1.1 Why this Code exists. Vector Technics designs and manufactures propulsion systems, motors, controllers, propellers and engines that fly in unmanned aircraft, aerospace and defence systems, and robots. Our products are only as safe, reliable and trustworthy as the supply chain behind them. This Code sets the minimum standards of conduct we require from every supplier, so that what reaches our customers is built lawfully, safely, honestly and securely.

1.2 Who it applies to. This Code applies to every person that supplies goods, materials, components, software, services, tooling or labour to Vector Technics Private Limited, CIN U31900TG2022PTC165278, Plot No. 2-12, SY No. 37/A, Rasheedguda, Shamshabad, Rangareddy, Telangana 501218, or its affiliates ("VT"), including manufacturers, distributors, contract manufacturers, service providers, consultants, contract-labour agencies and logistics providers (each a "Supplier"), and to their employees, agents and sub-suppliers at every tier involved in work for VT.

1.3 Standards it is built on. This Code is based on the laws of India and on internationally recognised standards, including the Universal Declaration of Human Rights, the UN Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work and the ILO core conventions, the OECD Guidelines for Multinational Enterprises, the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals, and the Responsible Business Alliance Code of Conduct.

1.4 Law first, then the higher standard. Suppliers shall comply with all applicable laws in every country where they operate. Where this Code sets a higher standard than local law, the Supplier shall meet the higher standard, unless doing so would itself breach the law. Where law and this Code conflict, the Supplier shall comply with the law and inform VT in writing.

1.5 Contractual effect. This Code forms part of every contract between VT and a Supplier through clause 7.9 of VT's General Terms and Conditions of Procurement and any supply agreement that refers to it. A breach of this Code is a breach of contract. Accepting a VT purchase order constitutes acceptance of the version of this Code in force on the date of the order.

1.6 Our commitment in return. VT is committed to meeting these standards in its own operations. We will explain this Code to our Suppliers, give reasonable time to correct shortcomings that are not serious, pay our micro and small enterprise Suppliers within the period required by law, and protect anyone who raises a concern in good faith.

2.1 Freely chosen employment. Suppliers shall not use forced, bonded, indentured, trafficked or involuntary prison labour, in any form. In particular, Suppliers shall not: retain workers' passports, identity documents or work permits; charge workers recruitment fees or related costs, directly or through agents; use debt, deposits or withheld wages to bind workers; or restrict workers' freedom to leave the workplace after their shift or to resign on reasonable notice. Employment terms shall be given to each worker in writing, in a language they understand, before they start work. Suppliers shall comply with the Bonded Labour System (Abolition) Act, 1976 and equivalent law elsewhere.

2.2 No child labour; protection of young workers. Suppliers shall not employ any person below the age of fifteen (15), the age for completing compulsory education, or the minimum working age under local law, whichever is highest, consistent with ILO Conventions 138 and 182 and the Child and Adolescent Labour (Prohibition and Regulation) Act, 1986. Workers under eighteen (18) shall not perform hazardous work, night work or overtime. Suppliers shall verify the age of every worker with reliable documents and keep records. If a child is found working, the Supplier shall remove the child from work and fund a remediation plan in the child's best interest, including support to attend school, and shall not simply dismiss the child.

2.3 Wages and benefits. Suppliers shall pay at least the applicable statutory minimum wage under the Code on Wages, 2019 or local law, pay overtime at the legal premium rate, provide all legally mandated benefits including provident fund, employees' state insurance, gratuity, bonus and paid leave, pay wages on time and in full, and give each worker a clear wage statement. Deductions from wages as a disciplinary measure are prohibited. Suppliers are encouraged to move towards a living wage.

2.4 Working hours. Working hours shall not exceed the limits set by law. Unless local law sets a lower limit, a working week shall not exceed sixty (60) hours including overtime, except in genuine emergencies, and all overtime shall be voluntary. Workers shall have at least one (1) day off in every seven (7) days and the rest breaks, holidays and paid leave required by law.

2.5 Non-discrimination and equal opportunity. Suppliers shall not discriminate in hiring, pay, promotion, training, discipline or termination on the basis of race, caste, colour, religion, sex, gender identity, sexual orientation, age, disability, pregnancy, marital status, nationality, ethnic or social origin, political opinion or union membership. Suppliers shall not require pregnancy tests or medical tests used to discriminate, and shall provide reasonable accommodation for workers with disabilities as required by the Rights of Persons with Disabilities Act, 2016 and equivalent law.

