Code of Conduct for suppliers

Introduction

Airgrup considers its suppliers and collaborators a fundamental part of its growth; therefore, it is committed to maintaining solid, ethical, and responsible commercial relationships with all members of its supply chain. The Code of Conduct for Suppliers is understood as an extension of the Airgrup Code of Conduct and aims to establish the guidelines that must govern the ethical behavior of all suppliers and external collaborators who maintain or will establish a commercial relationship with Airgrup, regardless of the type of agreement, nationality, or location where the activity takes place.

The supplier will be responsible for ensuring that the collaborators they work with also respect the principles established in this Code by communicating its content and monitoring its compliance. Likewise, Airgrup undertakes the commitment to communicate and disseminate the Code of Conduct for Suppliers among its suppliers and external collaborators.

The conduct criteria contained in this Code do not intend to cover all situations that suppliers and external collaborators may encounter but rather establish general guidelines to guide their behavior during their professional activity.

Ultimately, compliance with this Code of Conduct is a fundamental requirement for the selection and evaluation of suppliers and external collaborators, being an essential criterion for integration within Airgrup’s supply network.

General Principles

Human Rights

We require our suppliers and external collaborators to respect and protect internationally recognized human rights as set forth in the International Bill of Human Rights in all their operations, activities, and supply chain.

The OIT Declaration on Fundamental Principles and Rights at Work represents the commitment of governments, organizations, and workers to respect and uphold fundamental human values essential to our economic and social lives.

Suppliers and external collaborators will observe and ensure at all times the fulfillment of human rights, especially those related to the ILO Declaration:

• Freedom of association, freedom of assembly, and effective recognition of the right to collective bargaining.
• Elimination of all forms of forced or compulsory labor.
• Effective abolition of child labor.
• Elimination of discrimination in employment and occupation.
• A safe and healthy working environment.

Our suppliers and external collaborators will maintain zero tolerance for any form of human rights violations within our supply chain.

Principle of Legality and Integrity

Our suppliers and external collaborators will operate in compliance with the laws and regulations in force in the locations where their activities are carried out, always acting within the legal framework and conducting themselves with honesty, ethics, and consistency in all their actions. They will also provide the necessary means for their professionals to be aware of the regulations applicable to their activities and will establish internal control models to ensure compliance with legality and ethical values.

Environmental Responsibility

Preserving the environment is one of our fundamental principles; therefore, our suppliers and external collaborators will actively manage environmental risks and implement sustainable practices in their operations, products, and supply chain, as well as establish an appropriate environmental management system (such as ISO 14001 or equivalent) that includes policies to manage their environmental performance, integrating environmental aspects into product or service design.

• Management of substances and chemicals: Suppliers and external collaborators will communicate to Airgrup the environmental, health, and safety aspects of their products and comply with requirements related to the products and/or services they offer. They will also anticipate potential future regulatory restrictions on certain chemical substances to ensure supply continuity.
• Sustainable products and processes: Suppliers and external collaborators will support Airgrup’s sustainability strategy and do everything possible to minimize the environmental impact of their services and products. Suppliers are expected to reduce their climate impact, optimize resource use, minimize waste and hazardous materials, and manage emissions responsibly.

Occupational Health and Safety

We consider safety a responsibility and a condition of employment; therefore, we require our suppliers and external collaborators to integrate prevention policies into their production processes, providing a healthy, safe, and risk-free work environment for all their professionals and collaborators by eliminating unsafe behaviors that could cause serious harm to people and/or facilities

Rules of Conduct

Promotion of a Good Organizational Culture

Airgrup considers its corporate image and reputation as one of its most valuable assets to maintain the trust of its customers, professionals, suppliers, authorities, and society in general. Therefore, suppliers and external collaborators will act responsibly, respectfully, and consistently, taking maximum care to preserve Airgrup’s image and reputation in all their professional actions.

