Code of Business Conduct and Ethics
CODE OF BUSINESS CONDUCT AND ETHICS
AN-JET is a “Christian Faith-Based Enterprise”
AN-JET is a Christian faith-based enterprise which takes various calculated business risk(s) for corporate profit and routinely projects its corporate will in the marketplace in a legal manner. We display, hold out and promote our faith in GOD and His Son Jesus Christ - both in private and in public whenever possible. We believe all blessings, personal and corporate come from GOD’s Abundant Grace. As such, we make no separation between a faith in God and AN-JET’s public or private business actions. No person, group, tribe, or entity, real or created, who might or does object to our faith, or its practice in the marketplace, is under any pressure or compulsion to take employment with or do business with AN-JET. Employment is done on a voluntary basis - with full understanding of our intent to apply a Christian faith to our business dealings. We welcome all potential stakeholders, suppliers, and customers openly who have a desire to exchange products, services and compensation in a fair and equitable manner following the spirit of this Code.
This Code reaffirms AN-JET’s commitment to conduct its business in accordance with all applicable laws and the highest standards of business ethics and to ensure that all persons are aware of such standards, both legal and ethical. Some important purposes of this Code is to identify areas of ethical risk for directors, officers, and employees, provide guidance in recognizing and dealing with ethical issues, provide mechanisms to report unethical conduct, and help foster a culture of honesty and accountability.
The Code and standards defined in this document apply to employees and set out our expectation for suppliers, customers, and stakeholders to practice and uphold. This Code shall directly apply to all directors, officers, and full-time and part-time employees of AN-JET and those of its wholly owned domestic subsidiaries. This Code shall apply to each foreign subsidiary and other affiliates of AN-JET unless otherwise specifically mandated by local law. In addition to this Code, directors, officers, and employees are subject to the provisions of applicable policies, procedure and plant work rules or plant rules of conduct. Anyone who engages in prohibited conduct is subject to appropriate disciplinary action, including discharge. Appropriate cases may also be called to the attention of governmental enforcement agencies. References herein to “employee” or “employees” also include “directors” and “officers.”
Standards of Conduct
Acceptance of a AN-JET executive or management position at any level includes acceptance of responsibility to uphold the Company’s policies that governing ethical business practices. It also includes acceptance of responsibility to inculcate proper ethical behavior among subordinates and to act with the assurance that the Company is unwilling to seek any business advantage that involves unethical conduct.
Every AN-JET employee is responsible for adhering to business practices that are in accordance with the letter and spirit of applicable Federal, State and Local laws and do so with ethical principles that reflect the highest standards of corporate and individual behavior. Any employee who is uncertain about a standard of conduct, or the application of a law or regulation, should seek guidance as described under “Guidance Available.” All employees will be held accountable, as appropriate, for complying with this Code and the underlying corporate policies.
Safety and Health
The safety and health of all employees is of paramount importance to AN-JET. Company policies have been adopted and various federal, state, and local laws have been enacted to protect employees’ safety and health. It is the employee’s responsibility, for the employee’s own benefit and for the benefit of all other employees, to be aware of and comply with all applicable safety and health requirements. All employees are required to execute their duty in a safe manner. Working safely is a condition of employment. Dangerous or unsafe conditions should be reported immediately to the appropriate management personnel. Risks to person or property shall be evaluated for consequence and occurrence and steps (controls) shall be taken to minimize the likelihood of an unintended consequence occurrence. Evidence of controls working shall be monitored.
State and Federal law prohibits employees in the workplace from engaging in discriminatory harassment. AN-JET establishes a zero-tolerance policy for any act of discriminatory harassment. An employee must not engage in any threatening, intimidating, or hostile activity, or use epithets or slurs that relate to race, color, religion, gender, marital status, national origin, citizenship, age, veteran status or physical or mental disability. Likewise, an employee may not send to any co-employee or display or circulate in the workplace any written or graphic material that indicates or shows hostility toward an individual or group because of that individual's or group's race, color, religion, gender, marital status, national origin, citizenship, age, veteran status or physical or mental disability or take any action adverse to any other employee on that basis. A complaint procedure has been established, and any complaint should be directed to the appropriate member of management.
