It is AEROCOMPONENTS goal to maintain the highest standards of ethics, professionalism and business conduct as well as to ensure that we act in strict compliance with the law at all times.
We will not tolerate any behaviour or practice that compromises the Company’s integrity or honesty. All decisions will be fair and based on transparent processes.
Since the Company aims to maintain high ethical standards in carrying out its business activities, practices of any sort that are incompatible with AEROCOMPONENTS principles and policies will not be tolerated. Strict adherence to these principles / supporting policies is a condition of employment.
The Managing Director has overall responsibility for ensuring compliance with the objectives of this policy
AEROCOMPONENTS is committed to being fair, transparent and impartial in all of its dealings and our members of staff are expected specific standards of behaviour, namely:
i) All staff are required to act in a way that is unbiased, and they must not be subject to any influence which may lead them to act in a way which favours any particular person or organisation.
ii) Other than the salary paid by AEROCOMPONENTS, employees may not directly or indirectly accept any form of payment or material benefit from third parties for services they perform on behalf of AEROCOMPONENTS.
iii) All staff are required to declare in writing any financial or personal interest, direct or indirect, in another company which is either a supplier to or a competitor of AEROCOMPONENTS.
The Company promotes a working environment which encourages all members of our team to express their concerns about behaviour or decisions that they perceive to be unethical without fear of reprisal or victimisation. Any member of staff who needs guidance or advice on business ethics issues should speak to the Managing Director.
The Managing Director is responsible for initiating and supervising the investigation of all reports of breaches of these principles and policies and ensuring that appropriate disciplinary action is taken when required.
AEROCOMPONENTS is committed to attaining the highest standards of employment practice and wishes to be recognised as a good employer. It is committed to communicating its strategy and objectives to employees and to keeping employees informed on the Company’s progress against the strategy and objectives.
We support and promote the ethos and principles of equal opportunities in employment, striving to create a culture where every member of our team is treated fairly and without fear of harassment or victimization for any reason.
AEROCOMPONENTS will be transparent in all of its operations except where it is constrained by issues of confidentiality.
The Company will strive to communicate clearly and succinctly in order to minimise complexity in our business dealings.
We will comply with the provisions of the Data Protection Act.
All members of staff are required to avoid waste and extravagance and are encouraged to identify improvements to systems and procedures to achieve optimal effectiveness, efficiency and responsiveness.
All employees are expected to follow agreed procurement procedures when commissioning third party services. The Company’s assets and funds may only be used for the legitimate business purposes of AEROCOMPONENTS.
IT systems and electronic information are considered assets and are backed up for retrieval by those Authorised to access them, customer information is also securely backed up and confidential
Information is only available to those authorised in the skills matrix
AEROCOMPONENTS will aim to develop relationships with its suppliers, advisors and agents based on mutual trust and shared values. Therefore:
i) All members of staff will conduct business with suppliers, advisors and agents in a professional manner.
ii) The Company will pay its suppliers, advisers and agents on time and according to agreed terms.
iii) As far as is practicable, we will engage with our business partners on matters relating to Corporate Responsibility.
AEROCOMPONENTS will:
i) Compete in a lawful manner.
ii) Not seek to damage the reputation of competitors, either directly or by implication or innuendo.
iii) Avoid discussing proprietary or confidential information in any contacts with competitors.
iv ) Not attempt to acquire information regarding a competitor’s business by unlawful means, including industrial espionage, hiring competitors’ employees to obtain confidential information, urging competitors’ employees, clients or occupiers to disclose confidential information, or any other approach that is not above board.
AEROCOMPONENTS will:
i) Comply with all laws, rules and government regulations that are applicable to the Company.
ii) Maintain accurate business records, following best practice in all respects.
iii) Maintain financial statements and accounts in a manner that are accurate and auditable.
AEROCOMPONENTS is committed to meeting its contractual commitments and will build relationships with its suppliers, agents and contracted service providers based on mutual trust.
All members of staff are expected to understand and comply with the terms of the contracts for which they have a responsibility.
