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JABIL DEFENSE AND AEROSPACE

Supplier Standards of Business Conduct

Our suppliers must act ethically always and ensure the integrity of their operations.

Purpose:

Jabil Defense and Aerospace Services, LLC (“JDAS”) is committed to achieving the highest standards of ethics, integrity and performance to provide the products and solutions necessary for our customers. These Supplier Standards of Business Conduct set forth the fundamental requirements that we expect our suppliers (and those who work for them, including employees and subcontract labor) to comply with at all tiers.

A JDAS Supplier Shall Maintain the Highest Standards of Ethics and Integrity and Comply with Laws, Regulations, its Contractual Obligations with us and this Standard of Business Conduct

Our suppliers must act ethically always and ensure the integrity of their operations. Acting with integrity means being accountable for the highest standards of behavior. In addition, our suppliers must comply fully with all applicable laws and regulations, their contractual obligations with us and these Supplier Standards of Business Conduct.

A JDAS Supplier That Manufactures or Provides Goods and Services Used to Produce Electronic Goods, Shall Comply with The EICC Code of Conduct

JDAS expects our Suppliers’ providing goods or services used to produce electronics goods to comply with the EICC Code of Conduct, which supports our philosophy. JDAS expects our Suppliers to comply with the EICC code regardless of local business practices or social customs.

For more information on the EICC and to view the EICC Code of Conduct, visit http://www.eiccoalition.org/standards/code-of-conduct/

A JDAS Supplier is Accountable for Quality and On-Time Delivery

Quality and On-Time Delivery

Suppliers must ensure their work product meets our company’s quality standards. We expect our suppliers to have in place, the appropriate quality assurance processes, and systems, to identify defects, implement corrective actions and facilitate the on-time delivery of the product which quality meets, or exceeds the contract requirements.

Counterfeit Parts

We expect our suppliers to develop, implement, and maintain effective methods and processes appropriate to prevent the introduction of counterfeit parts and materials into JDAS deliverable products. Suppliers must ensure that effective processes are in place to detect counterfeit parts and materials, as applicable, and prevent them from being delivered to JDAS.

Defense Priorities and Allocations System (DPAS) Rated Orders

JDAS Suppliers shall not discriminate against DPAS rated orders in any manner, such as charging higher prices, or by imposing different terms and conditions, than for comparable unrated orders. JDAS suppliers shall give DPAS rated orders preferential treatment over unrated orders, and ensure rated orders are accurately scheduled and performed to ensure delivery, by the required delivery date.

Business Continuity Plan

JDAS Suppliers are expected to have Business Continuity and Recovery Plans that will facilitate quick response, reaction and resumption of parts and services in the event of disruptions. Suppliers are expected to establish a comprehensive crisis management approach to deal with potential disruptions (proactive) and disasters (reactive). The approach should include a plan of action, checklist of activities, communication plans, escalation procedures and organization with teams, roles and responsibilities.

A JDAS Supplier Shall Treat All People with Respect and Dignity

We expect our suppliers to treat people with respect and dignity, encourage diversity, remain receptive to diverse opinions, promote equal opportunity for all, and foster an inclusive and ethical culture. Suppliers must refrain from violating the rights of others and address any adverse human rights impacts of their operations.

Harassment

Our suppliers should ensure that their employees are afforded an employment environment that is free from physical, psychological, and verbal harassment, or other abusive conduct.

Discrimination

Our suppliers should provide equal employment opportunity to all employees and applicants for employment, without any unlawful discrimination.

Child Labor

Suppliers must ensure that child labor is not used in the performance of work. The term “child” refers to any person under the minimum legal age for employment where the work is performed.

Human Trafficking

We fully support the elimination of human trafficking and slavery from the supply chain and do not tolerate any trafficking in persons, both in the U.S. and globally. Suppliers must adhere to regulations prohibiting human trafficking, and comply with all applicable local laws in the country or countries in which they operate.

Wage and Benefits

Our suppliers must pay workers at least the minimum compensation required by local law and provide all legally mandated benefits. In addition to payment for regular hours of work, workers must be paid for overtime at such premium rate as is legally required.

Social dialogue

We expect our suppliers to respect the rights of workers to associate freely and communicate openly with management regarding working conditions without fear of harassment, intimidation, penalty, interference or reprisal. Suppliers are expected to recognize and respect the ability of workers to exercise lawful rights of free association, including joining or not joining any association of their choosing.

A JDAS Supplier Shall Not Use Unethical or Illegal Business Practices

Our suppliers must not seek to gain advantages through unfair, unethical or illegal business practices.

Anti-Corruption Laws

Our suppliers must comply with all applicable anti-corruption laws, directives and regulations, such as the U.S. Foreign Corrupt Practices Act and the U.K. Bribery Act.

We require our suppliers to refrain from offering or making any improper payments of money (or anything of value) to government officials, political parties, candidates for public office, or other persons. This includes a prohibition on facilitating payments intended to expedite or secure performance of a routine governmental action that the government official is already obligated to perform like obtaining a visa or customs clearance, even in locations where such activity may not violate local law. Payments made to protect personal safety are permitted where there is an imminent threat to health or safety but must be properly recorded and reported to the buyer representative as promptly as possible under the circumstances.

We require our suppliers to use due diligence to prevent and detect corruption in all business arrangements, including partnerships, subcontracts, joint ventures, offset agreements, and the hiring of intermediaries such as agents or consultants.

Illegal Payments

Our suppliers must not offer any illegal payments to, or receive any illegal payments from, any customer, supplier, their agents, representatives or others. The receipt, payment, and/or promise of monies or anything of value, directly or indirectly, intended to exert undue influence or improper advantage is prohibited. This prohibition applies even in locations where such activity may not violate local law.

