Ethics Policy

Certified management system ISO 9001:2015
DI 125 Issue 1 05/02/19

INTRODUCTION:

At Skytec Aviation Ltd we are commited to conducing our business with honesty and integrity. We expect all personnel, including Directors, Managers, staff and business partners to uphold these standards and to act in accordance with our ethics policy as well as with all applicable laws. We value a culture of openness and accountability and encourage seeking guidance on ethical and compliance issues and to report any concerns regarding any unethical, illegal or suspicious activity.

PURPOSE:

The aims of the policy are to:
1. remind you of your duty to report any unethical, illegal or suspicious activity that you observe in the knowledge your concerns will be taken seriously and investigated as appropriate;
2. provide guidance on how to raise those concerns;
3. provide reassurance that you can raise any concerns in good faith without fear of retaliation, even if those concerns turn out to be mistaken; and
4. encourage and facilitate the raising of good faith concerns within Skytec Aviation Ltd prior to seeking resolution outwith Skytec Aviation Ltd.

SCOPE:

This policy applies to all Skytec Aviation Ltd personnel and all business partners working or representing Skytec Aviation Ltd anywhere in the world.

POLICY REQUIREMENTS:

Our duty to raise concerns -
Asking questions or reporting known or suspected misconduct benefits and protects all of us. We all have a duty to report any unethical, illegal or suspicious activity or concerns.

Resources for raising concerns -
Use the following resources for reporting suspected illegal or unethical behaviour:
- the Development Manager
- the Managing Director
- raise concerns to Croner (0808 145 3490). Croner are independant advisors to Skytec Aviation.

For concerns relating to your own employment or circumstances at work that do not breach the company Ethics Policy, we would encourage you to raise these concerns initially with the Development Manager or Croner.

Confidentiality -
Skytec Aviation Ltd will seek to protect the confidentiality of any person making a good faith report. Reports may be submitted on a confidential basis or may be submitted anonymously. Bear in mind that it might be useful for you to identify yourself so that you can be contacted for further information that may assist with any investigation. If, however, you feel that you are not comfortable disclosing your identity, anonymous reports must contain sufficiently detailed information to enable Skytec Aviation Ltd to effectively address the reported activity. If you receive any information about any report and related investigation you must treat this as confidential information.

Investigation -
Skytec Aviation Ltd takes all concerns seriously and is commited to investigating all reports in a consistant manner. Any ethical concerns are generally addressed by the Development Manager or Croner. You are expected to cooperate with all investigations by providing honest, truthful and complete information.
If you have been found to have been personally involved in any wrongdoing, reporting will not absolve you from accountability – but your cooperation with the investigation will be taken into account when any disciplinary actions are considered.
Skytec Aviation Ltd strives to resolve all matters internally but nothing in this policy should be interpreted to prohibit you from reporting, at any time, suspected unlawful conduct to governmental authorities.

Protection from retaliation -
So long as you make a report or notification in good faith, Skytec Aviation Ltd will protect you from being retaliated against, even if the issues raised in your report are not proven in an investigation. "Good faith" means that you must have an honest belief that the information provided is truthful, even if the information turns out to be incorrect.
It is Skytec Aviation Ltd's policy that no one making a report in good faithshould experience any negative action or discrimination as a result of making their report. This includes threats, intimidation, demotion, discrimination, suspension, reassignment or other forms of retaliation or victimization.

If you believe you have been subject to any form of retaliation, as a result of making a report or assisting an investigation, or you witness retaliation against someone else, you should report it to the Development Manager or Croner as an independant party.

Compliance with this policy:
Anyone who is found to have breached this policy by not reporting a breach or suspected breach of the Ethics Policy or by retaliating against any person will be subject to disciplinary action.

In addition, any person who is found to have made a false allegation, provided false or misleading information in the course of an investigation or is found to have acted in bad faith will be subject to disciplinary action.

Contacts:
Any queries about this policy should be directed to the Development Manager.

David Shaw, Development Manager

[email protected]