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Statement of Policy on Ethics and Business Conduct

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Code of ethics and business conduct

It is the policy of Ultra Electronics that all employees will comply with all laws governing its operations and will conduct business affairs in an ethical manner. The company and its employees will maintain high standards of personal conduct and integrity at all times in carrying out the company’s affairs.

Ultra Electronics and its divisions and operating businesses require that all employees conduct themselves in ways that demonstrate high ethical standards in all of their dealings with customers, suppliers, governments, the public and each other. The integrity of Ultra Electronics’ businesses rests on the integrity of its employees.


Responsibilities

Although ultimate responsibility lies with the Ultra Group Board of Directors for the implementation of this policy, this requirement is delegated to Managing Directors and Presidents who have total responsibility for the implementation and control of this policy within their respective businesses.

In particular, Managing Directors and Presidents must ensure that:

  • a written and maintained Code of Ethics and Business Conduct (“Code”) exists for their business and is effectively implemented and compliance is enforced.
  • employees are provided with clear guidelines on matters of everyday business conduct in order to operate within the Code.
  • through appropriate communication and/or training programs, employees are aware of and understand the Code.
  • employees are provided with continuing advice and guidance on relevant policies and procedures.
  • there is no retribution for reporting an alleged violation of the Code or other related company policies or procedures.

Line Managers and Supervisors are responsible for the implementation of the procedures relating to the Code within their department.

Employees are also responsible for taking appropriate actions to comply with the Code within their business.


Monitoring and support

The operation of this policy will be monitored by the Group Board of Directors twice per year via a compliance report to be submitted by each business. Businesses are responsible for conducting periodic reviews to ensure that high standards of ethical behaviour are maintained across all parts of the Group.

Businesses are responsible for ensuring that appropriate support arrangements are in place including but not limited to advice and training.