Sexual harassment in the workplace is expressly prohibited by law, and AN-JET has a zero-tolerance policy to maintain a work environment free of all forms of sexual harassment. Sexual harassment is defined as an unwelcome sexual advance, any request for sexual favors, or any other verbal or physical conduct of a sexual nature in the workplace when submission to such conduct is made a condition of an individual’s employment or is used as the basis for employment decisions affecting such individual or creates a hostile work environment. AN-JET does not condone sexual harassment, whether committed by AN-JET employees or by employees of vendors, suppliers, contractors, or customers; such persons will be subject to appropriate corrective action for violations. Likewise, AN-JET bans pornographic material at any of its facilities. A complaint procedure has been established, and any complaint should be directed to the appropriate member of management at the phone number or email shown at the end of this document.
AN-JET requires its employees to comply with all environmental laws and regulations applicable to their activities in the workplace. Environmental compliance is everyone's responsibility. Each employee is responsible for understanding the environmental consequences of his or her job and shall perform their work an environmentally safe manner. Questions, concerns or suggestions about environmental compliance should be directed to your Supervisor or their Manager if not available. If an employee becomes aware of any actual or potential adverse environmental impact, he or she should promptly advise their supervisor or management if not available so that corrective action can be taken.
The Federal Government, most State Governments, and many Foreign Governments have enacted antitrust or "competition" laws intended to preserve independent competition among competitors and prohibit activities that are unreasonable restraints of trade. Certain types of restraints are considered illegal under the laws of the United States and many countries, and employees must be alert and vigilant to avoid even the appearance of such conduct. Some clear examples of antitrust violations are price fixing, bid rigging, market or customer allocation, production allocation and group boycotts such as joint refusals to deal. If an employee violates the antitrust laws, the employee may be subject to personal criminal liability, including possible fines and imprisonment. If an employee has a question concerning a specific situation, the advice of Management should be sought before taking any action.
Use of Corporate Assets; Fraudulent or Deceptive Practices; Fair Dealing
All employees must protect AN-JET's assets and ensure their efficient use. Company assets must be used for legitimate business purposes, in a manner consistent with corporate policy. Employees may not participate in any fraudulent or deceptive activities involving AN-JET, its customers, suppliers, contractors, co-workers, or anyone else whom AN-JET associates or does business with. Each employee should endeavor to deal fairly with AN-JET's customers, suppliers, competitors, and other employees. No employee should take unfair advantage through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any other unfair-dealing practice. Employees should conduct their business affairs in a manner that upholds AN-JET's reputation for ethical conduct will not be impugned if their dealings become a matter of public discussion.
Some examples of fraudulent or deceptive activities include:
• Theft, fraud, or embezzlement;
• False or inflated billings, or Company expense accounts;
• Payment of bribes, including, without limitation, bribes to governmental officials;
• Payment of or receipt of "kickbacks" for obtaining business for or from AN-JET;
• Improper or unauthorized offering or receipt directly or indirectly of money, goods, favors, or services.
Foreign Corrupt Practices Act
All contacts by AN-JET with officials of foreign governments, or officials of companies owned in whole or in part by foreign governments, must be conducted in compliance with the Foreign Corrupt Practices Act ("FCPA"). The FCPA prohibits payments of, promises to pay, or authorizations to pay, money, gifts, or anything of value to officials of foreign governments, in order to "obtain or retain" business. Payments or gifts to a third party, such as an agent or sales representative, while knowing (or having reason to know) that all or part of the money or gift will be offered or given to such an official, are also prohibited. If employees violate the FCPA, the violation creates severe potential criminal and civil liability for themselves and AN-JET. The types of conduct prohibited by the FCPA are not always clear. As a result, caution is required when doing business through foreign consultants, commercial representatives, or agents, or with businesses that are owned, in whole or in part, by foreign governments or that have personal or family ties to government officials. In such instances, management should be consulted for specific advice.
