OUR CODE OF ETHICS

Air One Aviation and all the members of its management team are committed to complying with all laws, rules and regulations, applicable with our business, whether in the country of establishment or in the country of operation or other laws applicable to the industry. The Management is hereby addressing all major laws, rules & regulation applicable but still there might be some areas which are left unintended. It is responsibility of each and every employee and associate to have knowledge of the law and he/she should follow the law in later spirit. It is the responsibility of every employee and associates to report any violations of the law.

The Employee agrees that there are no contracts, restrictions or other matters which would interfere with their ability to discharge their obligations under this agreement. If, while performing their duties and responsibilities under this agreement, the Employee becomes aware of any potential or actual conflict between their interests and those of the Employer, then the Employee shall immedi­ately inform the Employer. Where the Employer forms the view that such a conflict does or could exist, it may direct the Employee to take action(s) to resolve that conflict, and the Employee shall comply with that instruction. When acting in their capacity as an Employee, the Employee shall not, ei­ther directly or indirectly, receive or accept for their own benefit or the benefit of any person or en­tity, other than the Employer, any gratuity, emolument, or payment of any kind from any person having or intending to have any business with the Employer.

All due care should be taken to clarify the type of conflict that the Employer would consider re­quires discussion under this clause. It does not give the Employer unlimited ability to restrict the activities of an Employee, and advice should be sought where the Employer considers taking any action against the Employee as a result of any declared or undeclared conflict.

The Employee shall not, whether during the currency of his/her employment or after its termination, for whatever reason, use, disclose or distribute to any person or entity, otherwise than as necessary for the proper performance of their duties and responsibilities under this agreement, or as required by law, any confidential information, messages, data or trade secrets acquired by the Employee in the course of performing their services under this agreement. This includes, but is not limited to, information about the Employer’s business.

All work produced for the Employer by the Employee under this agreement or otherwise and the right to the copyright and all other intellectual property in all such work is to be the sole property of the Employer.

Air One Aviation and its affiliated entities are committed to doing business with integrity and the highest anti-corruption standards. All Air One Aviation employees, partners and suppliers are expected to conduct themselves with honesty, fairness and high ethical stan­dards, as well as abide by all anti-corruption/bribery laws and avoid even the perception of impropriety or a conflict of interest.

The policy applies to the entire Air One Aviation workforce, operations, subsidiaries and affiliates, in terms of all dealings and transactions in all countries where Air One Aviation is present. The Air One Aviation workforce, including others acting on behalf of Air One Aviation, are required to read, understand, and abide by this policy. In addition. Air One Aviation managers are required to enforce the policy and ensure that people and entities for which they are responsible understand and adhere to this policy.

In practice, the words “bribery” and “corruption” are generally used interchangeably. Corruption is defined as the misuse of power by someone to whom it has been entrusted, for their own private gain. The most common form of corruption is bribery, which is the giving or receiving of money, a gift or other advantage as an inducement to do something that is dis­honest, illegal or a breach of trust in the course of doing business. The anti-corruption laws prohibit an offer, payment, promise to pay or authorisation of payment of any money, gift, or anything of value to any government official for purposes of: – influencing any act or decision of the government official, – inducing him or her to do any act in violation of his or her lawful duties, – securing an improper advantage, or – inducing him or her to use his or her influence with a govern­mental agency, in order to assist in obtaining or retaining business or to direct business to anyone.

The “obtaining or retaining business” element is interpreted broadly to include business advantages, such as obtaining a permit or a tax break. In addition, according to the laws applicable in some countries, such as those that have ratified the Criminal Law Convention on Corruption of the Council of Europe, corruption is considered a criminal offence even in the event that the payment of a bribe would not be made in order to assist in obtaining or retaining business. In other words, the act of corrupting someone in order to induce him or her to act or refrain from acting in the exercise of his or her func­tions is considered a criminal offence. This means that unlike the US FCPA, the law of those countries makes no exemp­tion for the so-called facilitation payments.

Air One Aviation will seek to secure business from customers on the basis of having a “better product for a better price”. Our Employees shall not, directly or indirectly, offer bribes, kickbacks or other similar payments, or promise any other improper bene­fit for the purpose of influencing any customer, supplier, public official or any other person. Similarly, our Employees are prohibited from, directly or indirectly, accepting bribes, kickbacks or any other improper benefit which could influence or appear to influence them in the performance of their duties, provided that any payments which are permissible under ap­plicable law are not prohibited under this Code. Reasonable business entertainment and gifts or favours of nominal value or those which are appropriate in the circumstances will not be considered a breach of our commitment to fair dealing, as long as such entertainment or gifts are consistent with business practice, not intended as an inducement, not contrary to applicable law and will not embarrass us or our employees if disclosed publicly.

Facilitation payments are a form of bribery where {i) the sum involved is minor and paid to a low level official and (ii) the payment is made to secure an action or service to which an individual or company is routinely and legally entitled {e.g. routine processing of government papers such as a visa).

It is the policy of Air One Aviation to refrain from making any corrupt payments, including facilitation payments.

