Code of Conduct
Our Mission, Our Vision, and Our Values
Our mission is to provide quality aerospace parts, services, and support that exceed our customers’ expectations worldwide while also surpassing international regulatory requirements. Every day, we are committed to pursuing advancements within every level of our operation, through the development of our people, constant improvement of our worldwide quality standards, along with our significant investments towards future capability endeavors. We are an ever-growing and diversifying family devoted to maintaining and improving a collaborative working environment that allows every member the opportunity for growth and the same level of respect.
A Culture of Open and Honest Communication
At Dow Aero (“Company”) everyone should feel comfortable speaking their mind, particularly concerning ethics and safety concerns. Management is responsible for creating an open and supportive environment where employees feel comfortable raising such questions or concerns. We all benefit when employees exercise their power to prevent mistakes or wrong-doing by asking the right questions and bringing issues to focus at the correct times.
The Company will investigate all reported instances of questionable or unethical behavior and any safety concerns that arise. In every instance where improper conduct has occurred, the Company will take appropriate action. Likewise, the Company shall also review any safety concerns and take appropriate action. We will not tolerate retaliation against employees who raise genuine ethical and safety concerns in good faith.
Confidentiality, where appropriate, is a fundamental aspect of a manager and their employee’s working relationship. Employees should have confidence that the conversations they have with their superiors will generally remain private. Situations in which management must share details of a private chat should be kept to a minimum and on a strict, need-to-know basis while also delivering transparency when possible. Although Company and department leadership should generally preserve confidentiality and openness, situations may arise that necessitates disclosure of information that includes, but is not limited to, the potential harm of themselves, other employees, or the Company, along with incidents involving characteristics of harassment, discrimination, or retaliation.
In the first instance, employees are encouraged to address issues with their direct superior, as they both can resolve most problems swiftly. If it is not possible for any reason, or if not comfortable raising the issue with their direct superior, any employee may reach out to the Company’s Human Resources (“HR”) department. Additionally, employees may contact Ronda Hudson-Dowding, President and CEO, or William (Bill) Dowding, Chief Operating Officer, as they are both highly receptive to hearing from employees, regardless of the reason.
Select here for the Company’s Conflict Resolution Protocol >
Build Trust and Credibility
Our business’s success depends on the trust and confidence we earn from our employees and customers. We gain credibility by adhering to our commitments, displaying honesty and integrity, and reaching company goals solely through honorable conduct. It is easy to say what we must do, but the proof is in our actions. Ultimately, we are judged on what we do, so when considering any measure, it is wise to ask yourself:
Will this build trust and credibility for the Company?
Will it help create a working environment in which the Company, and its people, can succeed over the long-term?
Is the commitment I’m making one that can be achieved?
The only way we will maximize trust and credibility is by answering “yes” to those questions and by working every day to continue building our customers’ trust and gaining credibility.
Respect for the Individual
We all deserve to work in an environment where people are given dignity and respect. The Company is committed to creating such an environment as it brings out the full potential in each of us, contributing directly to our business success. We cannot afford to let anyone’s talents go to waste.
The Company is committed to equal employment opportunity for all of its employees and applicants while providing a workplace free of harassment and discrimination of all types, not limited to abusive/offensive behavior or actions. Any employee who feels harassed or discriminated against should report the incident to their superior or the Human Resources (“HR”) department.
Health and Safety
The Company is committed to maintaining a healthy and safe working environment for all its employees, contractors, and visitors. As part of this continuing and ever-evolving commitment, the Company has committed significant resources to establish an Environmental Health & Safety (“EH&S”) department and the development and maintenance of expansive lists of customized policies and procedures that tightly integrate into our unique work environment’s. Some of the documented policies and procedures enacted by the Company’s EH&S department include:
These policies and procedures exist to educate employees on a wide range of workplace health and safety topics. Employees shall complete required training before performing specific tasks associated with their job responsibilities. Employees must also conduct their duties safely and appropriately at all times.
