Code of Conduct
Our Mission, Our Vision, and Our Values
Our mission is to provide quality aerospace parts, services, and support that exceed the expectations of our customers worldwide, while also surpassing international regulatory requirements.
Everyday, 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 Logistics everyone should feel comfortable to speak his or her mind, particularly with respect to ethics and safety concerns. Managers have a responsibility to create an open and supportive environment where employees feel comfortable raising such questions. We all benefit tremendously when employees exercise their power to prevent mistakes or wrong-doing by asking the right questions at the right times.
The Company will investigate all reported instances of questionable or unethical behavior as well as any safety concerns that arise. In every instance where improper behavior is found to have 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 ethic 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 conversations they have with their managers will generally remain private. Situations in which managers must share details of a private conversation should be kept to a minimum and on a strict, need-to-know basis, while also delivering transparency when possible. Although confidentiality and transparency should generally be kept, situations may arise where managers have a responsibility to this Company and it's people to disclose information that includes, but not limited to potential harm of themselves, other employees, and/or the Company, or incidents involving characteristics of harassment, discrimination, or retaliation.
Employees are encouraged, in the first instance, to address such issues with their direct manager, as most problems can be resolved swiftly. If for any reason that is not possible or if an employee is not comfortable raising the issue with his or her direct manager any employee may reach out to Human Resources. Additionally, employees may contact Ronda Hudson-Dowding, President and CEO as well as William (Bill) Dowding, Chief Operating Officer as they are both highly receptive in hearing from any of you, regardless of reason.
Build Trust and Credibility
The success of our business is dependent on the trust and confidence we earn from our employees and customers. We gain credibility by adhering to our commitments, displaying honesty and integrity, while also 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 will be judged on what we do. When considering any action, it is wise to ask:
- Will this build trust and credibility for Dow Aero Logistics?
- Will it help create a working environment in which the Company, and its people can succeed over the long-term?
- Is the commitment I am making one I can follow through with?
The only way we will maximize trust and credibility is by answering “yes” to those questions and by working every day to build our trust and credibility.
Respect for the Individual
We all deserve to work in an environment where we are treated with dignity and respect. The Company is committed to creating such an environment because it brings out the full potential in each of us, which in-turn, contributes directly to our business success. We cannot afford to let anyone’s talents go to waste.
The Company is an equal employment opportunity employer and is committed to providing a workplace that is free of harassment and discrimination of all types from abusive to offensive behavior or actions. Any employee who feels harassed or discriminated against should report the incident to Human Resources or to their direct/indirect manager.
Health and Safety
The Company is dedicated to maintaining a healthy environment. An Injury and Illness Prevention Program ("IIPP") has been designed to educate you on safety in the workplace. All employee's are expected to review the IIPP and any supporting health and safety policies associated with an employee's job responsibilities.
The entire team at Dow Aero Logistics employs unrelenting efforts to continuously improve and deliver conforming products and services to our customers – the first time and every time.
With pride and dedication, we deliver to our customers the Power to Soar!
Uphold the Law
The Company’s commitment to integrity begins with complying with laws, rules, and regulations where we do business. Further, each of us must have an understanding of Company policies, laws, rules, and regulations that apply to our specific roles. If we are unsure of whether a contemplated action is permitted by law or Company policy, we should seek the advice from an appropriate source. We are responsible for preventing violations of law and for speaking up if we see possible violations.
Because of the nature of our business, some legal requirements warrant specific mention here:
- All employees shall report health and safety concerns to their direct manager, Human Resources, and/or Environmental Health and Safety (EH&S) to prevent injury to themselves or others in compliance with federal OSHA regulations.
- All employees should report suspicious behavior of fellow coworkers, including managers, to a direct manager or Human Resources when the coworker's behavior leads to the suspicion for the use of drugs and or alcohol in compliance with Federal Aviation Administration (FAA) and Department of Transportation (DOT) regulations.
We are dedicated to ethical, fair, and vigorous competition. We will sell the Company's products and services based on their merit, superior quality, functionality, and competitive pricing. We will make independent pricing and marketing decisions and will not improperly cooperate or coordinate our activities with our competitors. We will not offer or solicit improper payments or gratuities in connection with the purchase of goods or services for the Company or the sales of its products or services, nor will we engage or assist in unlawful boycotts of particular customers.