Air One Aviation firmly believes in conducting business with integrity, fairness and respect in all countries where we compete. Our Em­ployees shall respect and act in a manner sensitive to the cultures and customs of the countries in which we operate as well as the communities and environment where we conduct business.

Policy Statement

Air One Aviation is committed to equal opportunities for all. The Company values the individual contribution of all staff. All job applicants and staff will receive equal treatment regardless of sex, marital status, disability, race, colour, religion, age, sexual orientation, and nationality, ethnic or national origins.

What does this mean in practice?

The Company’s aim is that its staff are recruited, selected, trained and promoted on objective grounds, i.e. on the basis of their ability, skills and aptitudes and on the basis of the requirement of their jobs, which will enable the Company to make full use of the talents of its staff and demonstrate its commitment to be an equal opportunities employer.

Who is responsible for ensuring that the policy is implemented?

Each one of us is responsible for ensuring that our behavior is not discriminatory and that we follow the Company’s Equal Opportunities Policy and play our part in achieving its objectives. The Company’s Management takes overall responsibili­ty for implementation of the policy and will ensure that any staff who feel that they have not been treated in accordance with the policy have appropriate means of redress

Harassment is unwelcome verbal or physical conduct prohibited by law directed toward, or differential treatment of, an Employee because of his/her membership in any protected group or on any other prohibited basis (e.g., race, gender and/or gender identity or expression, color, creed, religion, age, national origin, ethnicity, disability, veteran or military sta­tus, sex, sexual orientation, pregnancy, genetic information, marital status or citizenship status.

The harasser can be the Employee’s supervisor, a supervisor in another area, a co-worker, or someone who is not an employee of the company, such as a client or customer.

A hostile work environment results from harassing conduct that has the purpose or effect of unreasonably interfering with an employee’s work performance, or creates an intimidating, hostile or offensive working environment.

Sexual harassment is a form of harassment that consists of making unwelcome sexual advances or requests for sexual favors, or engaging in other verbal or physical acts of a sexual or sex-based nature where such conduct interferes with the employee’s work performance or creates an intimidating, hostile or offensive working environment.

Sexual harassment may also occur where a supervisor/manager demands that an employee/subordinate satisfy sexual demands in order to receive job benefits, to continue employment, or as a basis for making any other employment deci­sion. Such sexual harassment occurs between a manager/supervisor and an employee due to the nature of the manager/subordinate relationship. A manager/supervisor for this purpose is someone who can affect or impact an em­ployee’s terms, conditions, or privileges of employment because he/she can take or impact action such as hiring, firing, promoting, disciplining, scheduling, training, or deciding how to compensate that employee.

Retaliation is any adverse action taken against an individual (applicant or employee) because he or she filed a charge of discrimination, complained to the Company or a government agency about discrimination on the job, or participated in an employment discrimination proceeding (such as an internal investigation or lawsuit), including as a witness. Retaliation also includes adverse action taken against someone who is associated with the individual opposing the perceived discrimi­nation, such as a family member.

Sexual assault is a sexual act against the will and without the consent of the employee-victim or where the employee-vic­tim is incapable of giving consent. Discrimination, harassment, retaliation, and sexual assault are unacceptable in the workplace. This behavior violates Company policy even when it does not constitute a violation of law.

Any employee who believes that he or she has been a victim of discrimination, harassment, retaliation or sexual assault prohibited by this policy, or any employee who has witnessed such discrimination, harassment, retaliation or sexual as­sault, should immediately report the circumstances to the HR Manager/CEO of the Company to investigate any conduct that violates this policy, even in the absence of a complaint, and take remedial action where appropriate.

All complaints under this policy will be referred to the Human Resources Officer of the Company. If the Human Resources Officer has a personal relationship with the accused individual or otherwise has a conflicting interest, he or she must for­ward it to the CEO.

Responsibilities of Managers and Supervisors

It is imperative that managers and supervisors set the tone for the enforcement of this policy. Managers and supervisors have a special obligation not to engage in discrimination, harassment, retaliation or sexual assault. All management and supervisory personnel have an affirmative duty and are required to promptly report any discrimination, harassment, re­taliation or sexual assault that they observe, learn about from others, or reasonably suspect has occurred with respect to an employee.

Access to the Internet has been provided to staff members for the benefit of the Company and its clients. It allows Em­ployees to connect to information resources around the world. Every staff member has a responsibility to maintain and enhance the Company’s public image, and to use the Internet facility provided by the Company in a productive manner. To ensure that all Employees are responsible, productive Internet users and are protecting the Company’s public image, the following guidelines have been established for using the Internet through the facilities provided by the Company.

Acceptable use of Internet: Employees accessing the Internet are representing the Company. All communications should be for professional reasons. Employees are responsible for seeing that the Internet is used in an effective, ethical and law­ful manner. Internet Relay Chat channels may be used to conduct the Company’s business, or to gain technical or analyti­cal advice. Databases may be accessed for information as needed. Email may be used for business contacts.

