AVIATION PRODUCTS AND EQUIPMENT MAINTENANCE CORPORATION

No 24 Alley 469/18, Nguyen Trai Street, Thanh Xuan Nam Ward,

Thanh Xuan District, Hanoi City, Vietnam

Date: 10th February, 2018

CODE OF CONDUCT

Introduction

To achieve business goals and achieve business success, APME always strives to maintain
business by ethical values. APME is committed to always conducting business activities by
the highest ethical standards/values and applicable laws and regulations. APME develops a
Code of Conduct to affirm its position with suppliers, customers, employees, and other
partners. This Code of Conduct sets out standards of conduct for APME's suppliers. This
Code of Conduct sets out standards of conduct for APME's suppliers. APME understands
that every supplier is an independent entity, but a supplier's business attitudes and business
practices can affect APME and our customers. This Code of Conduct sets out standards of
conduct for APME's suppliers. For this reason, APME expects suppliers to follow this Code
of Conduct when doing business with APME or on behalf of APME. Suppliers should
ensure that their subcontractors also comply with these standards.
Ethical Audits

APME reserves the right to conduct or authorize third-party audits of suppliers and plants at
any time, with or without prior notice.

Suppliers allow APME's customers to assess the factory to the extent permitted or requested
by the customer as a condition of cooperation with APME.

Suppliers and factories should keep records on-site so that when necessary, compliance with
the requirements of this Code of Conduct and all agreements between APME and suppliers
can be verified. All records must be accurate (i.e.,not intentionally misleading or
misleading) and available upon request from APME reviewers.

Suppliers need to meet the basic conditions within a reasonable time, and this – as a rule –
will be a prerequisite for cooperation with APME. If a supplier does not improve conditions
to make significant progress, APME will consider terminating the business relationship with
that supplier.
Standards - Ethical Standards
The APME Standards of Ethics are established based on crucial documents and agreements
of the United Nations and the International Labor Organization. They are also subject to the
Laws of the host country. When laws and standards for the same content are duplicated, the
highest standard will apply.
1. Forced Labor / Prison Labor
1.1 APME does not accept forced or prison labor. Suppliers must guarantee employment
voluntarily. APME does not receive products from suppliers that use forced or prison labor
in production, subcontracting, or other relationships to manufacture products.
1.2 Employees do not have to pay a “deposit” or identification documents with the employer
and are free to quit after proper notice.
2. Freedom of Association and Right To Collective Bargaining
2.1 All employees have the right to join or form a Trade Union of their own choice and to
bargain collectively. If Law restricts these rights, the Business owner should facilitate, not
hinder, promote similar methods freely and independently for Associations and
negotiations. Individuals representing employees are not discriminated against and are
allowed to exercise their representative role in the workplace.
3. Child Labor
3.1 APME does not accept the use of child labor. Suppliers and factories only employ legal
age employees (in Vietnam 16 years old) or 15 years of age or older if the statutory period is
lower.
3.2 New recruitment of child labor in violation of the above provisions will not be accepted.
If child labor already exists as described above, the situation must be changed as soon as
possible. However, it is necessary to create conditions for these children to enjoy their
childhood and study until the compulsory school age.
3.3 For jobs that require more maturity or have risks to occupational safety, employees must
be at least 18 years old.
4. Discrimination
4.1 Suppliers and factories do not discriminate against employees or job candidates in the
process of hiring, entering into terms of employment, or any other working conditions based
on race, color, or color skin, nationality, gender, religion, age, disability, political
orientation, sexual orientation, social status, marital status, child status, membership in labor
organizations motion, or any similar factor.
4.2 Measures should be established to protect employees from acts of sexual assault,
intimidation, humiliation or exploitation; inappropriate discrimination or dismissal, such as
on the basis of marital status, pregnancy, having small children or HIV infection.
5. No Harsh or Inhuman Treatment
5.1 Suppliers and factories do not use threats of corporal punishment or any form of
psychological abuse or harassment, physical (including sexual) or verbal abuse or
harassment form of threats against employees. Suppliers and factories need to treat
employees with respect and serious.
6. Health and Safety
6.1 Suppliers and factories must ensure a healthy and safe working environment, fully
comply with the safety measures prescribed by law to minimize risks to occupational health
and safety. Suppliers and factories should take appropriate measures to minimize the
hazards present in the work environment.
6.2 Employees must regularly receive training on occupational safety and health. Newly
recruited employees must also be trained in the same way.
6.3 Ensure right access to toilets and clean water. Also, provide hygienic food storage
equipment where possible.
6.4 Housing for employees should be clean, safe, well-ventilated and have toilets and clean
water.
7. Wages and Benefits
7.1 Suppliers and factories must pay employees the minimum wage (1) equal to the
statutory minimum wage or (2) the prevailing wage for the same type of work in the same
industry, or similar industry with the same type of ownership in the same area and must
cover basic needs and provide additional allowances in good faith.
7.2 All employees are provided with a clearly drafted employment contract on salary
conditions and payment methods before signing.
7.3 Wage deductions are not accepted as a disciplinary measure.
7.4 Suppliers and factories must pay employees for statutory holidays and vacations that
apply.
7.5 Suppliers and factories must ensure worker benefits at least those required by applicable
law
8. Working Hours
8.1 Suppliers and factories must comply with local laws and industry standards regarding
working hours.
8.2 Total working hours must not exceed 48 hours/week (8 hours/day).
8.3 Employees must have at least 1 day off in 7 working days.
8.4 Limit overtime. Maximum overtime is 12 hours/week.
8.5 Employees must be paid the minimum overtime pay under applicable law.
9. Regular Employment
9.1 Obligations to employees under international conventions and social security laws,
regulations arising from a stable employment relationship shall not be omitted when using
short-term contracts (such as unskilled or day labor), subcontractors, or other employment
relationships.
9.2 Employees are provided with an employment contract written in a language the worker
must understand.
9.3 The duration and content of apprenticeship programs must be clearly defined.
10. Consideration for Marginalized Populations
10.1 The extraction and use of raw materials for production do not damage the resources
and incomes of people in remote areas, for example requiring large areas of land or other
natural resources in places where the livelihood of the population is dependent.
11. Environmental Protection
11.1 Environmental measures must be considered throughout the entire production and
distribution chain, from raw material production to sales. Local, regional, and global
ecological factors need to be considered. Do not let pollution arise or destroy the
environment in the production area.
11.2 Suppliers and factories must at least comply with the provisions of the Law on
Environmental Protection. In the absence of Regulations, suppliers and factories are
responsible for taking measures to protect the environment.
11.3 Must be authorized to discharge waste in specified areas.
11.4 Strictly manage chemicals and hazardous substances.
12. No Bribery and Corruption
12.1 We expect our suppliers to conduct business ethically and cleanly. Suppliers may not
offer gifts, money, or services to gain an advantage in business cooperation. Suppliers must
not abuse trust to gain an undue advantage in business transactions.
Implementation
If the minimum standards cannot be immediately met or met, the supplier should
continuously improve production conditions. Concerning subcontractors, the supplier
through agreements ensures that the basic objectives are communicated to all subcontractors
and reports on business operations' social issues of subcontractors and require
subcontractors to achieve these objectives within specified time limits.
Supplier Agreement
We require our suppliers to commit to complying with this Code of Conduct in writing.
Signing this document means that your company officially commits to implementing this
Code throughout the production process of products for use at your facility.
The undersigned acknowledges receipt of this Code of Conduct and agrees to abide by the
terms.

(Company name & Chop )

(Job Title - Chức vụ)

(Signature - Kí tên)

(Print name - Họ tên)

(Date - Ngày)