AEROCOMPONENTS acknowledges the fact that child labour occurs in many countries.
However, AEROCOMPONENTS does not accept child labour, and works actively against it.
The complexity of the child labour issue requires a consistent, long-term effort to create sustainable and broad-based solutions in order to reach our goal; that no products delivered to AEROCOMPONENTS are produced by child labour.
AEROCOMPONENTS respects different cultures and values in countries where AEROCOMPONENTS
Precision Engineering operates and sources its products, but does not compromise on the basic requirements regarding the Rights of the Child.
AEROCOMPONENTS Child Labour Policy has been established in order to make AEROCOMPONENTS
Precision Engineering position clear to suppliers and their co-workers, as well as any other parties. The requirements in this code of conduct are mandatory to all suppliers and their subcontractors.
AEROCOMPONENTS does not accept child labour.
AEROCOMPONENTS supports the United Nations (U.N.) Convention on the Rights of the Child (1989).
AEROCOMPONENTS child labour policy is based on this Convention, which stipulates:
In addition, this policy is based on the International Labour Organisation (ILO) Minimum Age Convention no. 138 (1973). According to this convention, the word “Child” is defined as any person below fifteen (15) years of age, unless local minimum age law stipulates a higher age for work or mandatory schooling, in which case the higher age would apply. If, however, the local minimum working age is set at fourteen (14) years of age in accordance with exceptions for developing countries, the lower age will apply. This Policy also incorporates the ILO Convention on the Worst Forms of Child Labour no. 182 (1999).
All actions to avoid child labour shall be implemented by taking the child’s best interests into account. AEROCOMPONENTS requires that all suppliers shall recognise the U.N.
Convention on the Rights of the Child, and that the suppliers comply with all relevant national and international laws, regulations and provisions applicable in the country of production.
Suppliers are obliged to take the appropriate measures to ensure that no child labour occurs at suppliers’ and their sub-contractors’ places of production.
If child labour is found in any place of production, AEROCOMPONENTS will require the supplier to implement a corrective action plan. If corrective action is not implemented within the agreed time-frame, or if repeated violations occur, AEROCOMPONENTS will terminate all business with the supplier concerned. The corrective action plan shall take the child’s best interests into consideration, i.e. family and social situation and level of education. Care shall be taken not merely to move child labour from one supplier’s workplace to another, but to enable more viable and sustainable alternatives for the child’s development.
The supplier shall effectively communicate to all its sub-contractors, as well as to its own co-workers, the content of AEROCOMPONENTS Child Labour Policy, and ensure that all measures required are implemented accordingly.
AEROCOMPONENTS supports the legal employment of young workers.
Young workers of legal working age have, until the age of 18, the right to be protected from any type of employment or work which, by its nature or the circumstances in which it is carried out, is likely to jeopardise their health, safety or morals.
AEROCOMPONENTS therefore requires all its suppliers to ensure that young workers are treated according to the law; this includes measures to avoid hazardous jobs, night shifts and ensure minimum wages. Limits for working hours and overtime should be set with special consideration to the workers’ young age.
The supplier shall maintain documentation for every worker verifying the worker’s date of birth.
In countries where such official documents are not available, the supplier must use appropriate assessment methods as per local practice and law.
All suppliers are obliged to keep AEROCOMPONENTS informed at all times about all places of production (including their sub-contractors). Any undisclosed production centres found would constitute a violation of this code of conduct.
Through the General Purchasing Conditions for the supply of products to AEROCOMPONENTS
AEROCOMPONENTS has reserved the right to make unannounced visits at any time to all places of production (including their sub-contractors) for goods intended for supply to AEROCOMPONENTS. AEROCOMPONENTS furthermore reserves the right to assign, at its sole discretion, an independent third party to conduct inspections in order to ensure compliance with AEROCOMPONENTS Child Labour policy.
