CODE OF ETHICS AND CONDUCT

The Code of Ethics and Conduct (the “Code”)applies to all Aero Dynamic Machining, Inc. (“ADM”) employees, all levels of management at ADM, consultants, contract laborers and other agents when they represent ADM.

ADM expects that any person, when acting on behalf of ADM, to perform their duties in compliance with our Code and to conduct himself/herself in accordance with all applicable laws and regulations.

It is the objective of ADM to conduct its business in an ethical and proper manner at all times in full compliance with all applicable laws and regulations, and consistent with our values and our Code. In furtherance of such objectives, all businesses conducted on behalf of ADM must be performed with utmost integrity, honesty and fairness.

No employee, managers at any level, consultants, contractors and agents acting on behalf of ADM shall engage in any form of conduct or activity that may raise questions as to the company’s honesty, impartiality, reputation or otherwise cause embarrassment to the company.

All employees, consultants and/or contractors of Aero Dynamic Machining, Inc. shall be required to adhere to the following:

• I will, at all times, provide a service that shall reflect the highest professional, fairness and integrity values of ADM.
• I understand that integrity is a core company value of ADM and will support and promote such value during the course of my employment and/or association with ADM.
• I will not engage in any activity that might create a conflict of interest for me or for ADM.
• I will not engage or participate in any illegal or unethical activity, even if such acts will benefit ADM and/or is directed by a person of higher authority within ADM.
• I will report all suspicious activities that may be a violation of any law to upper management of ADM, including notifying the CEO, President, Vice President, the HR Department and/orADM’s General Counsel.
• I will cooperate with all internal investigations and with all governmental investigations.
• I will notify the CEO, President, Vice President, the HR Department and/or ADM’s General Counsel whenever I learn that a governmental agency or any third part is conducting an investigation or asking for information pertaining to a suspected violation of law.
• I will follow all restrictions on use and disclosure of information. This includes following all requirements for protecting company information and ensuring that proprietary information is properly safeguarded.
• I understand that ADM’s policy prohibits any form of kick-backs and/or bribery in order to gain business or a competition advantage for the company.
• Further, I understand that it is ADM’s policy that the offering of any gifts and/or kick-backs to any governmental contractors is strictly prohibited at all times.
• I will be vigilant at times to ensure that any business dealings and extension of business courtesy shall be reasonable, lawful and fully justified under the circumstances, and does not suggest the appearance of impropriety (i.e., kick-backs and/or bribery) and when in doubt, I shall inquire with the CEO, President, Vice President, the HR Department and/or ADM’s General Counsel to determine if any proposed action will be appropriate under the circumstances and that such business courtesy will not violate the rules of the recipient’s organization relating to such matters or any applicable law.
• As part of ADM’s anti-kick policies, I understand that I am required to maintain accurate financial records and appropriately document and obtain approval of costs and expenses.
• I will not use company credit cards for non-business expenses.
• I will refrain from using inappropriate language, whether it be written, electronic, or verbal.
• I will report all suspected violations of the Code.
• I will promptly report any illegal or unethical conduct to the CEO, President, Vice President, the HR Department and/or ADM’s General Counsel.
• I will accept the responsibility to actively uphold the Code and shall refrain from any action that would be detrimental to the safety or well-being of others, or that would impair the ability of others to follow the Code. For this reason, any employees, management personnel at any level, consultants, contract laborers and other agents who participate in illegal or prohibited activities or who build a reputation for involvement in these activities shall be subject to discipline including but not limited to suspension and dismissal from the employment and/or association with ADM.