Political Contributions; Political Activities
United States: It is the policy of AN-JET not to contribute corporate funds or other assets in connection with political campaigns at Federal, State, or Local levels anywhere in the United States or its territories and possessions. AN-JET may sponsor one or more political action committees to the fullest extent permitted by law. Contributions by any sponsored political action committee will be made in accordance with the constituent rules of the committee.
Foreign Countries Outside the United States: In countries where corporate political contributions are legal and accepted as part of a company’s role as a participant in the political process, such contributions may be made, but only if approved by AN-JET after determination to be legal and proper under all applicable laws, regulations, and Company policies.
Employees must comply with all applicable laws concerning the use of corporate funds, properties, and services to influence governmental action or the nomination or election of any candidate to public office. All other forms of direct or indirect political assistance or support must be in strict compliance with applicable laws and regulations and must be properly authorized. Direct or indirect assistance or support includes by way of example, the use of AN-JET meeting rooms, automobiles, computer, or mailing services, the services of AN-JET personnel, and any other thing of value. As in other matters, compliance with accepted accounting rules and controls is required. Company records must accurately reflect and accurately describe the transactions they record.
The above limitations relate only to the use of corporate property. Employees, as individuals, are encouraged to participate actively in the political process, including personal contributions to candidates or political parties of their choice. Nothing in this document shall serve to limit the legal rights of an individual – except as agreed in advance.
AN-JET's contacts with government officials and personnel, both in this country and abroad, must be conducted in compliance with all applicable laws and regulations and in such a way as to avoid even the appearance of impropriety. Contacts and relationships with government personnel must never be illegally fostered, suggest improper influence upon such persons, or compromise AN-JET's brand or corporate integrity. Assistance or support by AN-JET to government officials or personnel must be made in a manner consistent with legal and ethical business practices. This requirement also applies to direct or indirect contributions or expenditures made by employees, agents, or other representatives. Likewise, any entertainment of government officials must be conducted within the bounds of all applicable laws, sound business discretion, and the highest ethical standards.
Sanctions and Trade Embargoes
The United States Government uses economic sanctions and trade embargoes to further foreign policy and national security objectives. Employees must abide by all economic sanctions and trade embargoes that are in effect. Inquiries concerning whether a particular transaction is subject to an economic sanction or trade embargo should be referred to Management.
AN-JET does business in many countries and exports goods to many countries. We must conduct our business in strict compliance with the export control laws of all the countries in which we do business including U.S. laws and must not export any goods or data without any required licenses. Employees should consult with Management when exporting products or information to ensure compliance and correctness of documentation, content and shipment. In all cases, export and import duties must be approved by Management prior to shipment.
Misuse of Confidential Information
It is AN-JET's policy to maintain the confidential treatment of its financial, operating and other Company information, and to prohibit the misuse of any such information obtained during employment. Employees must maintain the confidentiality of information entrusted to them by AN-JET or its customers, except when disclosure is authorized or legally mandated. Confidential information includes all non-public information that might be of use to competitors, or harmful to the company or its customers, if disclosed. It is a violation of federal securities law for any employee to trade in AN-JET stock or securities, or the stock or securities of other companies, on the basis of non-public material information, including unannounced earnings or operating results, merger discussions, and possible acquisitions or divestitures. If an employee has knowledge of confidential or non-public material information, he or she may not use such information (or pass on such information to any other persons) for personal gain, directly or indirectly, through the purchase or sale of securities before such information is disclosed to the public. This applies even if a quarterly “trading window” is open. Engaging in insider trading will subject an employee to both civil and criminal penalties, as well as discharge from employment, and may also create civil and criminal liability. In addition, upon leaving employment (for any reason) each employee must return all Company property including but not limited to documents, books, records, files, electronic data, and identifications. All of the aforementioned property is considered as Business Sensitive to AN-JET and as such is not for public or independent private use.