It is important that we 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
We must avoid any relationship or activity that might impair, or even appear to impair, our ability to make objective and fair decisions when performing our jobs. At times, we may be faced with situations where the business actions we take on behalf of the Company may conflict with our own personal or family interests. We owe a duty to the Company to advance its legitimate interests when the opportunity to do so arises. We must never use Company property or information for personal gain or personally take for ourselves any opportunity that is discovered through our position with the Company. Here are some other ways in which conflicts of interest could arise:
- Being employed (you or a close family member) by, or acting as a consultant to, a competitor or potential competitor, supplier, or contractor, regardless of the nature of the employment, while you are employed with the Company.
- 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 his or her family.
- Accepting gifts, discounts, favors, or services from a customer/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 from management. Before engaging in any activity, transaction, or relationship that might give rise to a conflict of interest, employees must seek review from their direct/indirect manager and/or Human Resources.
Gifts, Gratuities, and Business Courtesies
The Company is committed to competing solely on a merit of our products and services. We should 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. We will neither give nor accept business courtesies that constitute, or could reasonably be perceived as constituting, unfair business inducements that would violate law, regulation or policies of the Company or customers, or would cause embarrassment or reflect negatively on the Company’s reputation.
Accepting Business Courtesies
Most business courtesies offered to us in the course of our employment are offered because of our positions at the Company. We should not feel any entitlement to accept and keep a business courtesy. Although we may not use our position at the Company to obtain business courtesies, and we must never ask for them, we may accept unsolicited business courtesies that promote successful working relationships and good will with the firms that the Company maintains or may establish a business relationship with.
Employees who award contracts or who can influence the allocation of business, who create specifications that result in the placement of business, or who participate in negotiation of contracts must be particularly careful to avoid actions that create the appearance of favoritism or that may adversely affect the Company’s reputation for impartiality and fair-dealing. The prudent course is to refuse a courtesy 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 is the way to obtain Company business.
Meals, Refreshments, and Entertainment
We may accept occasional meals, refreshments, entertainment, and similar business courtesies that are shared with the person who has offered to pay for the meal or entertainment, provided that:
- They are not inappropriately lavish or excessive.
- The courtesies are not frequent and do not reflect a pattern of frequent acceptance of courtesies from the same person or entity.
- The courtesy does not create the appearance of an attempt to influence business decisions, such as accepting courtesies or entertainment from a supplier whose contract is expiring in the near future.
- The employee accepting the business courtesy would not feel uncomfortable discussing the courtesy with his or her manager or co-worker or having the courtesies known by the public.
Employees may accept unsolicited gifts, other than money, 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).
Generally, employees may not accept compensation of any amount, or in any form, from entities with whom the Company does or may do business. Tangible gifts (including tickets to a sporting or entertainment event) that have a market value greater than $100 may not be accepted unless approval is obtained from management.
Employees with questions about accepting business courtesies should talk to their direct/indirect manager or Human Resources.
Offering Business Courtesies
Any employee who offers a business courtesy must assure that it cannot reasonably be interpreted as an attempt to gain an unfair business advantage or otherwise reflect negatively upon the Company. An employee may never use personal funds or resources to do something that cannot be done with Company resources. Accounting for business courtesies must be done in accordance with approved Company procedures.
Other than to our government customers, for whom special rules apply, we may provide non-monetary gifts (i.e., company logo apparel or similar promotional items) to our customers. Further, management may approve other courtesies, including meals, refreshments, or entertainment of reasonable value, provided that:
- The practice does not violate any law or regulation or the standards of conduct of the recipient’s organization.
- The business courtesy is consistent with industry practice, is infrequent in nature, and is not lavish.
- The business courtesy is properly reflected on the books and records of the Company.
Set Metrics and Report Results Accurately
Accurate Public Disclosures
We will make certain that all disclosures made in shared reports and documents are full, fair, accurate, timely, and understandable. This obligation applies to all employees, with any responsibility for the preparation for such reports, including 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 and/or Human Resources if they learn that information in any filing or public communication was untrue or misleading at the time it was made or if subsequent information would affect a similar future filing or public communication.
We create, retain, and dispose of our company records as part of our normal course of business in compliance with all Company policies and guidelines, as well as all regulatory and legal requirements.
