Code of Conduct

1. Introduction

In this Code of Conduct for Business Partners (“Code”), MDA SERVICES “Company, “restates its commitment to accountable management and sustainability, including but not limited to, the adoption of best practices and sound behavior, social and environmental issues and minimum standards to be followed by all of its business partners, including its suppliers, service providers, dealers and integrated producers (individually referred to as “Business Partner” and collectively referred to as “Business Partners”).

2. Purpose and Scope

The purpose of this document is to establish guidelines that must be followed by all Business Partners liaising with MDA SERVICES with a view to encouraging and fostering the adoption and fulfillment of all applicable laws, as well as all social and environmental practices applicable to their operations.

This document applies to all MDA SERVICES Business Partners, which is why the guidelines laid down here must be interpreted as part of the agreements signed with the Company.

3. Guidelines

1) Legal Compliance

MDA SERVICES Business Partners must conduct their business in strict compliance with the laws applicable to their business in the countries where they operate.

VI) Employment Contract and Employment Practices

Business Partners must comply with all labor laws applicable. Business Partner employees must be paid and receive benefits as set forth in the applicable laws and in the terms of collective bargaining agreements. They must also make sure they pay all labor taxes, social security contributions and payroll taxes. Business Partners must provide equal conditions of employment, compensation, access to training and workforce promotion opportunities.

VII) Child Labor

Business Partners must make sure they only hire workers at the legal working age and must ensure that their operations are free of sexual exploitation of children, as provided for in the ILO (International Labor Organization) standards and in the principles of the United Nations Global Compact.

VIII) Modern Slavery

Business Partners must not restrict workers’ freedom by withholding documents, subjecting them to exhaustive work routines, physically punishing or harassing them or providing degrading conditions of work and housing — which may characterize forced labor and/or modern slavery. Besides, business partners warrant that they will not use any production units that use slave or unpaid labor.

IX) Discrimination, Diversity and Inclusion

Business Partners must provide a work environment that respects diversity and forbids any sort of discrimination on the grounds of ethnicity, skin color, creed, gender, background, age, sexual orientation, physical or mental disability, pregnancy, marital status, labor union membership, political stance, and others. Besides, they must hire people with disabilities as determined by law.

Il) Anticorruption

Business Partners must comply with all applicable domestic and foreign antibribery and anticorruption laws. Also, they must not offer, pay, request or accept any bribes, including facilitating payments for their own or for MDA SERVICES ‘s benefit. They must also implement preventive mechanisms to address corruption and fraud in their activities.

Ill) Business Integrity

Business Partners must conduct their business with ethics and integrity. They must conduct business and business transactions with integrity and transparency and maintain accurate accounting records strictly complying with all national and foreign laws applicable to fraud prevention and money laundering.

IV) Conflicts of Interest

Business Partners must avoid any transactions, business deals or situations that may generate or characterize conflicts of interest with respect to MDA SERVICES employees. When faced with a conflict-of-interest situation, Partners must report such situation to MDA SERVICES through the Transparency Channel.

V) Legal Competition

Business Partners must compete fairly and conduct their business in line with the principles of fair competition and in compliance with all antitrust laws applicable. They must not allow any exchange of information or deal with any matters that may influence any decisions related to approvals, price quotes, purchases, contracts or termination of existing contracts.

X) Freedom of Association

Business Partners must guarantee the rights of employees to associate with trade associations, trade unions, and to organize themselves into groups of their choice, without retaliation.

XI) Freedom of Expression

Business Partners must respect and encourage all kinds of freedom of expression, provided that exercised with responsibility and ethics and within the legal limits.

XII) Health and Safety

Business Partners must comply with all Occupational Health and Safety laws applicable to their activities and maintain an environment that provides their employees with basic health and safety conditions, as well as provide them with proper training and implement preventive measures against accidents and illness, providing PPE (Personal Protective Equipment) and CPE (Collective Protection Equipment).

XIII) Confidential Information

and Intellectual Property
Information regarding contracts and commercial terms must be treated confidentially and disclosed to third parties only with the express permission of MDA SERVICES ‘s agent and by signing a Non-disclosure Agreement. It is forbidden to use MDA SERVICES ‘s trademarks, logos and any other intellectual property rights in whole or in part without the express prior permission of the teams in charge.

XIV) Environment

Business Partners must comply with the environmental laws and the requirements of the competent agencies, while ensuring, throughout the duration of the partnership, as appropriate: authorizations, licenses, grants, certificates and permits, proper disposal of any waste, packaging and disposable vaccine equipment, medicines, disinfectants, agrochemicals, as well as any other residues, taking full responsibility for their improper disposal and registration of | the property with the CAR (Environmental Registry of Rural Properties) and PRA, required for the regular development of their activities before the relevant local, state and federal authorities. Proof of legal standing must be provided when so requested.

Business Partners undertake to take all necessary measures to prevent and mitigate environmental damage in their activities, otherwise they will be liable for such damage, even if caused by third parties or as a result of acts of God, when they could have been avoided by protective measures that have not been adopted, in which case they will be fully and exclusively responsible for all damage of any amount and nature (especially environmental damage) arising from the partnership. In addition, they undertake to refrain from engaging in deforestation, vegetation suppression without prior authorization of the relevant environmental! authority or use of fire for any purpose.

XV) Animal Welfare

Where applicable to their activities, Business Partners undertake not to mistreat animals and to comply with all laws and technical standards applicable to their entire chain of breeding, keeping and use of wildlife resources, including animal waste management and fulfilment of all public commitments, in which case they may be held liable for any damage caused by failure to follow these principles.

XVI) Subcontracting

The services offered by the Business Partners may only be subcontracted upon express written approval of the MDA SERVICES manager responsible for the contract. Subcontractors must agree upon and comply with the terms of this Code and the Partners must maintain mechanisms to monitor their subcontractors with respect to the guidelines set forth in this Code.

XVII) Audit

MDA SERVICES reserves the right to audit its Business Partners from time to time to make sure that they are complying with the rules set forth in this Code. If any actions or omissions are found to violate any of the provisions laid down herein, MDA SERVICES may require corrective action to be taken by the Partners or terminate the agreement at MDA SERVICES ‘s sole discretion, depending on the severity of the violation.

2) Transparency Channel

The MDA SERVICES Transparency Channel was created for the reporting of potential violations of this Code of Conduct, or any laws or policies, rules and procedures of MDA SERVICES. If a Business Partner notices any infringement caused by the action or omission of any of its employees, competitors or MDA SERVICES employees, it should contact us immediately through:

• Our website: www.md-aviation.com
• Phone number: +962795610161

The Transparency Channel allows reports to be filed anonymously and handled confidentially. MDA SERVICES does not tolerate any form of retaliation against anyone who has filed a report in good faith.