Employees must not reproduce or distribute software that is protected by copyright, unless appropriate authorization has been obtained. Federal law provides protection to owners of copyrights to prevent unauthorized copying of their written works, and computer software is usually protected by copyright. Unauthorized copying of computer software or files can create significant criminal liability for an employee in the case of willful infringement for profit. The absence of copyright notice does not necessarily mean that the rightful owner does not claim copyright in the software, so an employee must make sure that all software utilized is either owned by AN-JET or covered by a proper written license agreement.
Maintenance of Accurate and Complete Records
Accurate and complete corporate records must be always maintained, and any falsification of corporate records is a serious offense subject to dismissal and criminal liability exposure. Records must be maintained for the period required by AN-JET policy to meet business needs and to comply with applicable laws, regulations, and other legal requirements. All payments of money, transfers of property, furnishing of services and other transactions must be approved in accordance with AN-JET policy. Managers at all levels are responsible for the completeness of the documentation and for ensuring that company funds are spent for the intended or described purposes.
There shall be no undisclosed or unrecorded fund or asset of the Company or any of its subsidiaries. There shall be no false or misleading entries made in the books and records of the Company or any of its subsidiaries. Strict compliance with corporate accounting methods and controls is expected, as is cooperation with internal and external auditors. All employees are required to make full disclosure of all relevant information to, and must cooperate with, internal and external auditors and legal counsel in the cause of audits or investigations.
Public Disclosure of Information
All disclosures of information in reports and documents AN-JET uses in public communications shall be accurate, timely and understandable. All other non-public information (without exception) created or used internally shall be treated as Business Confidential or Business Sensitive and shall not be divulged, conveyed, or transmitted to any unauthorized, unintended recipient or external entity or person without the express written consent of Management. In all cases without exception where confidential design, material, method, or formula information of any type maybe conveyed outside of AN-JET, a Non-Disclosure Agreement (NDA) shall be executed by the recipient company duly signed by their legal agent prior to transmittal of any AN-JET design, material, method, or formula information. In addition to an NDA, A Non-Compete Agreement (NCA) will be also used when the intended recipient is or could be a manufacturer, service company, or if it is found such entity might or does have a financial or vested interest in a manufacture or service company. The primary goal of NDA and NCA agreements are to protect the market and brand of AN-JET and to legally establish such protection prior to engagement whether: employee, associate, supplier, contact, or agent. AN-JET shall only do business with ethical companies and in opposite, doing business with a suspect non-ethical company therefore is a violation of this Code.
Use of Corporate Information Resources
The Internet and corporate email system are intended to be used for business purposes in compliance with all applicable laws and corporate policies. However, corporate policy does permit incidental personal usage. Personal use must be of reasonable duration and frequency, must not interfere with the performance of any employee's job, must not be in support of a personal business or political activities, and must not involve activities that violate any corporate policies or that could be detrimental to AN-JET brand or company. The passive receipt of offensive material by an employee may infer that such distribution is condoned. Accordingly, do not send or forward non-business-related material, and if any such offensive material is received, the recipient should respond to the sender that the message violates corporate policy; that the recipient does not desire to receive such messages; and that the sender should not send such messages in the future. An employee who continues to receive improper email after providing such a response should report the matter to management. Employees should have no expectation of privacy concerning any data, material or information created, received, transmitted, or stored on company property or equipment or on personal cell phones or computers when used in the performance of their duties.
Conflicts of Interest
There is a conflict of interest whenever personal interests or activities improperly influence or interfere with the objective and effective performance of one's duties for AN-JET, or when an employee or a member of his or her family receives improper personal benefits as a result of his or her position with AN-JET. Employees must not engage in activity that creates a conflict of interest or the appearance of a conflict of interest between personal and professional relationships. Employees must conduct themselves in an ethical manner, without conflict of interest, and must not seek or accept improper personal gain.
Each director, officer and employee are responsible for reporting through the normal organizational channels any activity in which the individual is engaged that might create, or appear to create, a conflict of interest. Management will then determine whether potential conflict exists and establish the controls required to prevent it. If adequate controls are not possible, the particular activity will be terminated.
