Atlantic Precision, INC. Supplier Code of Conduct

Overview

Atlantic Precision, Inc., (API) is committed to the highest standards of ethics and business conduct. As stated in our Code of Ethics, API Employees must comply with the law, honor their commitments, act in good faith, uphold API’s values, seek to advance the interests of stakeholders, communicate openly and effectively, and hold themselves accountable.

This Code of Conduct (the “Code”) sets forth our expectations for each of our product and service, and aligns with the expectations we maintain for our own managers, employees and representatives.

General Disclaimer: The expectations set forth in this Code are not intended to conflict with or modify the terms and conditions of customer contracts with API. If a contract requirement is more restrictive than this Code, API must comply with the more restrictive contract requirement. By way of example only, for contracts supporting U.S. Government contracts, the requirements of FAR 52.203-13, Contractor Code of Business Ethics and Conduct, also shall apply.

Compliance with Laws

At a minimum, API must maintain full compliance with all laws and regulations applicable to the operation of business.

Quality & Environmental Health and Safety

API’s products and services must be designed, produced, and delivered with the paramount consideration being the safety and health of our employees and consumers. We will have in place quality assurance processes to detect and communicate to our customers and correct defects to ensure delivery of products and services that meet or exceed contractual quality and legal and regulatory requirements. All required inspection and testing operations must be completed properly by appropriately authorized and qualified individuals, and any required certifications must be completed accurately.

API will not only comply with all applicable environmental, health and safety laws, regulations and directives, but also conduct our operations in a manner that safeguards the environment, minimizes waste, emissions, energy consumption, and the use of materials of concern. API will also assure safe and healthy work environments for our employees and business invitees.

Competition on the Merits and Fair Play

API will compete strictly on the basis of the merits of our products and services.

API will not pay a bribe in any amount, to anyone, anywhere, for any reason whatsoever, whether on API’s behalf, our customers behalf, or on behalf of others.

Accordingly, API will never offer, promise, authorize, or provide, directly or indirectly, anything of value (including business gifts or courtesies) with the intent or effect of inducing anyone (including a customer, employee, or higher tier or sub-tier supplier) to forego their duties and provide unfair business advantage to API, or others. This includes facilitating payments (e.g., payments to expedite or secure performance of a routine governmental action like obtaining a visa or customs clearance).

API will not engage in any anti-competitive conduct for any reason whatsoever, whether on API’s customer’s behalf, our behalf, or on behalf of others. Accordingly, API will never rig bids, fix prices, or allocate customers or markets, or exchange API’s or your competitively sensitive information (e.g., price, cost, output, etc.) with API’s competitors or our customer competitors. API will also refrain from abusing our market power, whether for our benefit or for the benefit of others, by refusing to deal, engaging in predatory or discriminatory pricing practices, conditioning the sale or provision of a particular product or service with that of another product or service, or undertaking similar abusive tactics.

API will not engage in other deceptive or unfair market practices, whether on API’s behalf, your behalf, or on behalf of others. Accordingly, API will never make misrepresentations regarding API’s products or services, your products or services, or the products or services of others. Similarly, API will never denigrate API.’s competitors or your competitors, or their products or services.

Conflict of Interest

API will avoid all conflicts of interest or situations giving the appearance of a conflict of interest in your dealings with API, API will report to API any instances involving actual or apparent conflicts of interest between your interests and those of API., such as when one of your employees (or someone close to one of your employees) has a personal relationship with a API employee who can make decisions impacting your business, or when a API employee has an ownership or financial interest in your business.

International Trade Compliance

API will conduct business in strict compliance with all applicable laws and regulations governing (a) the export, re-export and retransfer of goods, technical data, software and services; (b) import of goods; (c) economic sanctions and embargoes; and (d) U.S. anti-boycott requirements.

Government   Procurement

API will take special care to comply with the unique and special rules that apply to contracting with the U.S. Government. If you support an API contract with the U.S. Government, API will at all times follow the U.S. Government’s rules for competing fairly, honor restrictions applying to U.S. Government employees (e.g., receipt of gifts and employment), deliver products and services that conform to specifications, laws and regulations, adhere to government accounting and pricing requirements, claim only allowable costs, ensure the accuracy of data submitted and comply with all other applicable U.S. Government requirements.