Unacceptable use of Internet: Use of the Internet must not disrupt the operation of the Company network or the net­works of other users. It must not interfere with staff productivity. Staff members on the Internet shall not transmit copy­righted materials belonging to entities other than the Company. Users are not permitted to copy, transfer, rename, add or delete information or programs belonging to other users unless given express permission to do so by the owner. Failure to observe copyright or license agreements may result in disciplinary action from the Company or legal action by the copyright owner.

Company Email Policy

Aim: This is to set forth the Company’s policies with regard to access, review, or disclosure of electronic mail {“email”) messages sent or received by company Employees with the use of the company email system. It also sets forth policies on the proper use of the email system provided by the company.

General rules: Dos and don’ts

• The Company email system is primarily for the Company business use. Occasional and reasonable personal use is permitted provided that this does not interfere with the performance of staff duties.
• All email is stored and the Company may inspect email (including personal e-mail) at any time without notice.
• If you send a personal email, start or sign off the e-mail as personal.
• Obtain confirmation of receipt for important emails sent.
• Make and keep hard copies of important emails sent and received.
• Check your email on each working day or arrange for a duly authorized person to do so on your behalf.
• Reply promptly to all email messages requiring a reply.
• Do not impersonate any other person when using email or amend messages received.
• Do not import any non-text file, including files received as email attachments, onto your system without first checking them for viruses.
• Do not create email congestion by sending trivial messages or personal messages or by copying emails to those who do not need to see them. Make use of the Company Web.
• Do not deliberately visit, view, or download any material from any website containing obscene or illegal material or material that is offensive in any way whatsoever.

Confidential Company Information:

Employees must exercise a greater degree of caution in transmitting company confidential information on the email sys­tem than they take with other means of communicating information, (e.g., written memoranda, letters or phone calls) be­cause of the reduced human effort required to redistribute such information. Company confidential information should never be transmitted or forwarded to outside individuals or companies not authorized to receive that information and should not even be sent or forwarded to other employees inside the company who do not need to know the information. Always use care in addressing email messages to make sure that messages are not inadvertently sent to outsiders or the wrong person inside the company. In particular, exercise care when using distribution lists to make sure that all ad­dressees are appropriate recipients of the information.

Virus Protection Procedures

In order to prevent the introduction of virus contamination into the software system, the following must be observed:

• Unauthorized software including public domain software, magazine cover disks/CDs or Internet/World Wide Web downloads must not be used.
• All software must be virus checked using standard testing procedures before being used.

Air One Aviation is committed to providing and maintaining a safe and healthy workplace for all staff, and to providing the information, training and supervision needed to achieve this. Air One Aviation will take responsibility for health and safety procedures, however, Employees need to be aware of their responsibili­ties and comply with the Company health and safety policy.

Each Employee is encouraged to play a vital and responsible role in maintaining a safe and healthy workplace through:

• Being involved in the workplace health and safety system.
• Sticking to correct procedures and equipment.
• Wearing protective clothing and equipment as and when required.
• Reporting any pain or discomfort as soon as possible.
• Ensuring all accidents and incidents are reported.
• Helping new employees, trainees and visitors to the workplace understand the right safety procedures and why they exist.
• Telling your manager immediately of any health and safety concerns.
• Keeping the workplace tidy to minimise the risk of any trips and falls.

Professional Conduct

The Company maintains a pleasant, congenial and safe working environment. In order to accomplish this objective and to protect individual Employees, well-defined policies, procedures and guidelines are in place. These are not exhaustive, as it would be impossible to develop rules covering every possible situation. You are expected to adhere to accepted standards of conduct and courtesy. Violation of these standards may result in disciplinary action even leading to dismissal.

Personal Appearance

An employee is expected to maintain a smart appearance at all times during his/her hours of work and to follow any rule of the Company relating to appearance. All the employees are expected to wear clean and presentable clothes. The Office envi­ronment reflects the Company’s way of working and employees are expected to maintain a professional standard.

Visitors Policy

All Employees need to ensure that any visitor coming to meet them makes a prior appointment as far as possible. The Em­ployee needs to intimate the same to the Reception. On the arrival of the visitor, the reception would inform the con­cerned person who can either receive the visitor himself or direct the guest to the visitor area. After the visit, the visitor should be escorted to the reception. However, if a visitor comes unexpectedly, the reception will check with the concerned person. If the person declines to accept or to receive the guest, the visitor would be sent back. If the visitor is accepted, then the below-mentioned procedure will be followed.

Code of conduct (with outsiders)

All visitors to the Company premises must be met and the discussions held in the common reception/discussion area.

An Employee is not expected to:

• Discuss his/her Company-related activities with an outsider.
• Give out customer information.
• Comment on issues that are a subject matter in the court of law.
• Discuss financial projections of the company.
• Discuss plans, programs, products or operations of the company.

If anyone is found to be transgressing this, he/she shall be liable for suitable disciplinary action, including employment termination. The Company reserves the right to prosecute the Employee concerned or recover the damage incurred thereof. The following guidelines are intended to assist on the dos and don’ts while dealing with the visitors who visit the Company.