2.6 Dignity, harassment and abuse. Suppliers shall treat all workers with dignity and respect. Physical punishment, threats, verbal abuse, bullying, intimidation and sexual harassment are prohibited. Suppliers in India shall comply with the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013, including constituting an Internal Committee where required.

2.7 Freedom of association. Suppliers shall respect workers' rights to form and join trade unions of their choosing, to bargain collectively and to engage in peaceful assembly, in accordance with local law, and shall not discriminate against or penalise worker representatives. Where these rights are restricted by law, Suppliers shall allow workers to elect representatives and engage with them openly.

2.8 Contract and migrant workers. Suppliers remain responsible for the conduct of their labour agencies and contractors. Suppliers shall ensure that contract and inter-state migrant workers receive the same legal protections, wages and benefits as directly employed workers, are lawfully registered, and are not charged recruitment fees, and shall provide safe and decent accommodation where accommodation is provided.

2.9 Privacy of workers. Suppliers shall protect the personal data of their workers in accordance with the Digital Personal Data Protection Act, 2023 and other applicable law, and shall use workplace monitoring only for legitimate purposes and with notice to workers.

3.1 Safety management system. Suppliers shall comply with the Occupational Safety, Health and Working Conditions Code, 2020 and equivalent law, hold every licence, registration, fire no-objection certificate and building approval required for their premises, and operate a documented occupational health and safety management system. Certification to ISO 45001 is expected for Suppliers of Critical Items and for any Supplier with more than one hundred (100) workers.

3.2 Hazard identification and control. Suppliers shall identify and assess workplace hazards and control them in this order: eliminate, substitute, engineer, administer, then protect with personal protective equipment provided free of charge and properly maintained. Hazards common in VT's supply chain that Suppliers shall specifically control include:

• press, stamping, winding, machining and rotating equipment: machine guarding, interlocks and lock-out/tag-out;
• high-energy permanent magnets: crush and pinch injuries, projectile risk, and exposure of workers with implanted medical devices;
• magnet grinding and machining swarf: fire and dust;
• resins, varnishes, adhesives, solvents and carbon-fibre composites: ventilation, respiratory and skin protection, and dust control;
• soldering fumes, lead and other hazardous substances in electronics manufacture;
• lithium batteries and high-voltage test equipment: thermal runaway and electrical safety;
• fuels and engine test cells: fire, explosion, exhaust gas and noise;
• rotor, propeller and motor testing: containment of failed parts.

3.3 Emergency preparedness. Suppliers shall maintain emergency plans, fire detection and suppression, clearly marked and unobstructed exits, emergency lighting, first-aid facilities and trained responders, and shall conduct evacuation drills at least once a year. Exits shall never be locked during working hours.

3.4 Incidents. Suppliers shall record, investigate and correct the root cause of all work-related injuries, illnesses and near misses, report them to authorities as required by law, and notify VT within forty-eight (48) hours of any fatality or serious injury at a site performing work for VT.

3.5 Training and worker participation. Workers shall be trained, in a language they understand, on the hazards of their job and safe methods of work before starting and whenever these change. Workers have the right to refuse unsafe work and to report safety concerns without retaliation.

3.6 Facilities and accommodation. Suppliers shall provide clean toilets, safe drinking water, hygienic eating areas, adequate lighting and ventilation, and, where accommodation is provided, safe, clean and adequately spaced housing with emergency exits and reasonable privacy.

4.1 Permits and management system. Suppliers shall obtain and keep current all environmental permits, including consents to establish and operate from the relevant State Pollution Control Board, and comply with their conditions and with the Environment (Protection) Act, 1986, the Water (Prevention and Control of Pollution) Act, 1974, the Air (Prevention and Control of Pollution) Act, 1981 and equivalent law. Suppliers shall operate an environmental management system; certification to ISO 14001 is expected for Suppliers of Critical Items.

4.2 Waste and pollution. Suppliers shall minimise waste, emissions and wastewater, and handle, store, transport and dispose of hazardous waste only through authorised operators, in compliance with the Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016, the E-Waste (Management) Rules, 2022, the Battery Waste Management Rules, 2022 and the Plastic Waste Management Rules, 2016, including extended producer responsibility obligations. Spent solvents, resins, plating and etching chemicals, magnet swarf and electronic scrap shall never be released into drains, soil or general waste.

4.3 Hazardous substances. Suppliers shall identify, label, store and handle hazardous substances safely, keep current safety data sheets, maintain spill-response procedures, and notify authorities and communities of accidental releases as required by law. Products supplied to VT shall comply with the restricted-substance requirements in VT's General Terms and Conditions of Procurement, including RoHS, REACH and the E-Waste (Management) Rules, 2022.