Anti-Trust

Our suppliers must not engage in anti-competitive practices in violation of applicable law, regulation or contractual requirements.

Conflict of Interest

Our suppliers must avoid conflicts of interest or situations giving the appearance of a potential conflict of interest in their dealings with us. We require our suppliers to provide notification to affected parties if an actual or potential conflict of interest arises, including conflicts between the interests of our company and the personal interests of a supplier’s employees or those of close relatives, friends or business associates of a supplier or its employees.

Gifts/Business Courtesies

We believe our suppliers should compete on the merits of their products and services. The exchange of business courtesies may not be used to gain an unfair competitive advantage or exercise improper influence. In any business relationship, our suppliers must ensure that the offering, receipt of any gift, or business courtesy is permitted by law and regulation and complies with any contractual obligations, and that any exchanges do not violate the rules and standards of the recipient’s organization, and are consistent with reasonable marketplace customs and practices.

Procurement Integrity

Our suppliers must maintain the integrity of our procurement and acquisition processes. Suppliers may not improperly use competitors’ confidential or proprietary information for their own benefit. If a supplier becomes aware of any such confidential or proprietary information, they should promptly take steps to avoid its improper use and inform our Company as appropriate.

Insider Trading

Our suppliers and their personnel must not use material, non-publicly disclosed information obtained in the course of their business relationship with us as the basis for trading or for enabling others to trade in the stock or securities of our company or those of any other company.

A JDAS Supplier Shall Exhibit Good Trade Practices

Import

Our suppliers must ensure that their business practices are in accordance with all applicable laws, directives and regulations governing the import of parts, components, and technical data. We require our suppliers to provide truthful and accurate information and obtain appropriate licenses and/or consents where necessary.

Export

Our suppliers must ensure that their business practices are in accordance with all applicable laws, directives and regulations governing the export of parts, components, and technical data. We require our suppliers to provide truthful and accurate information and obtain appropriate licenses and/or consents where necessary.

Anti-Boycott

Our suppliers must not participate in, cooperate with, or further the cause of any unsanctioned foreign economic boycott, in accordance with the U.S. 1977 Export Administration Act and the U.S. 1976 Tax Reform Act, or similar legislation or regulations.

Responsible Sourcing of Minerals

Suppliers must comply with any applicable laws and regulations regarding conflict minerals and assist us in meeting our obligations under law and regulation. We report annually to the United States Securities and Exchange Commission on our use of conflict minerals (tantalum, tin, tungsten and gold) originating in the Democratic Republic of Congo (DRC) or any of the DRC’s adjoining countries in products manufactured or contracted to be manufactured by the company and are required to conduct due diligence on the use of conflict minerals in our supply chain. Our suppliers must support our efforts to conduct due diligence on the use of conflict minerals in our supply chain, including the identification of products in their supply chain that contain conflict minerals and validating the country of origin of these minerals.

A JDAS Supplier Shall Protect Information, Intellectual Property and The Supply Chain

Confidentiality of Sensitive Information

Suppliers must maintain the confidentiality of all information entrusted to them by us, our customers or other third parties, except where disclosure is authorized or legally required (and then only after notice).

We require our suppliers properly to handle and protect from improper disclosure any sensitive information, including classified, controlled, proprietary and personal information; competition sensitive information and intellectual property. Information should not be used for any purpose (e.g., advertisement, publicity, and the like) other than the business purpose for which it was provided, unless there is prior authorization from the owner. Suppliers must comply with all contractual obligations and applicable laws, including data privacy laws.

Security of Supply Chain

In addition to complying with our security requirements, suppliers are encouraged to implement practices and procedures to ensure the security of their people, property and other assets, including their supply chain. Suppliers are encouraged to participate in the Customs-Trade Partnership Against Terrorism initiative of the United States Department of Homeland Security.

Intellectual Property

We require our suppliers to respect and comply with all applicable laws and other binding obligations governing intellectual property rights, including protection against disclosure, patents, copyrights, and trademarks.

Cybersecurity

Suppliers must take care to safeguard and protect information entrusted to them and information generated or developed by them in support of our programs from unauthorized access, destruction, use, modification or disclosure. We expect suppliers to have risk-based cybersecurity programs designed to mitigate emerging threats to their information systems, products and services and supply chain and to comply with all applicable contractual and legal requirements.

A JDAS Supplier Shall Maintain Accurate Records

Suppliers must create and maintain accurate records. All records, regardless of format, made or received as evidence of a business transaction must fully and accurately represent the transaction or event being documented. When a record is no longer needed to conduct current business, records should still be retained based on the applicable retention requirements. Suppliers must not falsify or provide fraudulent records, billings or other statements to us or our customers.

A JDAS Supplier Shall Maintain a Healthy and Safe Workplace

Health and Safety

We require our suppliers to comply with all applicable health and safety laws, regulations, and directives. Suppliers should protect the health, safety, and welfare of their people, visitors, and others who may be affected by their activities.

Environment and Sustainability

Our suppliers must comply with all applicable environmental laws, regulations, and directives and operate as responsible stewards of the environment.

JDAS Supplier Integrity, Ethics Program Expectations

Compliance

We require suppliers to maintain an effective integrity, ethics and compliance program and to meet the requirements of this Supplier Standards of Business Conduct.

Consequences for Violating Standards

In the event of a violation of this Supplier Standards of Business Conduct, we may pursue corrective action to remedy the situation. In the case of an actual or possible violation of law or regulation, we may be required to report to proper authorities. We reserve the right to terminate our relationship or take any other appropriate action with any supplier under the terms of the existing procurement/purchasing contract.

Whistleblower Protection
Our suppliers should provide their employees with avenues for raising legal or ethical issues or concerns without fear of improper retaliation. Our suppliers should also take action to prevent, detect, and correct any retaliatory actions.