Code Of Business Ethics Policy

INTEGRITY, ETHICAL PRINCIPLES & THEIR IMPLEMENTATION

INTRODUCTION

Integrity being the firm adherence to correct ethical principles, Global Dynamic Support Limited’s ethical policy is based on the adoption and implementation of Principles of Business Ethics recognised and enunciated by the leading international associations within the Aerospace and Defence Sectors, the ASD (Aerospace and Defence Industries Association of Europe) and, in the USA, the AIA (Aerospace Industries Association).

In particular we model our code upon the ASD’s “Common Industry Standards for Aerospace and Defence” and the “Global Principles of Business Ethics for the Aerospace and Defence Industry” which was released jointly by the AIA and ASD.

COMPLIANCE WITH LAWS AND REGULATIONS

Global Dynamic Support Limited, together with its directors, officers, employees and others acting on their behalf must always and everywhere comply with all applicable laws and regulations of the countries or territories in which they operate, in particular in relation with integrity matters.

COMMUNICATION AND APPLICATION OF ETHICAL CODE

In order to ensure complete adherence to these Ethical Principles, Global Dynamic Support Limited will distribute its Ethical Code internally as well as to its agents and consultants, with a view to its assimilation by individuals. Global Dynamic Support Limited encourages its agents, consultants and business partners to adopt and comply with its principles of Business Ethics.

PROHIBITION OF CORRUPT PRACTICES

As per the ASD Common Industry Standards, “corruption, under the form of offering, promising or giving a bribe or any undue pecuniary or other advantage (active corruption), as well as under the guise of soliciting, demanding or extorting the same (passive corruption), distorts competition in the markets, is a criminal offence and must therefore be unequivocally condemned. Public corruption (bribing of national, foreign or international public officials), as well as private‐to‐private corruption (corruption between private commercial or non-commercial entities), in order to obtain or retain business or other improper advantage (e.g. in connection with regulatory permits, taxation, customs, or judicial and legislative proceedings) must be banned from economic life.”

Global Dynamic Support Limited, its directors, officers, employees and others acting on its behalf therefore abstain in all circumstances from all forms of direct and indirect corruption.

The Company takes, in particular, all reasonable measures within its power to avoid that money or other advantages are illicitly channelled by direct or indirect means to a public official.

GIFTS AND HOSPITALITY

Global Dynamic Support Limited prohibits the provision of a gift or hospitality to a governmental customer or to a public official by way of a business courtesy if:
a) Contrary to the laws and regulations of the country of the recipient;
b) Done with a view to obtaining any improper advantage;
c) Not duly accounted for in the books and records of the giver and in a manner which
permits reasonable traceability.

POLITICAL DONATIONS AND CONTRIBUTIONS

Global Dynamic Support Limited does not make donations or contributions to political parties, party officials, party representatives or candidates.

AGENTS, CONSULTANTS AND INTERMEDIARIES

Assessment of prospective Agents
Global Dynamic Support Limited shall pay therefore particular attention to the integrity profile of a potential agent, consultant or intermediary, before concluding any agreement or dealing in any way with a candidate. We will conduct a thorough due diligence examination, using various information sources and records to assess a candidate’s business and available personal standing; this may include a candidate’s history, education, ethical behaviour, technical and financial background and his or her knowledge of the Company’s environment and products. Such assessment shall be periodically reviewed.

Ensuring awareness of Ethical Principles
The prospective agent, consultant or intermediary shall be made aware of the Global Dynamic Support Limited Ethical Code and the legal provisions containing the incrimination of bribery of foreign public officials pursuant to the 1997 OECD Convention and UNCAC.

Agent Agreements
The agreement concluded in a written form between Global Dynamic Support Limited and the agent, consultant or intermediary shall include a clause whereby the latter commits to comply at all times with the provisions mentioned in previous paragraph and more specifically that no part of any payment originating from Global Dynamic Support Limited will be passed on as a bribe. Breach of this commitment shall entitle us to terminate forthwith the agreement.
The agent, consultant or intermediary shall report to us regularly and on a continuous basis on the accomplishment of his or her tasks and duties.

Agent’s Fees
Fees payable to an agent, consultant or intermediary shall correspond to an appropriate remuneration for legitimate services effectively rendered. No payments shall be made in cash. Payments are made, save in exceptional circumstances, in the country where the agent, consultant or intermediary is active or registered. These payments are properly recorded in our books and records.

Fees can take many forms (marketing fee, support fee, retainer fee or success fee), they can be a fixed amount calculated on an hourly, monthly or yearly basis, or a fixed or variable percentage of the sales to a specified customer or the refunding of expenditure based on vouchers. Whichever form or method used for the fee payable to an agent, consultant or intermediary, it shall be based on the most objective elements possible.

Right to Audit Agents and Intermediaries
Global Dynamic Support Limited shall reserve the right to audit an agent’s books and procedures to ensure that the agents, consultants or intermediaries are complying with their obligations.

MANAGING CONFLICTS OF INTEREST

Global Dynamic Support Limited shall follow all applicable laws, regulations and directives concerning the employment or engagement of public officials including those dealing with conflicts of interest. We will maintain policies to address or mitigate the risk of undue or improper conflicts of interest.

RESPECT FOR PROPRIETARY INFORMATION

Global Dynamic Support Limited shall keep proprietary information of third parties to which they have gained access in accordance with the terms of its disclosure and in strict compliance with all applicable laws and regulations.
We will not solicit or accept a third party’s proprietary information (whether provided by a customer or otherwise), such as bid and proposal information, or technical or price data, unless the owner of the data has agreed to its release. If we receive a third party’s proprietary information without authorization we:
1) shall promptly cease dissemination and review of such information;
2) shall promptly destroy or return such information; and
3) should inform the third party of the incident and their response.

INTEGRITY PROGRAMMES

Global Dynamic Support Limited is committed to implementing its Ethical Code by regularly informing and training its directors, officers and employees regarding changes to and implementation of its ethical code and developments in the field of business ethics, particularly as concerns anti-corruption.
We shall designate suitable personnel responsible for overseeing the compliance with our Ethical Code.
We shall encourage our officers and employees to report all specific concerns they may have in relation to the implementation our Ethical Policy and provide advice and guidance in this respect.

SANCTIONS

Global Dynamic Support Limited shall determine and apply appropriate, proportionate and dissuasive sanctions for evidenced cases of non‐compliance with our Ethical Code.