Failure to disclose circumstances that could constitute a conflict of interest will, in and of itself, constitute improper conduct. In order to assist employees in determining when conflicts may exist, some guidelines follow:
1. Outside activities covered by this policy include those involving any director, officer, or employee of the Company or members of their immediate families.
2. An unusual potential for conflict of interest is inherent in certain situations. The examples set out below are not to be regarded as all-inclusive.
(a) Relationships with an enterprise, organization, agency or institution, or its representatives, which supplies, buys from, or competes with the Company involving:
(i) Direct or beneficial ownership or an interest in or of any class of the security of such an enterprise, except:
(1) An investment representing less than 1% of the outstanding securities of a publicly owned corporation.
(2) Where such investment constitutes less than 10% in actual value of the individuals’ investment portfolio.
(ii) Borrowing from such an enterprise. (iii) Employment, consultation, or directorships with such an enterprise.
(iv) Receiving from or providing to such an enterprise, organization, agency or institution, or its representatives, gifts or favors of more than nominal value, or inappropriate or excessive entertainment, particularly in situations in which business judgment may be influenced.
(b) Purchase, sale or lease – beyond normal personal needs – of materials, equipment, supplies, products, or real property which the Company purchases, leases or sells.
Employees, officers and directors owe a duty to the Company to advance its legitimate business interests when the opportunity to do so arises. Employees, officers and directors are prohibited from (a) taking for themselves personally opportunities that are discovered through the use of corporate property, information or position; (b) using corporate property, information, or position for personal gain; and (c) competing with the Company.
Dealings with Company Suppliers and Sub-Contractors (Suppliers) shall be handled in a fair and ethical manner. Offers of graft, kickbacks or compensations in any form or manner from Suppliers shall be reported immediately to Management. Acceptance of same from Suppliers is grounds for immediate employee disciplinary action which may include but not limited to return of the monetary value received, reassignment, legal action and/or termination. Suppliers offering such graft or compensation shall be suspended or outright barred from doing future business with AN-JET.
This Code does not refer to all laws, policies rules or regulations or standards applicable to conduct by AN-JET employees. Requirements not referred to in this Code may apply to specific work activity. Many laws to which AN-JET is subject are complex, and their application to AN-JET business practices or activities can at times be unclear. Appropriate guidance should be sought regarding any proposed action that raises questions or creates uncertainty with respect to compliance with laws or regulations. Employees should seek the advice and guidance of Management with regard to any and all transactions that may have legal implications. Periodic legal and ethical compliance presentations may be made as seen appropriate by Management. Employees are expected to attend as requested and to follow the advice given at these presentations.
A waiver of any provision of this Code or an underlying policy thereto shall not be deemed to be an ongoing exception to policy. All policies and adherence to this Code shall be ongoing and intact – suitable for compliance unless amended in writing by AN-JET.
This Code reflects general and specific principles to guide employees in making morally ethical decisions for the company and for themselves and is not intended to address every possible situation. As such, nothing in this Code prohibits or restricts AN-JET or its owners from taking disciplinary action on matters of employee conduct whether it is expressly discussed in this Code or not. The Code is not intended to create any expressed or implied contract with any employee or third party, but it shall be used as a standard of principles and business ethics. Nothing in this document creates any employment contract between AN-JET and its employees. The Code may be revised, changed, or amended at any time by the owner of AN-JET or by Management.
Administration and Reporting Violations of the Code
Administration of this Code is under the direction of the President of AN-JET. An employee must report any suspected illegal or unethical conduct connected with or affecting the business of AN-JET or its affiliated companies. Such a good faith report should be made to the employee’s supervisor or to Senior Management. No retaliatory action will be taken against an employee who makes a good faith report of suspected illegal or unethical conduct. If the conduct relates to workplace harassment or other discriminatory matters, the report may be made directly to the President of AN-JET. AN-JET, to the extent practical, will keep confidential the identity of anyone making such a report. The email address and telephone number for reporting is email@example.com or 713-540-3080.
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