Social Responsibility

Conflict Minerals Policy

About ADI American Distributors LLC global aerospace supplier: Due to violence and human rights violations related to the mining of minerals from the Conflict Region in the eastern portion of the Democratic Republic of Congo and surrounding countries, ADI supports U.S. legislation and we ask our suppliers to undertake reasonable due diligence with their supply chains to determine that the minerals they use are processed in conflict-free facilities.

—

ADI American Distributors Business Ethics Policy

Purpose

This policy has been created to provide a framework and guidance on the company’s approach to achieving and maintaining good business behavior by means of sound ethical conduct. It serves to ensure that all employees are aware of their individual and collective responsibilities with regards to the company’s ethics, and to emphasize our employees’ and customers’ expectations to being treated fairly and in accordance with good business practices.

All employees are responsible for reading this document in its entirety and for ensuring that they comply with all the policy requirements as stated within this document. The purpose of this ethics policy is to maintain a culture of openness, trust and integrity in the company’s business practices.  Effective ethics is a ‘team effort’ involving the participation and support of every ADI American Distributors employee.

ADI American Distributors is committed to protecting employees, business partners and suppliers from illegal or damaging actions by individuals, either knowingly, or unknowingly. When ADI American Distributors addresses issues proactively and uses correct judgement, it will help to set the company apart from its competitors and help further enhance its reputation. ADI American Distributors will not tolerate any wrongdoing or impropriety at any time. The company will take the appropriate measures and act quickly where our ‘ethical code’ is broken.

Scope

This policy applies to all employees, contractors, consultants and part time employees of ADI American Distributors.

Policy

ADI American Distributors Senior Management teams commitment to Ethics is:

  *   That Integrity is one of the company’s core values

  *   To set and lead by example. In any business practice, honesty and integrity are of the highest importance

  *   To have an open-door policy and welcome suggestions and concerns from all employees.

This creates an environment that will allow employees to feel comfortable discussing any issues and will serve to alert the ADI Senior Management team to concerns within the company.

ADI Employee’s commitment to Ethics:

  *   To disclose any conflicts of interests regarding their position with the company

  *   To engage in carrying out the company’s mission in a professional manner and in line with the core values of the company which includes integrity

  *   To recognize that the main function of the company is at all times to serve the best interests of its current and future customers, and to do this with respect, concern, courtesy and responsiveness

  *   To treat everyone fairly, have mutual respect, promote a team environment and avoid the intent and appearance of unethical or compromising practices

  *   To treat all persons with respect and consideration, regardless of race, religion, gender, sexual orientation, maternity, marital or family status, disability, age or national origin

  *   To respect the structure and responsibilities of management, provide them with facts and advice as a basis for decision and policy making, and uphold and implement decisions and policies adopted by management

  *   To demonstrate the highest standards of personal integrity, truthfulness and honesty in all activities in order to inspire confidence and trust in such activities, both internally and externally

  *   To strive for personal and professional excellence, encourage the professional development of others and keep up to date on emerging issues affecting the Company

  *   To conduct themselves at all times with professional competence, fairness and impartiality

Company’s commitment to Ethics:

  *   To hold paramount the safety, health and welfare of the public in the performance of the company’s professional duties

  *   To keep the local communities informed about issues which may affect them

  *   To collaborate with and support partners in carrying out the company’s mission and in line with the company’s ethics policy

  *   To build professional reputations on the merit of our capabilities and refrain from competing unfairly with others

  *   Not to engage in any business practice or process or with any entity, including potential customers, that does not match the Company’s ethical standards

Governance and Review

Should an employee be in any doubt about a relevant course of action, require clarification on a particular issue or want to report a potential breach of ADI ethical code, they should report directly to their line Manager / Senior Manager.  The topic / issue will then be dealt with as quickly and efficiently as possible, and by the Managing Director if appropriate.

This policy will be held by the ADI American Distributors Senior Management Team and will be reviewed annually to ensure that it remains relevant, both internally with all employees and externally regarding changing social and moral attitudes and business best practice.

Modern Slavery and Human Trafficking Statement

ADI American Distributors are committed to ensuring that its staff are not subject to behavior or threats that may amount to modern slavery, human trafficking, forced labor, and or similar human rights abuses. We are also committed to ensuring our approach to tackling modern slavery in our own business and throughout our supply chains is consistent with our disclosure obligations under the Modern Slavery Act 2015. We all have a responsibly to be alert to the risks, however small, in our business and in the wider supply chain.

This statement sets out ADI’s actions to understand all potential modern slavery risks related to the business and to ensure steps are maintained to prevent both slavery and human trafficking.

Our Business

ADI American Distributors are distributors of electronic and electro-mechanical components to the aerospace and defense industry, ADI distribute components within this industry globally. ADI have several facilities in the US, UK and India.  With the corporate head office being based in Randolph New Jersey.

Our Policies

ADI’s Modern Slavery Policy, along with our Business Ethics Policy reflect our commitment to acting ethically and with integrity in all our business relationships.

Our Processes for Managing Risk

In order to assess the risk of modern slavery, we use the following processes:

  *   Identify and assess potential risk areas when considering taking on new suppliers and regularly review our existing supply chain.

  *   Review the potential for risk at regular intervals, including the possibility of auditing and / or re-auditing a supplier.

  *   Protect whistle blowers.

After due consideration, we have not identified any significant risks of modern slavery, forced labor, or human trafficking in our supply chain. However, we continue to be alert to the potential for problems.

Training

To maintain awareness and ensure a high level of understanding of the risks of modern slavery and human trafficking in our business our Modern Slavery Policy is to be read by all ADI employee’s. We provide training to all members of staff and this has been incorporated into our induction programmed.

Our Commitment

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes ADI’s slavery and human trafficking statement.  This policy has been approved and signed off by ADI’s senior management team, who will review and update it annually.

David Beck
CEO / President
On Behalf ADI American Distributors.