1.1 Our standard. We build propulsion that flies in aircraft, defence systems and robots. Customers trust us with their missions, and governments trust us with sensitive technology. That trust is earned by building products that work exactly as we say they do, and by doing business honestly. We would rather lose an order than win it the wrong way.

1.2 Who it applies to. This Code applies to every director, officer, employee, trainee, intern and contract worker of Vector Technics Private Limited and its subsidiaries ("Vector Technics", "we"), wherever they work. We expect agents, distributors, consultants and suppliers acting for us to meet the same standards; suppliers are bound by our Supplier Code of Conduct.

1.3 Law and this Code. We obey the law in every country where we operate. This Code sets a higher standard in many areas. Where local law and this Code differ, follow the stricter rule; if they conflict, follow the law and tell the Compliance Officer.

1.4 The decision test. When the right course is not obvious, ask:

1. Is it legal?
2. Is it consistent with this Code and our policies?
3. Would I be comfortable if it were reported in the newspaper, or explained to a customer, a court or my family?
4. Would a falsified or shortcut result put a pilot, an operator or a member of the public at risk?

If the answer to any question is no, or you are unsure, stop and ask your manager or the Compliance Officer before acting.

1.5 Managers' extra duty. Managers must lead by example, make sure their teams understand this Code, never pressure anyone to cut corners on quality, safety or compliance to meet a target, and act on concerns raised to them.

2.1 No bribery, ever. You must never offer, promise, give, ask for or accept a bribe, kickback or any improper advantage, directly or through anyone else, to win or keep business or gain any improper benefit. This applies to dealings with private companies and with public officials, including officers of the armed forces, defence agencies, public sector undertakings, customs, tax, licensing and inspection authorities. Facilitation payments to speed up routine government action are also prohibited, even where they are customary. The only exception is a payment demanded under threat to someone's safety; make it, then report it to the Compliance Officer the same day. Section 9 of the Prevention of Corruption Act, 1988 makes the company liable for bribes paid by anyone acting for it; the US Foreign Corrupt Practices Act and the UK Bribery Act 2010 can also apply to our international business.

2.2 Agents, distributors and consultants. We remain responsible for what third parties do for us. Before appointing any agent, distributor or consultant who will deal with customers or officials on our behalf, the Compliance Officer must approve them after a due-diligence check. Commissions must be reasonable for the services actually performed, paid only into an account in the agent's own name in its own country, and supported by invoices. Warning signs include requests for cash, payment to third parties or offshore accounts, unusually high commissions, and refusal to sign anti-bribery terms.

2.3 Gifts and hospitality. You may accept or give modest gifts and hospitality that are customary, infrequent and not intended to influence a decision. You must not: give or accept cash or cash equivalents; give or accept any gift or hospitality worth more than INR two thousand (₹2,000) per person per occasion without the Compliance Officer's written approval; give or accept anything, of any value, from a party in an ongoing tender, negotiation or audit; or give anything to a public official without prior approval. Record every gift and hospitality above that limit, offered or received, in the gifts register. Travel and accommodation for our employees on company business is paid by Vector Technics, not by customers or suppliers.

2.4 Conflicts of interest. Avoid situations where your personal interests conflict, or appear to conflict, with those of Vector Technics. Declare to your manager and the Compliance Officer, in writing, before it affects any decision: any financial interest in a customer, supplier, distributor or competitor; any family member working for one; any outside employment, directorship or business; and any opportunity you learn of through your work. Directors also make the disclosures required by the Companies Act, 2013.

2.5 Fair competition. We compete on performance, quality and price. Never agree or exchange information with competitors on prices, bids, customers, territories or capacity, and never rig a tender. Obtain competitor information only from lawful public sources or customers' lawful disclosures, never by misrepresentation or from a competitor's former employee's confidential knowledge. This complies with the Competition Act, 2002 and equivalent laws abroad.

2.6 Insider information. Information you learn at work about a listed company, such as a customer's order, a partner's programme or a supplier's results, may be unpublished price-sensitive information. Do not buy or sell that company's securities, or advise anyone else to, while you have such information, and do not share it outside those who need it for work.

2.7 Accurate records. Every invoice, expense claim, timesheet, inspection record, test report and financial entry must be complete, accurate and supported. Never create false or misleading records, off-book accounts or side agreements, and never split transactions to avoid approval limits.

