.
Verification Rights
JetZero reserves the right to verify STP compliance with these requirements. Verification may include on-site assessments, document reviews, or other verification methods to provide JetZero with reasonable assurances of STP and downstream compliance.
Human Rights, Child Labor, Slavery & Human Trafficking
JetZero is firmly committed to protecting and promoting human rights in all aspects of our operations. We uphold the principles outlined in international frameworks such as the United Nations Universal Declaration of Human Rights, U.S. Trafficking Victims Protection Act, the UK Modern Slavery Act, and all other applicable national and international laws regarding human trafficking and modern slavery. We strictly prohibit the use of forced labor, child labor, human trafficking, or any form of modern slavery within our business or supply chains. This includes, but is not limited to, involuntary servitude, debt bondage, and any labor obtained through threat, coercion, or deception. All work must be voluntary, and employees shall have the freedom to terminate employment in accordance with established laws and contractual obligations. JetZero expects all STPs to comply with these standards and report any concerns or violations.
Equal Opportunity
We expect STPs to strictly adhere to all Equal Employment Opportunity laws, fostering a workplace where all employees are treated with dignity and respect. STPs must ensure employment decisions, which include hiring, firing, promotions, etc., must be based on job-related qualifications, performance, and business needs; not on protected characteristics or immutable traits.
Harassment
Employees of STPs must be afforded an environment free from physical, psychological, verbal harassment, and any other abusive conduct. JetZero strongly encourages STPs to provide recurring training programs to assist employees with recognizing and preventing harassment before it occurs.
Wages and Benefits
We expect our SOTPs to respect the rights of workers to associate freely and communicate openly with management regarding working conditions without fear of harassment, intimidation, penalty, interference or reprisal. SOTPs are expected to recognize and respect the ability of workers to exercise lawful rights of free association, including joining or not joining any association of their choosing.
Social Dialogue
Workers' rights to associate freely and communicate openly with management regarding working conditions must be respected without fear of harassment, intimidation, penalty, interference, or retribution. Workers must be able to exercise their lawful rights of free association in accordance with applicable laws. Where worker representatives are lawfully established, STPs should engage in good-faith dialogue on workplace issues.
Take responsibility for quality
Conformity & Quality Assurance
STPs shall maintain effective quality assurance and due diligence processes to ensure delivered products and services meet all applicable contractual, regulatory, conformity, and JetZero quality requirements. Where applicable, these processes shall be supported by a quality system framework that meets the intent of 14 CFR § 21.137 and aligns with recognized aerospace quality management principles, such as AS9100, commensurate with the scope, complexity, and risk of the supplied product or service.
Quality Records, Control & Traceability
Quality records shall be readily identifiable, traceable, retrievable, and controlled in a manner that ensures consistency with recognized quality management system principles and applicable regulatory expectations, and shall support conformity determinations, regulatory oversight activities, and continued operational safety obligations. At a minimum, quality records shall include, as applicable: Inspection and Test Records; Configuration & Traceability Records; Nonconformance Records; Corrective Action Records.
Authorized Release Documentation
Where Authorized Release is required by contractual, regulatory, or customer requirements, STPs of Technical Products shall generate and retain release documentation demonstrating: product identification and traceability information; identification of the releasing authority; clear linkage to applicable inspection, test, and conformity records.
Counterfeit Parts
STPs of technical products shall establish, implement, and maintain appropriate processes to prevent the introduction of counterfeit or suspect parts and materials into delivered products. Such processes shall include measures to detect, control, and exclude counterfeit parts from the supply chain and delivered product. If counterfeit or suspect parts are identified, STPs shall promptly notify JetZero, segregate and quarantine affected items and take appropriate corrective action in accordance with contractual quality requirements to prevent recurrence and resolve any nonconformances.
Use ethical & legal business practices
Anti-Corruption Laws
JetZero is committed to conducting business with integrity and in compliance. We require our STPs to comply with all applicable anti-corruption laws, directives, and regulations such as the U.S. Foreign Corrupt Practices Act and the U.K. Bribery Act. Offering or making any improper payments of money (or anything of value) to government officials, political parties, candidates for public office, or other persons is prohibited. STPs must conduct due diligence to prevent and detect corruption in all business arrangements, including partnerships, subcontracts, joint ventures, offset agreements, and the hiring of intermediaries such as agents or consultants.
Competition & Anti-Trust
Anti-competitive practices in violation of applicable laws, regulations, or contractual requirements are strictly prohibited. Any appearance of collusion with competitors should be avoided, including pricing discussions and strategies, production capacity, cost structures, market territories, customer assignments, or any other competitively sensitive topics with rival companies.
Gifts & Business Courtesies
We believe our STPs should compete on the merits of their products and services. The exchange of business courtesies may not be used to gain an unfair competitive advantage or exercise improper influence. Normal, appropriate, modest gifts, hospitality, or entertainment are permitted if they build legitimate business relationships and goodwill, provided they do not influence or appear to influence decisions.
