CODE OF ETHICS & STANDARDS OF PROFESSIONAL CONDUCT
PPHU Navcom Systems s.c.

Professionalism.
Honesty and integrity.
Great care for our clients and for our reputation.
Respect for people and the environment.
Social responsibility.
Cooperation.
Compliance with the highest ethical standards in every aspect of our business.

Our Mission

Our mission is to provide the best services to satisfy the needs of our clients by being timely, reliable, and innovative while maintaining the highest quality standards

Our Vision

We envision ourselves as a leading aviation company, technically strong and financially sound, able to execute any assignment no matter how big or small, to help achieve our clients’ goals.

§ 1

1. This document describes the rules that we apply to our business. These rules regulate the everyday actions of our Board of Directors, employees, and our contractors in contact with other employees, clients and third party contractors..
2. NAVCOM Systems’ Code of Ethics & Standards of Professional Conduct, combines respect for the law and all regulations, with upholding human dignity and the highest ethical standards. This document is a framework for every action and dealing made by PPHU Navcom Systems s.c. with the flexibility to develop and implement new rules to reflect today’s changing business environment.
3. This document is a guide that describe the rules that we apply to our clients, partners, employees, and contractors.
4. We believe that cooperation is based in the TRUST that we gain every day by staying in touch with our clients electronically and in person.
5. Our Code of Ethics & Standards of Professional Conduct defines not only the rules, but the guidelines and recommendations that we apply to our work every day.
6. The Code of Ethics & Standards of Professional Conduct applies to all employees and contractors of PPHU Navcom Systems s.c..
7. The rules described in The Code of Ethics & Standards of Professional Conduct must be followed by any person representing PPHU Navcom Systems s.c. with no exceptions. Breaking these rules is prohibited and will not be not tolerated.
8. If any of the rules described in The Code of Ethics & Standards of Professional Conduct are broken, management will take the necessary steps in accordance with the law.

§ 2

1. Board of directors, management, employees, and contractors are obligated to::
   • respect the law and all internal regulations,
   • respect all cultures, religions, and ideological views of other employees, contractors, clients, and trading partners,
   • care for the environment,
   • act ethically, responsibly, and in a way that is worthy of emulation, regardless of position or type of cooperation with PPHU Navcom Systems s.c.,
   • take actions to prevent and resolve any expression of discrimination or oppression, both within the company and during business dealings, by referring to this Code of Ethics and following its instructions. We uphold all our employees lawful right to terminate their contracts after a notice period.
2. PPHU Navcom Systems s.c. offers the best quality products and services. All employees are obligated to observe the company’s ethical standards and to cooperate in upholding them.
3. Then needs and expectations of our clients determine our work. We work for our clients and for their benefit. We strive to predict their needs and to adapt our operations to an ever-changing business environment.
4. We focus the quality of our services on the principle: we deliver what we promised, because we aspire to earn the trust of our clients and develop our operations within a challenging market.
5. We believe that integrity and mutual respect are key factors that help us earn our clients’ trust.
6. Mutual respect for co-workers and clients is an important value that leads to better cooperation with each other.
7. We believe in team work. All our employees and collaborators operate as one big team; we believe in the importance of communication and the need to express different opinions and to share information.
8. We listen to each other, openly discuss problems and difficult issues. We always look for the best solution and believe that finding it is only possible when observing the problem from different perspectives.
9. We support open internal communications within our company, and seek to involve our employees in decision making and problem solving whenever possible.
10. Every person representing PPHU Navcom Systems s.c. is fully responsible for preforming his/her duties effectively and professionally. Every employee is obligated to inform his/her supervisor about errors and failed business processes and to be a part of seeking and implanting solutions. .
11. We believe in constructive criticism. When offering criticism, we focus on the problems not on our people.
12. We strive to create and maintain the best possible work environment. We care about the cleanliness of our workplace.
13. All our employees, including the management team, are obligated to observe the highest safety standards and procedures. All employees must be ready to help those in need, in case of a threat or accident.
14. PPHU Navcom Systems s.c. reinforces data-security and cyber-security. We protect our company’s, clients, and vendors data in every possible way, using all possible methods, tools, and software.
15. The personal data of our clients and employees are strictly confidential and while processing it, we exercise the most professional due diligence to protect them, and to prevent data from leaking to unauthorized parties.
16. Our company focuses on the effectiveness of our operation and on achieving the best results. We give credit to our employees and reward them according to their individual competencies and skills. We create a work environment where everyone feels that his/her achievements are appreciated, and where employees can develop professionally and grow personally.
17. All employees of PPHU Navcom Systems s.c. are expected to grow intellectually and to upgrade and broaden their skills on a regular basis.
18. All employees are expected to be loyal to PPHU Navcom Systems s.c. In external communication, we must present an image consistent with our company, which shows our focus on quality and values.
19. When making business decisions we must keep in mind the best interest of PPHU Navcom Systems s.c.
20. Private issues or personal benefits must not influence professional relationships nor business decisions.
21. Any form of corruption is strictly prohibited. We avoid all actions that can be qualified or perceived as would-be corrupt activities.
22. Fair play is our main rule in everyday work.
23. We respect the services and products of our competitors and observe the rules of fair-trade and market competition. We do not spread misinformation about the products or services of our competitors. We do not resort to unfair methods to gain advantage over our competitors.
24. We are aware of our place in society and work to empower social responsibility in our business and practice these rules whenever possible.

§3

Best Practices

• We do not use child labor.
• We ensure work hours and rest hours in accordance with the law.
• We do not use mandatory overtime.
• We provide adequate compensation in accordance with the law.
• We comprehensibly inform all employees in writing about wages terms and conditions.
• Regarding deductions from salary, we adhere to the terms in the Labor Code.
• We do not use deductions from salary as disciplinary measures.
• We provide all our employees a safe and healthy work environment in accordance with the law.
• We have a dedicated employee, responsible for implementing OSH, Occupational Health and Safety Code, daily.
• We provide OSH training to all our employees.
• Using his/her position in PPHU Navcom Systems s.c., by any employee, to gain unauthorized personal benefits and profits is strictly prohibited.
• Our employees are not authorized to conduct competitive activities without official permission, these include professional activities, business activities, or trading and cooperating with private persons and/or legal entities whose interests may conflict with the interests of our company.
• Retrieving company property for personal use or for re-sale is strictly prohibited.
• The visual/graphic identity of PPHU Navcom Systems s.c. may be used only for professional purposes.
• All employees are obligated to protect both PPHU Navcom Systems s.c. property and our clients’ property against theft, loss, damage, and misuse.

§4

1. The Code of Ethics & Standards of Professional Conduct became effective on Sept. 03, 2012 /with revisions made on Jan. 01, 2014
2. If there are questions, please consult with PPHU Navcom Systems s.c. management.

Świdnik, Sept. 01, 2014.