All corporate records must be true, accurate, and complete. Company data must be promptly and accurately entered in our books in accordance with the Company’s and other applicable principles.
We must not improperly influence, manipulate, or mislead any unauthorized audit, nor interfere with any auditor engaged to perform an internal independent audit of the Company books, records, processes, or internal controls.
Promote Substance Over Form
At times, we are all faced with decisions we would rather not have to make and issues we would prefer to avoid. Sometimes, we hope that if we avoid confronting a problem, it will simply go away.
At the Company, we must have the courage to tackle the tough decisions and make difficult choices, secure in the knowledge that the Company is committed to doing the right thing. At times this will mean doing more than simply what the law requires. Merely because we can pursue a course of action does not mean we should do so.
Although the Company’s guiding principles cannot address every issue or provide answers to every dilemma, they can define the spirit in which we intend to do business and should guide us in our daily conduct.
Each of us is responsible for knowing and adhering to the values and standards set forth in this Code and for raising questions if we are uncertain about Company policy. If we are concerned whether the standards are being met or are aware of violations of the Code, we shall contact Human Resources.
The Company takes seriously the standards set forth in the Code, and violations are cause for disciplinary action, up to and including termination of employment.
Confidential and Proprietary Information
Integral to the Company’s business success is our protection of confidential company information, as well as non-public information entrusted to us by employees, customers, and other business partners. Confidential and proprietary information includes such things as pricing and financial data, customer names/addresses, or non-public information about other companies, including current or potential supplier and vendors. We will not disclose confidential and non-public information without a valid business purpose and proper authorization.
We will not selectively disclose (whether in one-on-one or small discussions, meetings, presentations, proposals, or otherwise) any material non-public information with respect to the Company, its securities, business operations, plans, financial condition, results of operations, or any development plan. We should be particularly vigilant when making presentations or proposals to customers to ensure that our presentations do not contain material considered non-public information.
Use of Company Resources
Company resources, including time, material, equipment, and information, are provided for Company business use. Nonetheless, occasional personal use is permissible as long as it does not affect job performance or cause a disruption to the workplace.
Employees and those who represent the Company are trusted to behave responsibly and use good judgment to conserve Company resources. Managers are responsible for the resources assigned to their departments and are empowered to resolve issues concerning their proper use.
Generally, we will not use Company equipment such as computers, copiers, and fax machines in the conduct of an outside business or in support of any religious, political, or other outside daily activity, except for company-requested support to non-profit organizations. We will not solicit contributions nor distribute non-work related materials during work hours.
In order to protect the interests of the Company's network 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. We will not tolerate the use of Company resources to create, access, store, print, solicit, or send any materials that are harassing, threatening, abusive, sexually explicit, or otherwise offensive or inappropriate.
Questions about the proper use of company resources should be directed to a direct or indirect manager, Information Technology (where appropriate), and/or Human Resources.
Set the Tone at the Top
Management has the added responsibility for demonstrating, through their actions, the importance of this Code. In any business, ethical and safety-minded behavior does not simply happen; it is the product of clear and direct communication of behavioral expectations, modeled from the top and demonstrated by example. Again and ultimately, our actions are what matters.
To make our Code work, managers must be responsible for promptly addressing questions or concerns raised by employees and for taking the appropriate steps to deal with such issues. Managers should not consider employees’ concerns as threats or challenges to their authority, but rather as another encouraged form of business communication. We shall stride to keep open dialogue a natural part of daily work.
Although the Company is not necessarily considered a highly-publicized Company at this time, employees may still be approached by reporters and other members of the media, from time to time. In order to ensure that we speak with one voice and provide accurate information about the Company, we shall direct all media inquiries to Company ownership. No employee shall issue a press release without first consulting with Company ownership.
Simply, Just Do the Right Thing
In closing, several key questions can help identify situations that may be unethical, inappropriate, or illegal. Ask yourself:
- Is what I am doing comply with the Company's guiding principles, Code of Conduct, and Company policies?
- Have I been asked to misrepresent information or deviate from normal procedure?
- Would I feel comfortable describing my decision at a staff meeting?
- How would it look if it made the headlines?
- Am I being loyal to my family, the Company, and myself?
- What would I tell my child to do?
- Is this the right thing to do?