Personal Data Protection

Our suppliers and external collaborators will ensure the proper protection of sensitive or confidential information, respect the right to privacy, and comply with data protection regulations, promoting a culture of responsibility with such information. Any data breach incident will be reported immediately to Airgrup.

Against Corruption and Bribery

Our suppliers and external collaborators reject all forms of corruption, bribery, and influence peddling. They will conduct due diligence to prevent and detect corruption in their commercial agreements. Likewise, they will neither accept nor offer or grant, directly or indirectly, gifts or compensations aimed at improperly influencing their commercial, professional, or administrative relationships, both with Airgrup and with other public or private entities.

Conflict of Interest Management

Airgrup considers that relationships with suppliers or external collaborators should be based on loyalty arising from shared interests. Therefore, they will guarantee impartiality and integrity in the performance of their professional responsibilities and decisions so that personal, family, or commercial interests do not influence them. They will avoid situations that could lead to a conflict of interest, ensuring the independence of their actions and immediately notifying Airgrup of any potential or actual conflict.

Intellectual and Industrial Property

Suppliers and external collaborators will protect both Airgrup’s intellectual property and that of other organizations, complying with laws related to intellectual property rights and guaranteeing the protection of such information. Additionally, in their relationships with third parties, they will strictly follow norms and procedures in this area to avoid infringing on third-party rights.

Fair Competition

Airgrup competes fairly in the market, does not tolerate deceptive, fraudulent, or malicious conduct, and uses confidential information from other companies, customers, or suppliers appropriately to avoid distorting the supply and demand balance that leads the organization to unfair advantages. Therefore, suppliers and external collaborators will act with integrity, avoiding participation in anti-competitive or fraudulent agreements.

Against Money Laundering and Tax Evasion

Suppliers and external collaborators will strictly comply with all applicable laws in the fight against money laundering, maintaining commercial relationships only with clients, suppliers, and third parties that operate within the framework of legal commercial activities, rejecting any practices contributing to tax evasion.

Product Safety

The commitment with Airgrup is to offer the highest quality standards; therefore, suppliers and external collaborators will guarantee the safety of supplied parts, and it is essential that any damage be reported immediately to avoid additional risks.

Global trade

• Imports and exports: Suppliers and external collaborators will ensure that their commercial practices comply with all applicable laws, directives, and regulations for importing parts, components, technical data, and services, as well as for export control.
• Conflict minerals: Suppliers and external collaborators will comply with current regulations regarding the sourcing, both direct and indirect, of conflict minerals such as tin, tantalum, tungsten, and gold. They must ensure these minerals are responsibly sourced and provide Airgrup with the necessary information to guarantee their traceability and origin.
• Counterfeit parts: Suppliers and external collaborators will implement effective processes to minimize the risk of counterfeit parts and materials, including detection, reporting, and isolation, as well as preventing their return to the supply chain. If counterfeiting is detected or suspected, it will be immediately reported to Airgrup.

Supplier Commitment

All suppliers and external partners shall formalize their commitment to comply with the Airgrup Supplier Code of Conduct by accepting the contract/order:

"Airgrup is committed to maintaining the highest standards of ethics, integrity, and responsibility in all its operations and professional relationships, with the aim of establishing and sustaining solid and sustainable commercial relationships. In this context, Airgrup publishes this Code of Conduct for Suppliers, which establishes the minimum principles of ethical, social, and environmental conduct that all suppliers must know and adopt to collaborate with Airgrup. The Supplier expressly commits to knowing and complying with the principles set forth in this Code, disseminating its content among all its personnel and members of its supply chain involved in any aspect of the relationship with Airgrup, and ensuring compliance by them. Acceptance of the content of the Supplier Code of Conduct is considered complete and without reservations. The Supplier’s commitment will cover the entire commercial relationship with Airgrup, integrating into all business practices carried out within that framework. Non-compliance with the provisions contained in the Code may result in various consequences, which may include termination of the commercial relationship or review of their status as an Airgrup supplier."