For questions or to report any safety concerns, employees should contact their direct manager or supervisor, or contact the Company’s EH&S department.
Uphold the Law
The Company’s commitment to integrity begins with complying with the rules, laws, and regulations where we do business. Further, each of us must understand, abide by any applicable Company policies or procedures, statutory laws, and regulatory requirements that apply to our specific duties. If an employee is unsure whether a contemplated action is permitted, they should seek advice from an appropriate source. Employees play a significant role in preventing committed violations (either from themselves or others) and are expected to report possible violations.
Because of the nature of our business, some legal requirements warrant specific mentioning below:
Employees shall report health and safety concerns to a superior, department lead, or personnel within the Company’s Environmental Health & Safety (“EH&S”) or Human Resources (“HR”) departments to prevent injury to themselves or others, in compliance with Occupational Safety and Health Administration (OSHA) regulations.
Employees shall report suspicious behavior of peers, management, contractors, or visitors to a superior or the Company’s HR department when an individual’s behavior leads to the suspicion for the use of drugs and or alcohol, in compliance with Department of Transportation (DOT) and Federal Aviation Administration (FAA) regulations.
Employees shall report suspicious behavior of potential Human Trafficking violations, regardless of who is involved and without fear of retaliation.
If a supplier may be violating Human Trafficking laws, please notify the Company’s Quality Assurance department immediately.
If anyone else may be violating Human Trafficking laws, please notify the Company’s HR department immediately.
You may also report your concerns via the Global Human Trafficking Hotline:
Phone 1.844.888.3733
Email help@befree.org
Additionally, you may contact the National Human Trafficking Hotline:
Phone 1.888.373.7888
Text 233733 (Text "HELP" or "INFO")
Website humantraffickinghotline.org
Select here to learn more about the Company’s Human Trafficking Policy >
Competition
We shall be ethical, fair, and vigorous towards our competition. Employees shall sell the Company’s products and services based on their merit, superior quality, functionality, and competitive pricing. Pricing and marketing decisions shall be made independently, avoiding any improper cooperation or coordination of our activities with competitors. Offers and solicitations of improper payments or gratuities, connected with the purchase or sales of Company products or services, shall not be made. Any engagement or aid in an unlawful boycott of a particular customer shall also not occur.
Proprietary Information
We must respect the property rights of others. We will not acquire or seek to acquire improper means of a competitor’s trade secrets or other proprietary or confidential information. We will not engage in unauthorized use, copying, distribution, or alteration of software or other intellectual property.
Avoid Conflicts of Interest
Employees must avoid, or strictly limit where necessary, any relationship or activity that might impair, or even appear to impair, their ability to make objective and fair decisions when performing job responsibilities. At times, employees may face situations where the business actions they take on behalf of the Company may conflict with their own personal or family interests. Each employee owes a duty to the Company to advance its legitimate interests when an opportunity arises. Employees may not use Company property or information for personal gain or personally take an opportunity discovered through their position with the Company. Here are some other ways in which conflicts of interest could arise:
You are also, or a family member is employed by (or acting as a consultant to) an active/potential competitor, supplier, or contractor, regardless of the employment nature.
Hiring or supervising family members or closely related persons.
Serving as a board member for an outside commercial company or organization.
Owning or having a substantial interest in a competitor, supplier, or contractor.
Having a personal interest, financial interest, or potential gain in any Company transaction.
Placing Company business with a firm owned or controlled by a Company employee or their family member.
Accept gifts, discounts, favors, or services from an active or potential customer, competitor, or supplier unless equally available to all Company employees.
Determining whether a conflict of interest exists is not always easy to do. Employees with a conflict of interest question should seek advice. Before engaging in any activity, transaction, or relationship that might give rise to a conflict of interest, employees shall consult with their superior or the Company’s Human Resources (HR) department.