4.4 Resources and climate. Suppliers shall track and work to reduce their energy use, water use and greenhouse gas emissions, and shall provide this data to VT on request to support VT's and its customers' sustainability reporting, including emissions associated with goods supplied to VT.

4.5 Responsible sourcing of minerals. Suppliers shall exercise due diligence, consistent with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, on the sourcing of tin, tantalum, tungsten and gold, cobalt and mica, and the rare-earth elements and other materials used in permanent magnets, so that they do not finance armed conflict or involve serious human rights abuses. Suppliers shall provide completed Responsible Minerals Initiative reporting templates (CMRT and EMRT) on request, prefer smelters and refiners validated as conformant, and disclose the country of origin of magnet materials when VT requests it.

5.1 Zero tolerance for bribery. Suppliers shall not offer, promise, give, request or accept any bribe, kickback, facilitation payment or other improper advantage, directly or through any third party, to or from any VT employee, customer, public official or other person, to obtain or retain business or any improper benefit. Suppliers shall comply with the Prevention of Corruption Act, 1988, the US Foreign Corrupt Practices Act, the UK Bribery Act 2010 and all other applicable anti-corruption law, and shall maintain adequate procedures to prevent bribery by persons acting for them. VT works with government and defence customers; any improper approach to a public official in connection with VT's business is grounds for immediate termination and referral to the authorities.

5.2 Gifts and hospitality. Suppliers shall not offer VT employees or their families any cash or cash equivalent, any gift or hospitality worth more than INR two thousand (₹2,000) per person per occasion, or any gift or hospitality, of any value, during a tender, negotiation or audit. Travel and accommodation for VT employees is paid by VT, not by Suppliers. Customary business meals of modest value are permitted.

5.3 Conflicts of interest. Suppliers shall disclose to VT in writing any financial, family or personal relationship with a VT employee or director that could influence, or appear to influence, a business decision, and any ownership or employment of a VT employee or close relative in the Supplier.

5.4 Fair competition. Suppliers shall comply with the Competition Act, 2002 and equivalent law, and shall not engage in price fixing, bid rigging, market or customer allocation, or exchange of competitively sensitive information with competitors, including in VT tenders.

5.5 Accurate records and anti-money laundering. Suppliers shall keep complete and accurate books, records and invoices, shall not create false or misleading documents, and shall comply with the Prevention of Money-Laundering Act, 2002 and equivalent law. Payments shall be made only to bank accounts held in the Supplier's own name in the country where it operates, and changes to bank details shall be confirmed in writing by an authorised signatory and verified by VT before use.

5.6 Confidentiality and intellectual property. Suppliers shall protect VT's confidential information and intellectual property in accordance with their contract with VT, use it only for VT's work, and notify VT immediately of any suspected loss, misuse or infringement. Suppliers shall respect the intellectual property of third parties and use only properly licensed software and technology.

5.7 Data privacy and information security. Suppliers shall protect personal data in accordance with the Digital Personal Data Protection Act, 2023 and other applicable law, maintain information security controls appropriate to the information they hold, and report security incidents affecting VT's information or systems to VT without delay.

5.8 Communications and publicity. Suppliers shall not publicise their relationship with VT or its customers, or use VT's name or brand, without VT's prior written consent, and shall not make statements on VT's behalf.

6.1 Integrity of quality records. VT's products fly. A falsified record can cost a life. Suppliers shall never falsify, back-date, alter, copy or fabricate any certificate of conformity, material certificate, inspection or test result, calibration record, first article inspection report or traceability record, and shall never ship product that has not passed the required inspections while representing that it has. Any such act is a serious breach of this Code, regardless of whether the product was in fact conforming, and will result in termination and may be reported to customers and authorities.

6.2 Product safety awareness. Suppliers shall ensure their personnel understand that their work contributes to the safety of aircraft and people, know the consequences of nonconforming product, and are encouraged to stop work and raise concerns about product safety or quality without fear of retaliation.

6.3 Counterfeit prevention. Suppliers shall buy components only from original manufacturers or their authorised distributors, maintain controls to detect and prevent counterfeit and suspect parts, and report any suspected counterfeit part to VT within twenty-four (24) hours.

6.4 Transparency of origin and ownership. Suppliers shall give VT accurate, complete and current information on the country of origin of the goods and materials they supply, on their manufacturing locations and sub-suppliers, and on their ownership and control, including any owner or controlling person based in a country sharing a land border with India. Suppliers shall never misdeclare origin, transship goods to disguise origin, or substitute materials or sub-suppliers without VT's approval.

