Last modified 08/24/2023
Introduction
JetZero is committed to achieving the highest standards of ethics, integrity, and performance to provide the products and solutions necessary for our customers. This document sets forth the fundamental requirements that we expect our Supplier and Other Trading Partners ("SOTPs") (And those who work for them, including employees and subcontract labor) to comply with at all tiers.
For the purposes of this document, other trading partners include JetZero’s prime contractors, resellers/distributors, teaming partners, and other companies JetZero may conduct business with.
JetZero expects our SOTPs to maintain the highest standards of ethics and integrity, comply with laws, regulations, contractual obligations and standards of business conduct. Our SOTPs must act ethically at all times and ensure the integrity of their operations. Acting with integrity means being accountable for the highest standards of behavior. In addition, our SOTPs must comply fully with all applicable laws and regulations, their contractual obligations with us and this document.
Treat people with dignity and respect
We expect our SOTPs to treat people with respect and dignity, encourage diversity, remain receptive to diverse opinions, promote equal opportunity for all, and foster an inclusive and ethical culture. SOTPs must refrain from violating the rights of others and address any adverse human rights impacts of their operations.
Child Labor
SOTPs must ensure that child labor is not used in the performance of work. The term “child” refers to any person under the minimum legal age for employment where the work is performed.
Human trafficking
We fully support the elimination of human trafficking and slavery from the supply chain and do not tolerate any trafficking in persons, both in the U.S. and globally. SOTPs must adhere to regulations prohibiting human trafficking and comply with all applicable local laws in the country or countries in which they operate.
For more information, please refer to our Slavery & Human Trafficking Policy.
Harassment
Our SOTPs should ensure that their employees are afforded an employment environment that is free from physical, psychological, and verbal harassment, or other abusive conduct.
Non-discrimination
Our SOTPs should provide equal employment opportunity to all employees and applicants for employment, without any unlawful discrimination.
Wages and benefits
Our SOTPs must pay workers at least the minimum compensation required by local law and provide all legally mandated benefits. In addition to payment for regular hours of work, workers must be paid for overtime at such premium rate as is legally required.
Social dialogue
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.
Take responsibility for quality
Quality
We expect our SOTPs to have in place quality assurance processes to identify defects and implement corrective actions and to facilitate the delivery of a product whose quality meets or exceeds the contract requirements. SOTPs must take due care to ensure their work product meets our company’s quality standards.
Counterfeit Parts
We expect, and will ask our SOTPs to confirm, they have developed, implemented, and maintain methods and processes appropriate to their products to prevent the introduction of counterfeit parts and materials into deliverable products. SOTPs must ensure that effective processes are in place to detect counterfeit parts and materials, as applicable, and exclude them from the delivered product.
Use ethical & legal business practices
Our SOTPs must not seek to gain advantages through unfair, unethical or illegal business practices.
Anti-corruption laws
Our SOTPs must comply with all applicable anticorruption laws, directives and regulations, such as the U.S. Foreign Corrupt Practices Act and the U.K. Bribery Act.
We require our SOTPs to refrain from offering or making any improper payments of money (or anything of value) to government officials, political parties, candidates for public office, or other persons. This includes a prohibition on facilitating payments intended to expedite or secure performance of a routine governmental action that the government official is already obligated to perform like obtaining a visa or customs clearance, even in locations where such activity may not violate local law.
Payments made to protect personal safety are permitted where there is an imminent threat to health or safety but must be properly recorded and reported to the buyer representative as promptly as possible under the circumstances.
We require our SOTPs to use 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.
Illegal payments
Our SOTPs must not offer any illegal payments to, or receive any illegal payments from, any customer, supplier, their agents, representatives or others. The receipt, payment, and/or promise of monies or anything of value, directly or indirectly, intended to exert undue influence or improper advantage is prohibited. This prohibition applies even in locations where such activity may not violate local law.
Anti-trust
Our SOTPs must not engage in anti-competitive practices in violation of applicable law, regulation or contractual requirements.
Gifts/business courtesies
We believe our SOTPs 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.
In connection with JetZero business, our SOTPs must ensure that the offering or receipt of any gift or business courtesy complies with JetZero policies and any applicable laws, regulations, contractual obligations, and rules and standards of the recipient’s organization, and are consistent with reasonable marketplace customs and practices.
Conflict of interest
Our SOTPs must avoid conflicts of interest or situations giving the appearance of a potential conflict of interest in their dealings with us. We require our SOTPs to provide notification to affected parties if an actual or potential conflict of interest arises, including conflicts between the interests of our company and the personal interests of a supplier’s or other trading partner’s employees or those of close relatives, friends or business associates of a SOTP or its employees.