2.8 Money laundering and fraud. Accept payments only from the customer or a known financing bank, in the invoiced currency, through traceable channels. Report unusual payment requests, overpayments with refund requests, and any change of bank details that has not been verified by telephone.

3.1 Quality and the truth of our records. Never falsify, back-date, copy or invent any test result, inspection record, certificate of conformity, calibration record, traceability record or datasheet value, and never ship a product as passed when it has not been tested as required. Anyone may stop a shipment they believe is non-conforming; no one will be penalised for doing so in good faith. Falsifying quality records is a dismissal offence, whether or not the product was actually good.

3.2 Honest product claims. Every performance figure we publish or quote must be supported by test data under stated conditions. Never overstate certifications or claim one before the certificate is issued. Never describe a product as compatible with, or a replacement for, another manufacturer's product unless we have verified it.

3.3 Product safety. Report immediately any field failure, incident or test result suggesting a product could cause injury, fire or loss of an aircraft. Quality and engineering will decide on containment, customer notification and recall. Never hide or delay a safety issue to protect a delivery date.

3.4 Export controls and sanctions. Some of our products, drawings, firmware and test data may be controlled under India's SCOMET list and under the laws of other countries. Before quoting, shipping, emailing technical data abroad, or showing it to a foreign visitor, follow the export control procedure: check the product's classification, screen the customer and end user, and obtain any required authorisation and end-user certificate. Never help a customer avoid export rules, split shipments to avoid scrutiny, or ignore red flags about the end use. Stop and escalate if you are unsure.

3.5 Origin and compliance declarations. Only the authorised signatory may sign declarations of country of origin, restricted-source compliance (including US NDAA requirements), conformity or substance content, and only after checking the bill of materials. A false declaration exposes the company and the signatory to severe penalties.

3.6 Intellectual property and confidential information. Our designs, winding data, magnet and material specifications, processes, firmware, test data, prices, costs and customer information are our most valuable assets. Use them only for company work, share them only with people who need them and are bound by confidentiality, never take them with you when you leave, and never upload them to personal accounts or public AI tools not approved by the company. Respect others' rights: do not use a competitor's or former employer's confidential information, unlicensed software, or open-source code in our products without following the open-source procedure.

3.7 Personal data. Handle personal data of colleagues, customers and suppliers only for legitimate business purposes, following our Privacy Policy and the Digital Personal Data Protection Act, 2023. Report any suspected data breach to the Grievance Officer immediately.

3.8 Information security. Use strong passwords and two-step verification, lock your screen, never share credentials, report phishing and lost devices immediately, and connect only approved devices to company networks. Report any cyber incident at once; the company must report certain incidents to CERT-In within six hours.

4.1 Respect and equal opportunity. We hire, pay, train and promote on merit. We do not tolerate discrimination on the basis of caste, religion, race, colour, sex, gender identity, sexual orientation, age, disability, pregnancy, marital status, region, language, political opinion or union membership.

4.2 No harassment. Bullying, intimidation, abusive language, physical violence and sexual harassment are prohibited, in the workplace, at company events, while travelling and online. Complaints of sexual harassment are handled by our Internal Committee under the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 and our POSH policy, confidentially and within the time limits the Act sets.

4.3 Safety first. Every person has the right and the duty to stop work they believe is unsafe. Follow safety procedures and wear the protective equipment provided, especially around presses, winding machines, magnets, resins and solvents, battery and high-voltage testing, engine test cells and rotor and propeller testing. Report every injury and near miss. Never bypass a guard or interlock.

4.4 Fair employment. We pay at least the legal minimum wage, on time and in full, provide statutory benefits, respect working-hour limits, and never use child, forced or bonded labour, directly or through contractors. We expect the same of our labour contractors and check it.

4.5 Alcohol, drugs and weapons. Do not work under the influence of alcohol or drugs, and do not bring personal weapons onto company premises. Report to work fit to operate machinery and to make safe decisions.

4.6 Visitors and site security. Our facility manufactures products for defence customers. Escort all visitors, record their entry, and never allow photography or access to restricted areas without authorisation.

