Ethics & Conduct

Code of Conduct

Issuing date: January 2021

1.0 PURPOSE

InVeris Training Solutions, Inc. and all subsidiary companies will conduct business fairly, impartially, and in compliance with all applicable laws and regulations. Our values of Teamwork, Integrity and Excellence are at the heart of how we do things, and we reinforce these daily by applying our high performance culture principles. We are firmly committed to integrity, honesty and respect for others in all our business relationships, including those with customers, suppliers, communities where we conduct business, and amongst employees. The highest standard of ethical behavior is expected from all of our employees, directors, and from those who act on InVeris’ behalf in the performance of their professional responsibilities and in their own personal conduct.

Our Code of Conduct promotes “doing the right thing” and “doing things right” so that we maintain our personal and business integrity. No Code of Conduct can address every possible situation. Where a specific action is not mentioned or you are not sure what action to take, you should always seek guidance. This Code will help you identify the right resources and the people who can help you.

2.0 POLICY

Employees, directors, and those who act on our behalf, in accordance with our related policies and procedures, should:

• Regularly read this Code of Conduct;
• Familiarize yourself with our policies and processes;
• Participate in training to learn about business ethics, compliance, laws and regulations that affect your role and our business;
• Be alert to any Code of Conduct violations, illegal or unethical conduct and promptly report them to management or other appropriate officials (see below). If you believe that our Code of Conduct or related policies are being violated, you have a responsibility to speak up;
• Raise questions or concerns about the business and follow them through to appropriate conclusion via your manager or any Ethics team member.
• Comply with all applicable laws and regulations;
• Deal fairly and impartially in all transactions;
• Not participate in activities that may raise questions as to your own or InVeris’ integrity, impartiality, and reputation;
• Not engage in conduct that might create a conflict of interest for InVeris or for yourself individually;
• Safeguard all InVeris and customer assets and use them only for approved activities. Never seek personal gain through the inappropriate use of our intellectual property and confidential information or the intellectual property or confidential information of any third party which has been entrusted into our care;
• Never seek personal gain through the inappropriate business dealings;
• Be familiar with and refer to the other relevant policies, including our Anti-corruption Policy.

Our Anti-corruption Policy covers the following issues:

• Bribery
• Gifts and Entertainment
• Conflicts of Interest
• Competition and anti-trust
• Sales representatives
• Distributors
• Political contributions and lobbying activities

Our Financial Crime Policy covers the following issues:

• Money laundering
• Fraud
• Tax evasion and facilitating tax evasion

InVeris has implemented an Ethics and Business Conduct Program across the company in order to:

• Explain our policies and procedures which relate to ethical business conduct;
• Provide regular training in ethics and business conduct;
• Create an engaged environment where employees feel confident that they may raise questions or concerns, and report suspected violations without fear of punishment or retaliation for doing so or for participating in an investigation;
• Sponsor a monitored Ethics Line to enable employees to report questions or concerns about possible misconduct or to seek guidance about the proper course of action. The free telephone numbers are provided at the end of this Code and on posters in our sites.
• Provide a safe and productive work environment in which we promote employee’s health and well-being and protect others from the consequences of alcohol, drug and substance misuse;
• Monitor compliance with this

InVeris will rigorously enforce compliance with this Code. Violations may subject employees to disciplinary action, including, in serious cases, the termination of employment. However, the statutory employment rights of employees will always be honored.

If you have any questions or concerns about any aspect of this Code of Conduct or the way in which we are conducting business or treating people, you should address them with your manager or your local site leader.  You may contact Human Resources at any time.  If you do not consider these options appropriate you may call our Global Ethics Line, available 24 hours a day / 7 days a week: +1-833-350-1704 or +1 678-288-1512.

Ethics and Business Conduct

Issuing date: November 2020

1.0 PURPOSE

InVeris Training Solutions, Inc. and all subsidiary companies will conduct business fairly, impartially, and in compliance with all applicable laws and regulations, and guided by:

• the Global Principles adopted by the International Forum on Business Ethical Conduct (IFBEC) and
• the Common Industry Standards adopted by the Aerospace and Defense Industries Association of Europe (ASD).

2.0 POLICY

InVeris is firmly committed to integrity, honesty, and respect for others in all its business relationships; including those with customers, suppliers, communities where we conduct business, and amongst its employees. The highest standard of ethical behavior is expected from InVeris employees, directors and from those who act on the Company’s behalf in the performance of their professional responsibilities and in their own personal conduct.

A Code of Conduct has been adopted along with related policies to guide the conduct of our businesses; the people who work at InVeris; those who work on our behalf; and others with whom we work. These policies and procedures include our Anti-Corruption Policy and Corporate Responsibility Policy.

The company has implemented an Ethics and Business Conduct Program across the Group which includes:

1. Training and awareness presentations;
2. The names and contact information for people who can help employees;
3. An Ethics Line for raising questions or concerns;
4. Other policies and procedures to be adopted from time to time to assist in the implementation of this policy;
5. Regular monitoring of the Ethics and Business Conduct Program and of compliance with the Code of Conduct;

This policy, our Code of Conduct and related policies will be provided to all employees and directors.

The Board delegates responsibility for oversight of the Ethics and Business Conduct Policy to the Chief Executive Officer, the Chief Financial Officer, and the Corporate Ethics Officer. Site Leaders are responsible for local implementation of this policy.