Code of Conduct

Code of Conduct

Last updated: April 2, 2025

1. Introduction and Purpose

At InfinityAero, we are committed to conducting business with the highest standards of ethics, integrity, and professionalism in the global aviation industry. This Code of Conduct outlines the principles and standards that guide our actions and decisions as we fulfill our mission to provide premium aviation parts and services.

This Code applies to all InfinityAero employees, officers, directors, contractors, consultants, suppliers, and business partners. We expect everyone representing or working with InfinityAero to uphold these standards and to act in accordance with both the letter and spirit of this Code.

2. Our Core Values

Our Code of Conduct is built upon these fundamental values:

• Safety First: We prioritize aviation safety above all other considerations.
• Unwavering Integrity: We conduct business honestly, transparently, and ethically.
• Quality Excellence: We deliver the highest quality aviation parts and services.
• Reliability: We fulfill our commitments and are dependable partners.
• Innovation: We continuously improve and adapt to industry advances.
• Respect: We treat everyone with dignity and respect differences.

3. Aviation Safety and Quality

3.1 Safety Commitment

Safety is our highest priority. We are committed to providing aircraft parts and services that meet or exceed all applicable safety standards and regulatory requirements. We will never compromise on safety to achieve business objectives.

3.2 Quality Assurance

We maintain rigorous quality control processes throughout our supply chain. We source, inspect, and distribute aviation parts in compliance with all applicable industry standards, including FAA, EASA, and other relevant regulatory requirements.

3.3 Documentation and Traceability

We maintain complete, accurate, and verifiable documentation for all aviation parts we supply. We ensure proper traceability of parts throughout the supply chain and strictly adhere to established airworthiness certification procedures.

3.4 Counterfeit Parts Prevention

We have zero tolerance for counterfeit or unapproved parts. We implement robust counterfeit part detection and prevention procedures and only source parts from authorized and verified suppliers.

4. Business Integrity

4.1 Anti-Corruption and Anti-Bribery

We do not engage in or tolerate bribery or corruption in any form. We strictly prohibit offering, giving, soliciting, or receiving anything of value to improperly influence decisions or actions relating to our business activities. We comply with all applicable anti-corruption laws worldwide, including the U.S. Foreign Corrupt Practices Act and the UK Bribery Act.

4.2 Gifts and Hospitality

We exercise caution with gifts and hospitality. Any gifts, meals, entertainment, or travel offered or received must be reasonable in value, infrequent, transparent, and consistent with industry customs. They must never be intended to improperly influence business decisions.

4.3 Conflicts of Interest

We avoid situations where personal interests could conflict, or appear to conflict, with the interests of InfinityAero. We disclose potential conflicts of interest promptly and take appropriate steps to manage them.

4.4 Fair Competition

We compete fairly and comply with antitrust and competition laws. We do not engage in price fixing, bid rigging, market allocation, or other anti-competitive practices. We gather competitive intelligence ethically and legally.

4.5 Accurate Records

We maintain accurate and complete records of all business transactions. We never falsify documents, misrepresent facts, or create misleading records. We comply with all applicable accounting standards and financial reporting requirements.

5. Trade Controls and Sanctions

5.1 Export and Import Compliance

We comply with all applicable export and import laws and regulations. We implement appropriate controls to ensure compliance with trade restrictions, licensing requirements, and customs regulations.

5.2 Sanctions Compliance

We respect international sanctions and do not conduct business with sanctioned countries, entities, or individuals in violation of applicable laws. We conduct appropriate due diligence on our business partners and transactions to ensure compliance.

5.3 Anti-Money Laundering

We are committed to preventing our business operations from being used for money laundering or terrorist financing. We implement appropriate due diligence and monitoring procedures to identify and report suspicious activities.

6. Workplace Environment

6.1 Diversity and Inclusion

We value diversity and foster an inclusive environment where all employees can contribute and advance based on merit. We prohibit discrimination based on race, color, religion, gender, gender identity, sexual orientation, national origin, age, disability, or any other protected characteristic.

6.2 Harassment-Free Workplace

We maintain a workplace free from harassment, intimidation, and offensive behavior. We treat everyone with dignity and respect, and we do not tolerate any form of harassment, whether verbal, physical, or visual.

