Tower Aerospace Corporate Policy

Responsible Marketing Sales and Service
Tower Aerospace’s corporate culture is an important factor in the company’s success. Central to this culture are our values: Leadership,Integrity, Flexibility,Efficiency and Education. Summarized by the term Integrity. In the marketing and sales of our products and services, Integrity means:

“To comply with applicable laws, regulations and good business practices”
We are committed to ethical sales & marketing practices that meet the standards set by external regulations and codes of practices, in particular:

    • all laws and regulations dealing with marketing practices
    • all applicable global, regional and local industry relevant codes and standards for our business
    • privacy of customer or consumer personal/professional information and data protection
    • recommendation and promotion only of lawful uses of offered products and services

In addition, we are committed to observe company-specific rules and regulations, most of all:
“The Tower Aerospace Corporate Compliance Policy”. It draws attention to a number of principles that are of particular significance in practice and gives guidance to all Tower Aerospace employees, subcontractors and professional associates.

“Strive constantly to express honesty and reliability”
We are committed to accurate and scientifically substantiated communication, in particular:

    • clarity: regarding no misleading statements or miss communication
      and or understanding
    • accuracy: all advertising to undergo internal review for accuracy & compliance
    • transparency: evaluation of risks and proper information about any risk associated to our products and services in accordance with industry practices and relevant requirements
    • consistency of information irrespective of form and forum (e.g. press information, social media, customer letter, legal contracts, any form of communications)
    • the objective of ethical behavior and transparent business practices at all times

“To listen attentively and communicate appropriately”
We are committed to openness and transparency, in particular:

    • transparent product information
    • implementation of efficient, reliable internal management systems
    • responsible interaction with all stakeholders and customer groups
    • transparent socially responsible lobbying activities
    • collect customer and public feedback and consider outside views

“To care about people, safety, equipment and the environment”We are committed to implementation and monitoring of procedures, systems and processes, in particular:

    • assess risks: regularly review business marketing operations to assure highest quality of our products and services as well as safeguarding people and the environment
    • prevention: extensive ongoing training in order to help employees
      and associates understand applicable laws, regulations, risk mitigation and customer support as well as company rules
    • to act: corrective actions where required in timely manner and
      transparent reporting on reassessments, evaluations and finding solutions
    • change: to adapt (including restrict) marketing of products and service to the extent required by law and risk assessments

This Policy is valid for Tower Aerospace Inc. and all “bound” associated companies and applies to all marketing, sales and support activities.

Additional regulations of the Tower Group of Companies provide more detailed information and guidance on industry specific issues and internal management systems.

Last Updated — 5 November 2019