Business Courtesies
The Company is committed to competing solely on the merit of our products and services. Employees shall avoid any actions that create a perception that favorable treatment of outside entities by the Company was sought, received, or given in exchange for personal business courtesies. Business courtesies include gifts, gratuities, meals, refreshments, entertainment, or other benefits from persons or companies with whom the Company does or may do business. Employees shall neither receive nor award business courtesies that constitute (or that could reasonably be perceived as constituting) unfair business inducements that violate statutory legal or regulatory requirements or Company rules. It can also include situations that can cause embarrassment or reflect negatively on the Company’s reputation.
The prudent course to any business courtesy that would otherwise not be available to others within our organization is to refuse such offerings from a supplier when:
The Company is involved in choosing or reconfirming a supplier; or
Under circumstances that would create an impression that offering courtesies are the way to obtain Company business.
Most business courtesies shown to employees during employment present themselves because of their positions at the Company. No employee should feel any entitlement to accept and keep a business courtesy. Although employees may not use their work at the Company to obtain business courtesies (and must never ask for them), they can be accepted when prior approval is granted from appropriate management.
The following employees must be conscientious about avoiding actions that create the appearance of favoritism to avoid adversely affecting the Company’s reputation for impartiality and fair-dealings:
Those who can award contracts or influence the allocation of business;
Create specifications that result in the placement of; or
That participates in the negotiation of contracts.
Any employee who offers a business courtesy shall assure that it cannot reasonably be perceived as an attempt to gain an unfair business advantage or otherwise reflect negatively upon the Company. An employee may never use their financials or resources to do something that cannot be provided with previously approved Company resources. We may give non-monetary gifts (i.e., company logo apparel or similar promotional items) to our customers, except for our government customers, where special rules apply. Further, management may approve other courtesies, including meals, refreshments, or entertainment of reasonable value, provided that:
The practice does not violate any statutory laws or regulatory requirements, along with the standards of conduct of the recipient’s organization;
The business courtesy is consistent with industry practice, is infrequent, and is not lavish; and
The business courtesy reflects within accounting and other appropriate records for the Company.
Employees with questions about business courtesies should talk to their direct/indirect manager or immediate supervisor or the Company’s Human Resources (“HR”) department.
Meals, Refreshments, and Entertainment
Employees may accept occasional meals, refreshments, entertainment, and similar business courtesies provided that they are not:
Inappropriately lavish or excessive.
e.g., at or below $25.00 per person.
Alcohol is not permitted.
Frequent, or do not reflect a pattern of regular acceptance from the same person or entity.
Influence (or appearance thereof) of business decisions.
e.g., accepting courtesies or entertainment from a supplier whose contract is expiring soon.
It causes un-comfort when discussing with management or a co-worker, or concern if the public knows it.
Gifts
Employees may accept unsolicited items that conform to the reasonable ethical practices of the marketplace, including:
Flowers, fruit baskets, and other modest presents that commemorate a special occasion.
Gifts of nominal value, such as calendars, pens, mugs, caps, and t-shirts (or other novelty, advertising, or promotional items).
Employees may not accept compensation of any amount, or in any form, from entities with whom the Company does or may do business. Employees may not receive tangible gifts (including tickets to a sporting or entertainment event) with a market value greater than $25.00 unless prior approval is granted from appropriate management.
Set Metrics and Report Results Accurately
Accurate Public and Private Disclosures
Where appropriate, some employees shall be responsible for certifying that all public and private disclosures made in shared reports and documents they’ve prepared or contributed to are full, fair, accurate, timely, and understandable. This obligation applies to employees involved in drafting, reviewing, signing, along with certifying the information contained therein. No business goal of any kind is ever an excuse for misrepresenting facts or falsifying records.
Employees should inform appropriate management or the Company’s Human Resources (“HR”) department upon learning of any disclosure being made that contained either untrue or misleading information.
Corporate Recordkeeping
Employees shall properly create, retain, and dispose of Company records as part of our regular business operations. These actions shall remain in compliance with:
Company policies, processes, and guidelines;
Customer, contractor, and supplier relevant agreements or clauses; and
Applicable regulatory and legal requirements.