Conflict of Interest
A conflict of interest may arise when a personal, financial, or familial interest compromises, or could be perceived to compromise, judgment, objectivity, or ability to perform duties impartially under the agreements with JetZero. STPs must avoid conflicts of interest or the appearance of a potential conflict of interest. STPs should provide prompt written notification to JetZero if an actual or potential conflict of interest arises, including conflicts between the interests of JetZero and the personal interests of a STPs employees or those of close relatives, friends, or business associates of a STP or its employees.
International Trade Compliance
Import & Export
STPs must ensure their business practices are in accordance with applicable laws, directives, and regulations governing the import and export of parts, components, and technical data. JetZero requires STPs to provide truthful and accurate information and obtain appropriate licenses and/or consents where necessary. Export control regulations must be followed, where applicable, including the U.S. Export Administration Regulations and International Traffic in Arms Regulations and equivalent rules in other countries must be considered.
Economic Sanctions
STPs must conduct business in full compliance with economic sanctions, trade embargoes, and restrictive measures from relevant government authorities, including the U.S. Office of Foreign Assets Control, UN Security Council, European Union, and others. If potential sanctions issues arise during JetZero business, STPs must notify us immediately and pause the transaction until resolved.
Anti-Boycott
JetZero will not participate in any unsanctioned economic boycott in accordance with the 1977 U.S. Export Administration Act and the 1976 U.S. Tax Reform Act, or similar legislation or regulations (the "Acts"). STPs must not participate in, cooperate with, or otherwise agree to do anything in violation of the Acts.
Responsible Sourcing of Minerals
JetZero is required to report and certify to its customers that its products do not contain conflict minerals sourced from conflict-affected regions. To support this requirement, STPs are expected to submit annual statements certifying they have conducted appropriate due diligence and their materials comply with OECD guidance and conflict mineral regulations.
Confidential Information, Intellectual Property & Supply Chain Security
Confidentiality, Data Protection, & Cyber Security
STPs may have access to sensitive, confidential, proprietary, CLASSIFIED, trade secret, customer, and personal data information belonging to JetZero (“Confidential Information”). At all times, STPs shall protect and safeguard this Confidential Information with the same level of care that it protects its own Confidential Information, in addition to abiding by all applicable laws and regulations. STPs shall only use JetZero’s Confidential Information for the contracted business purpose and are required to maintain the confidentiality of such information both during and after contracts.
STPs shall safeguard and protect Confidential Information entrusted to them, and any information generated or developed by them in support of our programs from unauthorized access, destruction, use, modification, or disclosure. STPs must immediately notify JetZero of any data breaches or cyber security incidents that affect or could affect our information, systems, products, or business. If cybersecurity incidents do occur, including those in a STP's supply chain that could impact JetZero, STPs must take immediate action to address the incident and quickly notify JetZero to support response and remediation efforts.
Intellectual Property
STPs shall comply with all intellectual property rights and follow applicable laws related to patents, copyrights, trademarks, trade secrets, and confidential information. STPs must not use, share, or disclose JetZero’s intellectual property without prior written authorization. Any products or services that STPs provide to JetZero must be ones the STP is authorized to provide and must not include intellectual property that belongs to someone else without permission.
Security of Supply Chain
STPs are expected to implement practices and procedures to ensure the security of their supply chain. STPs are encouraged to participate in the Customs-Trade Partnership Against Terrorism initiative of the United States Department of Homeland Security.
Maintain a safe & healthy workplace
Environmental, Health, and Safety
A safe and healthy work environment preserves employee health, safeguards third parties, and prevents accidents, injuries, and work-related illnesses. JetZero requires STPs to comply with all applicable environmental, health, and safety laws. STPs should consider implementing occupational health and safety management systems such as ISO 45001.
STPs are expected to be responsible stewards of the environment. This includes safeguarding natural resources, minimizing waste, and reducing or mitigating the environmental impacts of their operations. STPs must comply with all applicable environmental and pollution control laws and should actively seek to prevent waste and promote sustainable business practices.
Business Preparedness
Risk Management
STPs should adopt and incorporate risk management processes to identify potential risks, assess their likelihood and impact, prioritize risks requiring attention, implement mitigation strategies, and monitor risks continuously.
Consequences of Non-Compliance & Management of this document
STPs should promptly notify JetZero upon becoming aware of any actual or potential violations of this Supplier Code of Conduct, applicable laws, or contractual requirements. JetZero reserves the right to require remediation plans, conduct audits, and withhold payments where appropriate. STP non-compliance may result in corrective action, suspension of business, or termination of the commercial relationship. JetZero may be required to report violations of law to the applicable authorities.
Management and Administration
JetZero’s Supply Chain Team is responsible for the management of this Supplier Code of Conduct. Any changes shall be reviewed and approved in accordance with JetZero’s policy review process in effect at the time. Questions regarding this Supplier Code of Conduct should be directed to your Supply Chain Team point of contact.