5.1 Company assets. Use company equipment, materials, vehicles, funds and systems for company business, with limited personal use of IT that does not interfere with work or create risk. Scrap, samples and rejected parts are company property; never sell, give away or take them home. Our products and components in the wrong hands can be misused, so dispose of rejected parts only through approved channels.

5.2 Speaking for the company. Only the CEO and people the CEO authorises may speak to the media, investors, analysts or government bodies on behalf of Vector Technics. Refer all such enquiries to them.

5.3 Social media. Do not post confidential information, photographs of the shop floor, test areas, customer products or programmes, or comments about customers, competitors or pending business. Make clear that personal views are your own. Never post about defence customers or programmes, even after they become public, without approval.

5.4 Trade shows and publications. Technical papers, conference talks, trade-show exhibits and social posts about our technology must be approved in advance by the CTO, to protect patentability and to check export controls.

5.5 Political and charitable activity. You may take part in political activity in your own time and name. The company does not make political contributions except as approved by the Board and permitted by section 182 of the Companies Act, 2013. Charitable donations and corporate social responsibility spending follow the company's approval process and must never be used to influence a business decision.

6.1 What to report. Report any actual or suspected breach of this Code, our policies or the law, including bribery, fraud, falsified quality or test records, safety hazards, export control breaches, harassment, discrimination, retaliation, data breaches and environmental violations. You do not need proof; a reasonable, good-faith concern is enough.

6.2 Who can report. Employees, contract workers, former employees, suppliers, distributors, customers and members of the public.

6.3 How to report. Use whichever channel you are comfortable with:

Help us investigate by stating who was involved, what happened, when and where, how often, and what evidence exists.

6.4 What happens next. We acknowledge every report within seven (7) days where we can contact you. The Compliance Officer, or, for matters involving a director, the CEO or the Compliance Officer, a director not involved in the matter, decides who investigates, ensuring no one investigates a matter in which they are involved. Investigations are fair to everyone concerned, and the person accused has a chance to respond. Where we can, we tell you what action was taken within three (3) months, even if the investigation has not finished. Findings may lead to corrective action, disciplinary action, recovery of losses, or reporting to authorities.

6.5 Confidentiality and anonymity. We protect your identity and share it only with those who need it to investigate, unless you agree or the law requires disclosure. Anonymous reports are accepted and investigated, but they can be harder to follow up, so please give a way to contact you if you can.

6.6 No retaliation. No one will be dismissed, demoted, transferred, harassed, denied a benefit, or have a contract terminated for raising a concern in good faith or helping an investigation, even if the concern turns out to be unfounded. Retaliation is itself a serious breach of this Code and leads to disciplinary action. If you believe you have suffered retaliation, report it through any channel above.

6.7 False reports. Knowingly making a false report to harm someone is a disciplinary offence. A report made in good faith that proves mistaken is not.

7.1 Compliance Officer. The Board appoints a Compliance Officer, who has direct access to the Board. Until one is appointed, the CEO performs this role. Employees and contract workers reach the Compliance Officer at hr@vectortechnics.com; anyone outside Vector Technics at legal@vectortechnics.com. The Compliance Officer interprets this Code, approves the exceptions it allows, maintains the gifts and conflicts registers, runs training, and reports to the Board every quarter on reports received, investigations and their outcomes, without identifying reporters.

7.2 Consequences. Breaching this Code, the law, or our policies, failing to report a breach you know of, or retaliating against someone who reports, may lead to disciplinary action up to dismissal, termination of contracts, recovery of losses and referral to the authorities, in accordance with applicable law and our disciplinary procedure.

7.3 Waivers. Only the Board may waive a provision of this Code for a director or officer, and only the Compliance Officer for other staff. Every waiver is recorded with reasons.

7.4 Training and acknowledgement. Every new joiner receives this Code at induction and confirms they have read it. All staff complete annual training and an annual acknowledgement. Sales, purchasing, logistics, engineering and quality staff receive additional training on anti-bribery, export controls and record integrity.

7.5 Review. The Compliance Officer reviews this Code at least once a year and proposes updates to the Board.

Contact. Vector Technics Private Limited, Plot No. 2-12, SY No. 37/A, Rasheedguda, Shamshabad, Rangareddy, Telangana 501218, India
Phone: +91 40 2933 0019
Speak Up (employees): hr@vectortechnics.com
Speak Up (everyone else) and legal: legal@vectortechnics.com