Version 1.0 – January 2025

1. Introduction

At Airvolute, we are committed to conducting our business responsibly, ethically, and in full compliance with all applicable laws and regulations. As a trusted supplier to the defense and aerospace industry, we recognise that our reputation depends on the integrity of our people, our products, and our business practices.

This Responsible Business Conduct Policy sets out the standards we uphold across our operations and supply chain. It reflects our commitment to human rights, safe working conditions, ethical business practices, environmental responsibility, and community engagement.

2. Human Rights and Fair Employment

Airvolute respects and promotes human rights in all our operations and business relationships.
We are committed to:

• Providing fair employment practices and competitive wages.

• Prohibiting harassment, bullying, discrimination, and retaliation.

• Ensuring all work is voluntary and free from forced, bonded, or trafficked labour.

• Prohibiting child labour in any form.

• Allowing freedom of movement and prohibiting the withholding of personal documents.

• Conducting due diligence to identify and mitigate human rights risks.

3. Inclusion and Equal Opportunity

We strive to create a diverse and inclusive workplace where every employee is respected, valued, and able to contribute fully.
Airvolute provides equal employment opportunities and complies with all relevant laws regarding non-discrimination, diversity, and inclusion.

4. Health, Safety, and Wellbeing

We are committed to providing a safe, healthy, and productive workplace.
Airvolute maintains an occupational health and safety management system designed to:

• Prevent workplace injuries and illnesses.

• Comply with all relevant safety regulations.

• Continuously improve safety practices through training and engagement.

5. Wages, Benefits, and Working Hours

We ensure our employees receive at least the minimum legal wage and all mandated benefits.
We also respect regulated working hours, rest periods, and paid leave, in compliance with applicable laws.

6. Anti-Corruption and Ethical Business Practices

Airvolute maintains a zero-tolerance approach to bribery, corruption, and unethical conduct.
We comply with the UK Bribery Act, the US Foreign Corrupt Practices Act, and all other relevant anti-corruption laws.
Employees and representatives must not offer or accept bribes, improper gifts, or facilitation payments.

All gifts and hospitality must be lawful, proportionate, transparent, and never in cash or cash equivalents.

7. Competition and Fair Trade

We conduct business in accordance with all applicable competition and antitrust laws.
Airvolute does not participate in price-fixing, bid-rigging, or other anti-competitive behaviour.

8. Managing Risk and Record Keeping

We identify and manage risks in our operations and supply chain, including those that could affect product quality or supply continuity.
All business records are to be accurately and securely maintained.

9. Conflicts of Interest and Fraud Prevention

Employees must avoid any actual or perceived conflict between personal interests and company responsibilities.
Any potential conflicts must be disclosed promptly.
Airvolute prohibits all forms of fraud and requires integrity and transparency in every transaction.

10. Trade Compliance and Security

Airvolute complies with all export control, import, and trade sanction regulations.
We implement robust cybersecurity, physical security, and personnel security measures to protect sensitive information, technology, and assets.
Security incidents are to be promptly reported and addressed to maintain operational resilience.

11. Product Quality and Counterfeit Prevention

We are dedicated to producing high-quality, reliable electronic systems.
Airvolute maintains a rigorous quality assurance system focused on defect prevention and continuous improvement.
We procure components only from approved and traceable sources to prevent counterfeit parts from entering our supply chain.

12. Intellectual Property Protection

We respect intellectual property rights and safeguard proprietary and confidential information belonging to Airvolute, our customers, and partners.

13. Environmental Responsibility

Airvolute is committed to minimising the environmental impact of our operations.
We aim to:

• Comply with all environmental laws and standards.

• Reduce waste and emissions.

• Improve energy efficiency.

• Promote responsible material sourcing and recycling.

14. Responsible Sourcing

We ensure that all materials, including minerals, are sourced responsibly and do not contribute to conflict or human rights abuses.
Airvolute performs due diligence on suppliers and expects them to meet equivalent standards.

15. Community and Social Impact

As a small business, we take pride in contributing positively to our local community through responsible employment, apprenticeships, charitable support, and engagement in STEM initiatives that promote skills and education in engineering and technology.

16. Reporting Concerns

Airvolute encourages all employees, suppliers, and partners to raise concerns about unethical behaviour, legal violations, or breaches of this policy.
Reports can be made confidentially to management or via our Ethics Reporting Channel:
info@airvolute.com

Airvolute strictly prohibits retaliation against anyone who raises a concern in good faith.

17. Continuous Improvement

This policy will be reviewed annually and updated as necessary to reflect evolving best practices, regulations, and stakeholder expectations.