6.5 Export controls and sanctions. Suppliers shall comply with all applicable export control, customs and sanctions laws, including India's SCOMET controls and the laws of the United States, European Union and United Kingdom. Suppliers shall classify their goods and technology accurately, obtain required licences, screen their counterparties, and shall not deal with sanctioned persons or territories in connection with VT's business.

6.6 Defence and sensitive information. Some of VT's work supports defence and national security customers. Suppliers shall handle drawings, specifications and programme information marked as restricted, classified or controlled only as instructed by VT and as required by applicable law, including the Official Secrets Act, 1923 where it applies; limit access to cleared or authorised personnel; and report any loss, unauthorised access or suspicious enquiry about VT, its products or its customers to VT immediately.

6.7 Security of products and systems. Suppliers of software, firmware, electronics or connected equipment shall develop and deliver them securely, shall not include hidden functions, remote-disable features or undisclosed data transmission, and shall disclose known vulnerabilities to VT promptly. Suppliers shall protect their own networks against intrusion and shall not allow VT's data to be stored or processed in locations VT has not approved.

7.1 Accountability. Each Supplier shall appoint a senior manager responsible for compliance with this Code, adopt written policies covering its requirements, and allocate the resources needed to meet them.

7.2 Communication and training. Suppliers shall communicate this Code, or policies at least as protective, to their workers in a language they understand, and train relevant personnel, including managers, buyers, quality staff and labour agencies, on its requirements.

7.3 Sub-supplier due diligence. Suppliers shall flow down the requirements of this Code to their sub-suppliers and labour agencies, assess them for risk, and monitor their compliance. Suppliers remain responsible to VT for breaches by their sub-suppliers in connection with VT's work.

7.4 Records. Suppliers shall keep the records needed to demonstrate compliance with this Code, including age verification, wage and hours records, permits, training, incident and waste records, for at least eight (8) years.

7.5 Self-assessment and audit. Suppliers shall complete VT's self-assessment questionnaire when requested and provide supporting evidence. VT, or an independent auditor appointed by VT, may audit a Supplier's sites and records for compliance with this Code on reasonable notice, or without notice where VT has reasonable grounds to suspect a serious breach. Auditors may interview workers privately and without management present, and Suppliers shall not coach, threaten or penalise workers for what they say.

7.6 Corrective action. Where VT identifies a shortcoming, the Supplier shall agree and carry out a time-bound corrective action plan, address the root cause, and provide evidence of completion. VT will support Suppliers making genuine progress.

7.7 Consequences. VT's response will be proportionate to the seriousness of the breach and the Supplier's response. VT may require corrective action, suspend new orders, reduce business, or terminate any or all contracts with immediate effect, as provided in its General Terms and Conditions of Procurement. The following are treated as zero-tolerance breaches that ordinarily lead to termination: forced, bonded or child labour; bribery; falsification of quality or compliance records; knowing supply of counterfeit parts; serious, uncorrected risks to life or health; deliberate breach of export controls or sanctions; and retaliation against a person who raised a concern.

7.8 Continuous improvement. VT recognises Suppliers that exceed these standards, and will take a Supplier's performance under this Code into account in sourcing decisions and supplier ratings.

8.1 Supplier grievance channels. Suppliers shall provide their workers, and the workers of their sub-suppliers and labour agencies, with an effective way to raise concerns about conditions at work or breaches of this Code, including at least one channel that allows anonymous reporting and does not pass through the worker's direct supervisor. Concerns shall be investigated promptly and fairly, and the outcome communicated to the person who raised them where possible.

8.2 Reporting to VT. Anyone, including Supplier personnel, sub-supplier workers and members of the public, may report a suspected breach of this Code, or any unethical conduct by a VT employee, directly to VT at legal@vectortechnics.com with the subject "Speak Up", or by post marked "Confidential – Legal" to VT's registered office. Reports may be made anonymously, including from an email address that does not identify you. VT will treat reports confidentially, disclose a reporter's identity only with their consent or where required by law, investigate, and take appropriate action.

8.3 No retaliation. Suppliers shall not dismiss, demote, discipline, threaten, blacklist or otherwise retaliate against any person for raising a concern in good faith, cooperating with an investigation or refusing to take part in conduct that breaches this Code. VT will not reduce business with a Supplier because the Supplier itself reported a problem in good faith and acted to correct it. Retaliation is a zero-tolerance breach under clause 7.7. Knowingly false reports made to cause harm are not protected.

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 and legal: legal@vectortechnics.com