6.3 Health and Safety

We provide a safe and healthy work environment. We comply with applicable health and safety laws and regulations and take appropriate measures to prevent workplace accidents and injuries.

6.4 Human Rights

We respect internationally recognized human rights and are committed to upholding them in our operations. We prohibit the use of child labor, forced labor, and human trafficking in our operations and supply chain.

7. Environmental Responsibility

7.1 Environmental Compliance

We comply with environmental laws and regulations applicable to our operations. We obtain all required environmental permits and approvals and maintain them as required.

7.2 Sustainable Operations

We strive to minimize the environmental impact of our operations through resource conservation, waste reduction, and pollution prevention. We continuously work to improve our environmental performance and support sustainable aviation initiatives.

7.3 Responsible Disposal

We dispose of aviation parts and materials responsibly, in accordance with applicable regulations and industry best practices. We ensure proper handling of hazardous materials and implement appropriate recycling programs.

8. Information Protection

8.1 Confidential Information

We protect confidential information of InfinityAero, our customers, and business partners. We do not disclose confidential information to unauthorized persons and use it only for legitimate business purposes.

8.2 Intellectual Property

We respect intellectual property rights. We protect InfinityAero's intellectual property and do not infringe on the intellectual property rights of others.

8.3 Data Privacy

We respect privacy and protect personal information. We collect, use, store, and transfer personal information in compliance with applicable data protection laws and our Privacy Policy.

8.4 Information Security

We implement appropriate security measures to protect information assets from unauthorized access, use, disclosure, disruption, modification, or destruction. We follow established information security protocols and regularly assess and address security risks.

9. Customer and Supplier Relations

9.1 Customer Focus

We are committed to understanding and meeting our customers' needs. We deliver high-quality aviation parts and services and strive to exceed customer expectations. We address customer concerns promptly and fairly.

9.2 Responsible Sourcing

We source materials and services responsibly. We conduct appropriate due diligence on suppliers and expect them to comply with applicable laws and ethical standards. We strive to work with suppliers who share our commitment to quality, safety, and ethical business practices.

9.3 Fair Treatment

We treat our suppliers fairly and with respect. We select suppliers based on objective criteria such as quality, reliability, service, price, and ethical standards. We honor our commitments to suppliers and pay them in accordance with agreed terms.

10. Compliance with Laws and Regulations

10.1 Legal Compliance

We comply with all applicable laws, regulations, and industry standards in the jurisdictions where we operate. We stay informed about legal developments affecting our business and take necessary steps to ensure ongoing compliance.

10.2 Regulatory Cooperation

We cooperate with regulatory authorities and respond truthfully and completely to regulatory inquiries and investigations. We maintain open and constructive relationships with regulatory authorities.

11. Implementation and Compliance

11.1 Training and Communication

We provide regular training and communications to ensure awareness and understanding of this Code. We make this Code available to all employees and relevant stakeholders and provide resources to help them comply with it.

11.2 Reporting Concerns

We encourage reporting of known or suspected violations of this Code, company policies, or laws. We provide multiple channels for reporting concerns, including through management, Human Resources, Legal, and our Ethics Hotline.

11.3 Non-Retaliation

We prohibit retaliation against anyone who reports concerns in good faith or participates in an investigation. Any form of retaliation is a violation of this Code and may result in disciplinary action.

11.4 Enforcement

We take violations of this Code seriously. Violations may result in disciplinary action, up to and including termination of employment or business relationship. We may also report violations to relevant authorities when appropriate.

12. Amendments and Waivers

This Code may be amended from time to time to reflect changes in laws, regulations, or business requirements. Any amendment will be communicated appropriately. Waivers of this Code for directors or executive officers may only be granted by the Board of Directors and will be disclosed as required by law or regulation.

13. Contact Information

If you have questions about this Code or need guidance on a specific situation, please contact:

Ethics and Compliance Office
InfinityAero
7901 4th St N,
St. Petersburg, Florida, USA

Email: ethics@infinityaero.com

14. Acknowledgment

By working with or for InfinityAero, you acknowledge that you have read and understand this Code of Conduct and agree to abide by its principles and requirements. You also understand that compliance with this Code is a condition of your employment or business relationship with InfinityAero.

This Code of Conduct has been approved by the Board of Directors of InfinityAero.

InfinityAero - Committed to Excellence, Safety, and Integrity in Aviation