Procurement integrity
Our SOTPs must maintain the integrity of our procurement and acquisition processes. SOTPs may not improperly use competitors’ confidential or proprietary information for their own benefit. If a supplier or other trading partner becomes aware of any such confidential or proprietary information, they should promptly take steps to avoid its improper use and inform our Company as appropriate.
Insider trading
Our SOTPs and their personnel must not use material or non-publicly disclosed information obtained in the course of their business relationship with us as the basis for trading or for enabling others to trade in the stock or securities of our company or those of any other company.
Use good trade practices
Import
Our SOTPs must ensure that their business practices are in accordance with all applicable laws, directives and regulations governing the import of parts, components, and technical data. We require our SOTPs to provide truthful and accurate information and obtain appropriate licenses and/or consents where necessary.
Export
Our SOTPs must ensure that their business practices are in accordance with all applicable laws, directives and regulations governing the export of parts, components, and technical data. We require our SOTPs to provide truthful and accurate information and obtain appropriate licenses and/or consents where necessary
Anti-boycott
JetZero will not participate in any unsanctioned economic boycott, in accordance with the U.S. 1977 Export Administration Act and the U.S. 1976 Tax Reform Act, or similar legislation or regulations (the “Acts”). JetZero SOTPs must not participate in, cooperate with, or otherwise agree to do anything in violation of the Acts. SOTPs must not ask JetZero to do anything in violation of the Acts.
Responsible sourcing of minerals
SOTPs must comply with any applicable laws and regulations regarding conflict minerals and assist us in meeting our obligations under law and regulation.
We report annually to the United States Securities and Exchange Commission on our use of conflict minerals (tantalum, tin, tungsten and gold) originating in the Democratic Republic of Congo (DRC) or any of the DRC’s adjoining countries in products manufactured or contracted to be manufactured by the company and are required to conduct due diligence on the use of conflict minerals in our supply chain.
Our SOTPs must support our efforts to conduct due diligence on the use of conflict minerals in our supply chain, including the identification of products in their supply chain that contain conflict minerals and validating the country of origin of these minerals.
Protect information, intellectual property & the supply chain
Confidentiality of sensitive information
SOTPs must maintain the confidentiality of all information entrusted to them by us, our customers or other third parties, except where disclosure is authorized or legally required (and then only after notice).
We require our SOTPs properly to handle and protect from improper disclosure any sensitive information, including classified, controlled, proprietary and personal information; competition sensitive information and intellectual property.
Information should not be used for any purpose (e.g., advertisement, publicity, and the like) other than the business purpose for which it was provided, unless there is prior authorization from the owner. SOTPs must comply with all contractual obligations and applicable laws, including data privacy laws.
Intellectual property
We require our SOTPs to respect and comply with all applicable laws and other binding obligations governing intellectual property rights, including protection against disclosure, patents, copyrights, and trademarks.
Cybersecurity
SOTPs must take care to safeguard and protect information entrusted to them and information generated or developed by them in support of our programs from unauthorized access, destruction, use, modification or disclosure.
We expect SOTPs to have risk-based cybersecurity programs designed to mitigate emerging threats to their information systems, products and services and supply chain and to comply with all applicable contractual and legal requirements.
Security of supply chain
In addition to complying with our security requirements, SOTPs are encouraged to implement practices and procedures to ensure the security of their people, property and other assets, including their supply chain. SOTPs are encouraged to participate in the Customs-Trade Partnership Against Terrorism initiative of the United States Department of Homeland Security.
Maintain accurate records
SOTPs must create and maintain accurate records. All records, regardless of format, made or received as evidence of a business transaction must fully and accurately represent the transaction or event being documented.
When a record is no longer needed to conduct current business, records should still be retained based on the applicable retention requirements. SOTPs must not falsify or provide fraudulent records, billings or other statements to us or our customers.
Maintain a safe & healthy workplace
Health and safety
We require our SOTPs to comply with all applicable health and safety laws, regulations, and directives. SOTPs should protect the health, safety, and welfare of their people, visitors, and others who may be affected by their activities.
Environment and sustainability
Our SOTPs must comply with all applicable environmental laws, regulations, and directives and operate as responsible stewards of the environment.
Ethics program expectations
Compliance whistleblower protection
We require SOTPs to maintain an effective ethics and compliance program and to meet the requirements of this document.
Whistleblower protection
Our SOTPs should provide their employees with avenues for raising legal or ethical issues or concerns without fear of improper retaliation. Our SOTPs should also take action to prevent, detect, and correct any retaliatory actions.
Consequences for violating this code
In the event of a violation of this document, we may pursue corrective action to remedy the situation. In the case of an actual or possible violation of law or regulation, we may be required to report to proper authorities. We reserve the right to terminate our relationship or take any other appropriate action with any SOTP under the terms of the existing contract/transaction.