This Supplier Code of Conduct was last updated on 24 July 2023

1. INTRODUCTION
   • This Supplier Code of Conduct (the Code) defines Storm Aviation Limited (including its subsidiaries and their respective subsidiaries) (collectively, Storm Aviation, we or us) expectations of the conduct of suppliers and business partners doing business with Storm Aviation (the suppliers). This Code is based on our corporate values and adheres to the ten principles of the United Nations Global Compact. Suppliers are expected to understand, comply and act consistent with this Code. Storm Aviation expects suppliers will cascade similar expectations through their own supply chains.
   • Storm Aviation endeavours to do business with suppliers that meet our standards. We expect that suppliers will satisfy contractual requirements, comply with laws, regulations, Storm Aviation policies and this Code and act consistently with the principles and values of this Code.
   • This Code represents a minimum standard of best practices. It shall be governed by the law of the relevant contract between Storm Aviation and the supplier (if any). In the event there is no contract, this document shall be applicable to all relationships between the supplier and Storm Aviation and applicable law.
2. HUMAN RIGHTS

We aim to conduct our business operations in a way that seek to respect, protect and promote the full range of human rights. Therefore, we expect all suppliers to have processes in place to prevent, mitigate, and take effective measures to address human rights violations. The suppliers are expected to commit to comply with such internationally recognized standards as the United Nations Guiding Principles on Business and Human Rights, the OECD Guidelines for Multinational Enterprises, the International Labor Organization’s (ILO) Declaration on Fundamental Principles and Rights at Work, and the Universal Declaration of Human Rights.

3. BULLYING & HARRASMENT

We are committed to ensure that the workplace is free from all forms of bullying and harassment, whereby everyone is treated with dignity and respect. Our suppliers must ensure that they recognise the right of everyone to be treated with dignity and respect at work and are committed to ensuring that all their employees are free to do their work without bullying and harassment.

4. EMPLOYMENT, DIVERSITY, INCLUSION & NON-DISCRIMINATION
   • Storm Aviation is committed to promoting equality of opportunity and strive to create a working environment in which all individuals are able to make best use of their skills, free from discrimination or harassment, and in which all decisions are based on merit. As such, we expect our suppliers to commit and promote equality and diversity for all their employees and job applicants and not to discriminate against staff on the basis of age, disability, gender reassignment, marital or civil partner status, pregnancy or maternity, race, colour, nationality, ethnic or national origin, religion or belief, sex or sexual orientation. The principles of non-discrimination and equality of opportunity should also apply to the way in which employees treat visitors, clients, customers, vendors and former employees.
   • Suppliers must also conduct all their operations in a socially responsible, non-discriminatory manner and in full compliance with applicable laws associated with Child Labor, Forced or Compulsory Labor, Working Hours, Compensation, Freedom of Association and Collective Bargaining.
5. HEALTH & SAFETY

We prioritize safety in everything we do and recognise it as a prime consideration for its employees and visitors.  We expect our suppliers to prioritize the occupational health and safety of its employees and others who may be affected by the supplier’s activities and meet legal and regulatory requirements.

6. ENVIRONMENTAL SUSTAINABILITY

Storm Aviation recognises the importance of being a responsible and sustainable business that contributes positively to society and healthy environment. We aim to operate ethically, minimize its environmental impact, and support local communities. We expect suppliers to adhere to this statement as well as all applicable environmental laws, regulations and standards. We also encourage suppliers to implement policies and take measures that aim at reducing the environmental impact of their operations.

7. INFORMATION & DATA PROTECTION
   • Protecting Sensitive, Confidential and Proprietary Information

Suppliers must ensure that all sensitive, confidential and proprietary information is appropriately protected. Suppliers must comply with applicable data privacy laws on the collection, processing and transfer of personal data and information. Suppliers must not use information 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 of the information. Suppliers must protect the sensitive, confidential and proprietary information of others, including personal data/ information, from unauthorized access, destruction, use, modification and disclosure, through appropriate physical and electronic security procedures, including mitigating emerging risk to information systems by implementing appropriate IT cyber security programmes. Suppliers must report any suspected or actual data breach or security incident as soon they are aware to Storm Aviation individual they do business with.

• Intellectual Property

Suppliers must comply with all the applicable laws governing intellectual property rights assertions, including protection against disclosure. Suppliers are expected to ensure that all sensitive, confidential and proprietary information is appropriately protected. In their relationship with Storm Aviation, suppliers must comply with all applicable data privacy laws and regulations.

• Insider Trading

Suppliers and their personnel must not use any material or non-publicly disclosed information obtained in the course of their business relationship with Storm Aviation as the basis for trading or for enabling others to trade in the stock or securities of any company.

• Cyber security

Suppliers shall protect the sensitive, confidential and proprietary information of others, including personal data/information, from unauthorized access, destruction, use, modification and disclosure, through appropriate physical and electronic security procedures, including mitigating emerging risk to information systems by implementing appropriate IT cyber security programmes. Suppliers shall report to Storm Aviation any suspected or actual data breach or security incident as soon they are aware. In order to guarantee the compliance with security requirements, Storm Aviation might carry out audits or send dedicated questionnaires to suppliers.

8. ETHICAL BUSINESS PRACTICES
   • Compliance with applicable Laws, Rules and Regulations
   • Suppliers are required to comply with all applicable laws, ordinances, rules and regulations, obtain all licenses, approvals and permits required by, and pay all taxes, fees, charges, and assessments imposed or enacted by, any governmental authority. The supplier undertakes to comply with all other obligations arising from the laws of the country in which the services/goods are provided, without those set out in this Code being restrictive or exhaustive.
   • Bribery and Anti-Corruption

Bribery and corruption are not accepted in any form. Suppliers (or third parties acting on their behalf) may not make, offer, promise, pay, receive, request or agree to receive, directly or indirectly, any financial or other advantage to any person or entity if it is intended, or could reasonably appear as intended, to influence improper action, obtain or retain business, or secure an improper advantage for Storm Aviation.  

• Conflicts of Interest

We manage business conduct and practices that may pose a conflict among the interests of Storm Aviation, its employees and its suppliers. It is our obligation to be alert to such conflicts and to escalate them as appropriate.  We expect our suppliers to maintain similar principles. Suppliers, their employees and their close persons (including family members) cannot receive improper benefits through their relationship with Storm Aviation or allow other activities to conflict with acting in the best interests of Storm Aviation.

• Whistleblowing

Suppliers can report their concerns relating to Storm Aviation ethical misconduct, such as bribery or other improper payments; potential money laundering or other suspicious activity; or inappropriate conflicts of interest, by clicking here. These reports may be made anonymously and confidentially.