Information Protection

API will respect the legitimate proprietary rights and intellectual property rights of API and others. API will take proper care to protect sensitive information, including confidential, proprietary and personal information. You should not use such information for any purpose other than the business purpose for which it was provided, unless the owner of the information provided prior authorization.

Accuracy of Records and Submissions

API will maintain books and records that accurately and completely reflect all transactions related to API business and each of your submissions to API, its customers, and regulatory authorities must be accurate and complete. API will never make any entry in your books and records or alter, conceal, or destroy any document to misrepresent any fact, circumstance, or transaction related to API business.

Non-Discrimination

API will treat your existing and prospective employees and business partners fairly, based only on merit and other factors related to your legitimate business interests, and without regard to race, religion, color, age, gender, gender identity or expression, sexual orientation, national origin, marital status, veteran status or disability.

Child Labor

API will ensure that child labor is not used in the performance of your work, whether or not related to API business. The term “child” refers to any person under the minimum legal age for employment where the work is performed.

Human Trafficking

API will comply with laws and regulations prohibiting human trafficking. API will not engage in the use of forced labor, bonded labor, indentured labor, involuntary prison labor, slavery or trafficking in persons.

Anonymous Reporting & Reporting Misconduct

API will provide our employees and our business partners with access to adequate reporting channels to raise legal or ethical issues or concerns, including, without limitation, reports of a violation of this Code by API or our business partners, without fear of retaliation, including opportunities for anonymous reporting.

In the event that you become aware of misconduct related to API business undertaken by any API employee, any of our employees, or any employees of our business partners, we expect you to promptly notify UTC. You may contact UTC’s Global Ethics & Compliance Office at bpo@corphq.utc.com, or, if you prefer to contact UTC anonymously, you may use our Ombudsman program (details regarding the Ombudsman program can be accessed at the following site http://www.utc.com/Our-Company!Ethics-And­ Compliance/Pages/Ombudsman-DIALOG.aspx   ).

API must promptly investigate reports of legal or ethical issues or concerns.

Ethics & Compliance Program

Commensurate with the size and nature of our business, API will have management systems, tools and processes in place that (a) ensure compliance with applicable laws, regulations and the requirements set forth in this Code; (b) promote an awareness of and commitment to ethical business practices, including, without limitation, the expectations set forth in this Code; (c) facilitate the timely discovery, investigation, disclosure (to API. and others, as appropriate) and implementation of corrective actions for violations of law, regulations or the expectations set forth in this Code; and (d) provide training to your employees on compliance requirements, including the expectations set forth in this Code.

Your Business Partners

If our contract with our customers prohibits us from assigning, delegating, or subcontracting our obligations, we will strictly comply with this prohibition.

If our contract with our customers permits us to assign, delegate, or subcontract our obligations or procure products or services from others that will be incorporated in products or services acquired by API will carefully select our business partners, and perform due diligence, audit, and oversight to prevent and detect misconduct. API will flow down the principles set forth in this Code to these business partners and we will hold them responsible for ensuring compliance.

Code Compliance

Suppliers will permit API and/or its representatives to assess your compliance with the expectations set forth in this Code in performing work for API including on-site inspection of facilities and review of associated books, records and other documentation. Suppliers will also provide API upon request with additional information and certifications evidencing compliance.

API will ensure that our customers have the right to assess our business partners’ compliance with the expectations set forth in this Code in performing work for API, including on-site inspection of facilities and review of associated books, records and other documentation. API will ensure that our business partners will provide API upon request with additional information and certifications evidencing compliance.

In the event of any wrongdoing, you will fully cooperate with any related investigation conducted by API and will ensure that our business partners also fully cooperate if such investigation involves their performance.

For questions or concerns about this Code, including its application to specific circumstances in connection with your organization ‘s performance of work for UTC, or suspected failures by your organization to satisfy these expectations in performing work for UTC, please contact UTC’s Global Ethics & Compliance Office at bpo@corphq.utc.com, or, if you prefer to contact UTC anonymously, you may use our Ombudsman program (details regarding the Ombudsman program can be accessed at the following site http://www.utc.com/Our-Company!Ethics-And­ Compliance/Pages/Ombudsman-DIALOG.aspx   )