Corporate records shall be accurate and promptly available while remaining in conformity with the Company’s policies and other applicable principles.
Employee shall not improperly influence, manipulate, or mislead any unauthorized audit, nor interfere with any auditor/inspector engaged to perform an independent internal audit of the Company’s records, processes, or internal controls.
Trustworthy
Confidential and Proprietary Information
Integral to the Company’s business success is the protection of its confidential information, in addition to non-public information entrusted to us by other employees, customers, and other business partners. Private and proprietary information includes pricing and financial data, customer names/addresses, or non-public information about other companies, including current or potential suppliers and vendors. Employees shall never disclose confidential and non-public information without a valid business purpose and proper authorization.
Selective Disclosure
Employees shall not selectively disclose (whether in one-on-one or small discussions, meetings, presentations, proposals, or otherwise) any material non-public information concerning the Company, its securities, business operations, plans, financial condition, operations, or any developments. Employees are to remain particularly vigilant when making presentations or proposals to customers to ensure that any representations do not contain materials considered non-public information.
Use of Company Resources
Company resources, including time, material, equipment, and information, are provided to employees with the key intent for business use. Nonetheless, occasional personal use of Company resources may be permissible as long as job performance is not affected or disruptions to the workplace do not occur. Employees and those who represent the Company are trusted to behave responsibly and use good judgment to conserve these resources. Management is responsible for the resources assigned to their departments or teams and is empowered to resolve proper use issues.
Employees may not use Company equipment, such as computers and printers, to conduct outside business or support any religious, political, or other outside daily activity, except for Company-approved support to non-profit organizations. Employees shall also not solicit contributions, nor distribute non-work related materials, during work hours unless prior approval is granted by appropriate management.
To protect the interests of the Company’s network resources and our fellow employees, the Company reserves the right to monitor or review all data and information contained on an employee’s Company-issued computer or electronic device, along with the use of the internet or the Company’s intranet. Any Company resources used to create, access, store, print, solicit, or send any materials that are harassing, threatening, abusive, sexually explicit, or otherwise offensive or inappropriate shall not be tolerated and can result in disciplinary action to any individual involved, up to immediate termination for severe cases.
For questions about the proper use of Company resources, consult:
An employee’s direct/indirect manager or immediate supervisor;
Company’s Human Resources (HR) department; or
Company’s Information Technology (IT) department where appropriate.
Set the Tone at the Top
Management has the added responsibility for demonstrating, through their actions, the importance of the Company’s policies, processes, guidelines, and principles (including this Code of Conduct). In any business, ethical and safety-minded behavior does not just happen; it is the product of clear and direct communication of behavioral expectations, modeled from the top, and demonstrated by example. Again, actions are what matters.
For the Company’s Code of Conduct to remain effective, management must promptly address questions or concerns raised by employees and take the appropriate steps to deal with such issues. Managers and supervisors should not consider an employee’s good-faith concerns as a threat or challenge to their authority, but rather as another encouraged form of business communication. Strides to maintain open dialogue shall remain a natural part of daily work.
Media Inquiries
Although the Company is not actively considered a highly-publicized organization, employees could still be approached by reporters and other media members on occasion. Media inquiries shall be directed to Company ownership to ensure provided communication is clear and accurate; no employee shall issue a press release without first consulting with Company ownership.
Simply, Do the Right Thing
In closing, several key questions can help identify situations that may be unethical, inappropriate, or illegal. Ask yourself:
Am I complying with the Company’s guiding principles, Code of Conduct, and other Company policies?
Have I been asked to misrepresent information or deviate from the standard procedure?
Would I feel comfortable describing my decision at a staff meeting?
Am I being loyal to my family, the Company, and myself?
How would my actions appear if they made the headlines?
What would I tell my child to do?
Is this the right thing to do?