Supplier Code of Conduct

AAI Supplier Code of Conduct Overview

AAI is committed to ethical business conduct and the highest standards in social and environmental responsibility. This Code of Conduct sets forth AAI’s key expectations for AAI suppliers regarding labor and human rights, environmental issues, ethical responsibility and management systems. All AAI suppliers are expected to meet these code of conduct policies and comply with all applicable laws and regulations.AAI suppliers will maintain management system to ensure: (a) compliance with applicable laws, regulations and customer requirements; (b) conformance with this AAI code of conduct; and (c) identification and mitigation of operational risks to facilitate risk control and continual improvement.

AAI Supplier Labor Policy

1. Anti – Discrimination:
   In hiring and employment practices, AAI suppliers must not engage in discriminatory practices against any worker based on race, religion, creed, color, national origin, sex, sexual orientation (including gender identity), marital status, age, physical or mental disability, medical condition, genetic information, ancestry, veteran status, or any other characteristic protected by law.
2. Anti – Harassment:
   AAI suppliers must treat all workers humanely and with respect and commit to a workplace free of harassment. Suppliers may not subject workers to corporal punishment, physical, sexual, psychological, or verbal harassment. Suppliers may not threaten workers with monetary fines as a means of discipline.
3. Child Labor:
   AAI suppliers must not employ child labor in manufacturing. In the absence of local law, suppliers shall not employ workers under 15 year of age. Further, workers under the age of 18 years of age shall not be required to perform work likely to jeopardize their health, or safety, including night shifts and overtime.
4. Forced Labor and Human Trafficking:
   AAI suppliers must not participate in any form of slave, forced, bonded, indentured, or prison labor. Suppliers must not participate in human trafficking, or any form of involuntary labor, including but not limited to the transportation, recruitment, and employment of individuals by means of threat, fraud, abduction, or payments to any individual having control over another individual for the purpose of exploitation or abuse. Suppliers must ensure that workers have access to their government-issued identification, work related and travel documents. Suppliers must not require workers to deposit money to access such documents. Workers must be allowed to resign their employment in accordance with local and national employment laws or regulations.
5. Third Party Employment Agencies:
   AAI suppliers must ensure that third party recruitment agencies are compliant with the provisions of this Code of Conduct and legal requirements and be responsible for any payment for all recruitment-related fees and expenses. If such fees are found to have been paid by the workers, they must be repaid to the workers.
6. Compensation, Benefits, and Working Hours:
   AAI suppliers must comply with all applicable wage laws, including those relating to minimum wages, overtime hours and legally mandated benefits. Employees must compensate workers for overtime work at pay rates greater than regular hourly rates. All workers must be provided with written information about their employment conditions in a language that is understandable to them. Suppliers are not permitted to deduct wages as a disciplinary measure, nor will any deductions from wages not provided for by national or local law be permitted without express, written permission of the worker concerned. All temporary and outsourced labor shall be within the limits of the local law. Working hours are not to exceed the maximum set by local law. A workweek should not be more than 60 hours per week, including overtime, except in emergency or unusual situations. Workers must be allowed at least one day off every seven days. Employees must follow all applicable laws and regulations regarding working hours and days off. All overtime must be voluntary.
7. Freedom of Association:
   In conformance with local law, AAI suppliers must respect the right of all workers to associate with others, form and join, (or refrain from joining), organizations of their own choosing, and bargain collectively, without fear of interference, discrimination, retaliation, or harassment.

AAI Supplier Health, Safety and Environmental Policy

AAI Suppliers are expected to provide workers with a safe and healthy work environment. Suppliers must take proactive measures to minimize the incidence of work-related injury and illness by integrating prudent health and safety management practices into their business.

1. Occupational Health & Safety:
   Suppliers must identify, assess, and manage occupational health and safety hazards through proper design, engineering and administrative controls, preventative maintenance and safety training.
2. Working and Living Conditions:
   Suppliers must provide workers with reasonably accessible clean toilet facilities, potable water and sanitary food preparation, storage, and eating facilities. Any worker dormitories provided by the Supplier or a third-party must be maintained clean and safe, and provided with reasonable living space.
3. Health and Safety Communication:
   Suppliers must provide workers with appropriate workplace health and safety information and training in their local or primary language. Health and safety related information should be clearly posted in the facility. As part of the communication and awareness, workers must be encouraged to raise safety concerns.
4. Environment, Environmental Permits and Reporting
   Suppliers must be committed to sustainability in its operations. Suppliers are to comply with all applicable environmental laws and regulations regarding hazardous materials, air emissions, waste, and wastewater discharges, including (as applicable) the manufacture, transportation, storage, disposal, and release to the environment of such materials. All required environmental permits registrations are to be obtained, maintained and kept current including operational and reporting requirements.
   

AAI Supplier Ethics Policy

AAI Suppliers are expected to uphold the highest standards of ethics including:

1. Business Integrity
   The highest standards of integrity are to be upheld in all business interactions and suppliers shall have a zero-tolerance policy to prohibit any and all forms of bribery, corruption, extortion and embezzlement. Standards of fair business, advertising and competition are to be upheld. All business dealings should be transparently performed and accurately reflected in business records. Falsification of records or misrepresentation of conditions or practices in the supply chain are unacceptable. Disclosure of information is to be in accordance with applicable laws and regulations.
2. No Improper Advantage
   Bribes or other means (e.g. gifts, etc.) of obtaining undue or improper advantage are not to be promised, offered, authorized, given or accepted by AAI suppliers. This prohibition covers promising, offering, authorizing, giving or accepting anything of value, either directly or indirectly through a third party, in order to obtain or retain business, direct business to any person, or otherwise gain an improper advantage. Bribes, kickbacks and similar payments are strictly forbidden. These payments are prohibited even when local laws may allow such activity.
3. Intellectual Property
   Intellectual property rights are to be respected by AAI suppliers; transfer of technology and know- how is to be done in a manner that protects intellectual property rights; and customer and supplier information is to be safeguarded.
4. Conflict of Interest
   In conduct of business with AAI, Suppliers must avoid actual or appearance of conflicts of interests with AAI.
5. Responsible Sourcing of Minerals
   AAI Suppliers must exercise due diligence on the materials in their supply chains, to include developing policies and procedures to identify applicable risks and take appropriate steps as necessary to mitigate them. Suppliers are expected to supply conflict-free materials and products. Suppliers must reasonably ensure that their products do not directly or indirectly finance, or benefit armed groups or contribute to serious human rights abuses, or severe health and safety risks and negative environmental impacts.
6. Privacy
   AAI suppliers are committed to protecting the reasonable privacy expectations of personal information of everyone they do business with, including suppliers, customers, consumers and employees. Suppliers are to comply with privacy and information security laws and regulatory requirements when personal information is collected, stored, processed, transmitted, and shared.
7. Reporting Concerns & Non-Retaliation
   AAI suppliers must provide an anonymous complaint mechanism for employees, agents, and subcontractors to report grievances. Supplier must protect whistleblower confidentiality and prohibit retaliation.
   • Ref: Whistleblower: Any person who makes a disclosure about improper conduct by an employee or officer of a company, or by a public official or official body.