CFT Ukraine

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Code Of Business Conduct

We are required to conduct our business in compliance with all applicable laws and in an ethical manner. Ethical behavior, compliance with laws, and economic success are complementary goals – acting in an ethical and compliant manner is good for our business and has a positive impact on the product we create. Ethics and integrity, our people, social responsibility, and responsible manufacturing and service are the four themes that drive our work.

This Code sets out a number of key principles that are to be considered and applied by Employees in the performance of their day to day duties. this Code is intended to put forth certain guiding principles that Employees can look to in order to assess and evaluate situations that they may find themselves in from time to time. In many places this Code will reinforce or be supplemented by various policies and procedures that we already have in place, or that might be adopted from time to time.

This Code is based on the ATS Group Code of Conduct, as CFT-Ukraine is a part of ATS Automation Tooling Systems Inc.

All Employees of CFT-Ukraine are responsible for complying with the Code of Business Conduct. It is the responsibility of every Employee to know and understand this Code and any other policies of CFT-Ukraine relevant to their job or position.

Management at all levels of the Company is responsible for promoting awareness of, and ensuring adherence to, this Code and to assist Employees to resolve any questions or issues relating to the application of this Code.

We require ourselves to be ethical, compliant and fair in our internal and external business dealings. It is imperative that the Company and its management and employees work to maintain a healthy, safe and productive work environment for all.

We ask everyone to be proactive when it comes to safety initiatives – you can make a difference.

We strives to be a place where people want to work and is committed to diversity, inclusion, and employment equity. We must provide a work environment free from harassment, discrimination, violence, and in compliance with all workplace laws.

Our employees are the Company’s most valuable asset and each deserves a positive and productive work environment. Avoid personal behavior, both at work and outside of work, that harms our reputation.

Unfair business practices such as giving or receiving bribes or kickbacks are strictly prohibited, without exception, in all circumstances. Wemust not be associated in anyway with agreements between CFT-Ukraine and suppliers or any organization in where a have Family Member have an interest or which might result in personal gain a Family Member.

CFT-Ukraine Employees may not work for any organization that competes with the Company or that is a supplier or customer of CFT-Ukraine. This includes serving as a director, officer, trustee, partner, employee, consultant, or agent.

All Employees are required to follow safe work practices and comply with all applicable health and safety laws and regulations relating to their work, as well as all CFT-Ukraine health and safety policies. All Employees are expected to conduct the Company’s business in an environmentally responsible manner and not to engage in any activity that violates environmental laws or regulations.

We must at all times be aware of applicable export/ import laws and ensure compliance when moving goods or information.

Employees should treat all information which is not otherwise publicly available as Confidential Information including things such as client and customer lists, pricing lists or strategies, construction plans, supplier data, business leads, and all information relating to customer projects. All Employees are responsible for protecting the Confidential Information of CFT-Ukraine or of any customer, supplier or business partner of CFT-Ukraine and ensuring that such information is only used for the purpose for which it was provided.

All Employees are required to conduct themselves in a fair and even-handed manner in their day-to-day business dealings to ensure that all business partners, including customers, suppliers, shareholders, and fellow employees, are treated with high standards of honesty, fairness, and courtesy.