If child labour is found in the supply chains of AEROCOMPONENTS, it will seek to work in partnership with the supplier and appropriately qualified organisations to develop a responsible solution that is in the best long-term interests of the children. The supplier and AEROCOMPONENTS Precision Engineering will agree a corrective action plan, which may comprise the following actions:
Such actions will be considered by AEROCOMPONENTS as evidence that the supplier is not committed to child labour remediation, in breach of this Child Labour Policy.
To preclude the introduction of counterfeit product into our supply chain through strict avoidance, mitigation, and disposition processes.
AEROCOMPONENTS Ltd purchases material, measuring equipment etc from authorized manufacturers and suppliers.
AEROCOMPONENTS Ltd maintains traceability of purchases from Suppliers, retaining the original purchase orders and other receiving documentation, including manufacturers’ Certificate of Conformance, for the required document retention periods.
The disposition of any products returned by our customers will be identified. Any product that is deemed to be defective and not recoverable will be disposed of in accordance with the company procedure. We will only use authorised scrap metal merchants to ensure no defective product is returned to the supply chain
All our employees involved in the purchasing of goods have been informed about the potential for Counterfeit, Fraudulent and Suspect Items, and advised that all goods must be purchased directly from the manufacturers or from agreed and official distribution channels.
It is the policy of AEROCOMPONENTS Limited (the Firm) to conduct business in an honest and ethical manner. As part of that, the Firm takes a zero-tolerance approach to bribery and corruption and is committed to acting professionally, fairly and with integrity in all its business dealings and relationships, wherever it operates, and implementing and enforcing effective systems to counter bribery.
The Firm will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which it conducts business, including, in the UK, the Bribery Act 2010 (the Act), which applies to conduct both in the UK and abroad.
This policy applies to all individuals working for or on behalf of the Firm at all levels and grades, whether permanent, fixed-term or temporary, and wherever located, including consultants, contractors, seconded staff, casual staff, agency staff, volunteers, agents, sponsors and any other person who performs services for or on behalf of the Firm, (collectively referred to as Workers in this policy).
In this policy, Third Party means any individual or organisation that Workers come into contact with during the course of work and the running of the Firm’s business, and includes actual and potential clients, intermediaries, referrers of work, suppliers, distributors, business contacts, agents, advisers, government and public bodies (including their advisers, Centatives and officials), politicians and political parties.
A bribe is an inducement or reward offered, promised or provided in order to improperly gain any commercial, contractual, regulatory or personal advantage, which may constitute an offence under the Act, namely:
The Firm may also be liable under the Act if it fails to prevent bribery by an associated person (including, but not limited to Workers) for the Firm’s benefit.
This policy does not prohibit normal and appropriate gifts and hospitality (given and received) to or from Third Parties unless otherwise specifically stated. However, we have specific internal policies which provide guidance to Workers as to what is to be regarded as normal and appropriate gifts and hospitality in terms of financial limits, subject to the principles set out below (the Overriding Principles), namely that any gift or hospitality:
The Firm appreciates that the practice of giving business gifts varies between countries and regions and what may be normal and acceptable in one region may not be in another. The test to be applied is whether in all the circumstances the gift or hospitality is reasonable and justifiable both in the UK and any other relevant country. The intention behind the gift should always be considered.
It is not acceptable for any Worker (or someone on their behalf) to:
We do not make, and will not accept, facilitation payments or “kickbacks” of any kind, such as small, unofficial payments made to secure or expedite a routine government action by a government official, or payments made in return for a business favour or advantage.
The Firm only makes charitable donations and provides sponsorship that are legal and ethical under local laws and practices and which are in accordance with the Firm’s internal policies and procedures.
The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for us or under our control. All Workers are required to avoid any activity that might lead to, or suggest, a breach of this policy
Workers are required to notify the Firm as soon as possible if it is believed or suspected that a conflict with this policy has occurred, or may occur in the future, or if they are offered a bribe, are asked to make one, suspect that this may happen in the future, or believe that they are a victim of another form of unlawful activity.
Any employee who breaches this policy may face disciplinary action.
All Policies approved Simon Rose July 23
Reviewed and updated Jim Ledger Sept 24