TP Aerospace (“TPA”) is committed to the highest standards of integrity and social responsibility, and TPA expects all its suppliers engaged in providing products and services to TPA (“Suppliers”) to have, or to make, a similar commitment. The TPA Supplier Code of Conduct (“Code”) describes TPA’s expectations of how its Suppliers conduct business. TPA expects Suppliers to act in accordance with the Code, and at a minimum requires that all Suppliers comply with applicable laws and regulations within the geographies where they operate and be open and cooperative with the regulators enforcing such laws. In instances where expectations outlined in the Code differ from local laws, Suppliers must follow these expectations within the bounds of applicable local laws.:
The Code reflects TPA’s values and sets forth what is expected of its Suppliers with respect to the following topics:
• 1. Ethics and integrity
• 2. Data privacy and security
• 3. Inclusion and diversity
• 4. Labor and Human Rights
• 5. Wellbeing, health and safety
• 6. Climate and Environment
TPA is committed to the highest ethical standards and compliance with all applicable laws, rules, and regulations. TPA requires Suppliers to adhere to the following standards:
Bribery and anti-corruption
Suppliers must fully comply with requirements of all applicable bribery and anticorruption laws (e.g., U.S. Foreign Corrupt Practices Act and UK Bribery Act). TPA has a zero-tolerance policy towards corruption in any form and expects its Suppliers to adhere to the same standard.
Gifts and entertainment
Suppliers must not offer or accept any gift to obtain improper advantages or influence for the Supplier, TPA (such as TPA’s employees and their family members and associates), or any third party. Gifts include a benefit, fees, commissions, dividends, cash, gratuity, hospitality, services, or any inducements.
Conflict of interest
Suppliers must avoid situations where there is a conflict of interest between the Supplier and TPA, including interactions with TPA employees that could create a conflict of interest with the employee’s duty to act in the best interest of TPA.
Competition and antitrust
Suppliers must not enter into formal or informal anti-competitive arrangements that fix prices, collude, rig bids, limit supply or allocate/control markets. Suppliers are also not to exchange current, recent or future pricing information with their competitors. Suppliers must not participate in cartels or any activity that would unlawfully restrain or impact competition.
Export control
Suppliers must ensure that their business practices are in compliance with export control laws and regulations including the US, EU and any applicable national regulations, including compliance with sanctions and embargoes legislations. Suppliers shall provide truthful and accurate export control classification, information and obtain export control licenses or authorizations when required.
Non-retaliation for reports of concern
TPA expects Suppliers to have a policy and process for reporting of workplace concerns. The policy and process should be transparent and understandable and should protect reporting and participating individuals from retaliation.
TPA requires its Suppliers to protect the privacy of individuals and the security of confidential assets and information.
Confidential assets and information
Suppliers must protect TPA’s and its customers’ confidential assets and information. Suppliers must design and maintain processes to provide appropriate protections for this information.
Personal information and privacy
TPA requires Suppliers to protect personal information in compliance with all applicable local laws. Personal information provided by or on behalf of TPA should only be used, accessed, and disclosed as permitted by the Supplier agreement or if there is no Supplier agreement, only in agreement with TPA.
Cyber Security
Compliance with Cyber Security Standards: Suppliers must adhere to industry best practices and comply with all applicable local, regional, national, and global cyber security regulations. Suppliers are required to implement and maintain robust cyber security measures to protect the confidentiality, integrity, and availability of data.
Data Protection: Suppliers must ensure that all data, susceptible and personal information, is protected against unauthorized access, disclosure, alteration, and destruction. Suppliers should use encryption and other security technologies to safeguard data during storage and transmission.
Incident Response: Suppliers must have an incident response plan to promptly address potential cyber security breaches. Suppliers must notify TPA immediately in case of a data breach or any other cyber security incident that could impact TPA’s operations or data.
Regular Audits and Assessments: Suppliers should conduct regular security audits and assessments to identify and mitigate vulnerabilities. Suppliers must provide evidence of these audits and assessments upon request.
Training and Awareness: Suppliers must ensure that their employees and subcontractors receive regular cyber security training and know their responsibilities in protecting data.
TPA fosters an inclusive culture and believes diversity should be celebrated and discrimination of any form should not be tolerated.
Non-discrimination and workplace diversity
Suppliers must comply with all applicable laws relating to discrimination in hiring, employment practices, and harassment and retaliation. TPA expects Suppliers to operate workplaces free of discrimination, harassment, victimization, and any other abuse on any grounds including but not limited to age, disability, ethnic or social origin, gender, gender identity, nationality, race, sexual orientation, marital status, parental status, pregnancy, political convictions, religious beliefs, union affiliation, or veteran status.
Supplier diversity
As one component of TPA’s long-standing commitment to advancing diversity and inclusion, TPA actively promotes relationships with diverse and underrepresented businesses in TPA’s strategic sourcing and procurement process. TPA searches for Suppliers that similarly value diversity in Suppliers’ own supply chain and that support TPA’s goals with respect to supplier diversity. TPA expects Suppliers to: (i) utilize search and assessment processes that are both unbiased and transparent, (ii) ensure that Suppliers’ procurement teams proactively provide diverse businesses with fair access to bids, and (iii) where practicable, actively seek out and provide opportunities for diverse suppliers to participate in business opportunities.
As a participant in the United Nations Global Compact, TPA supports the Universal Declaration of Human Rights and the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work. TPA aligns its efforts and policies to the UN Guiding Principles on Business and Human Rights to ensure protection of the human rights of the people within its sphere of influence and expects its Suppliers to do the same.
Modern slavery / human trafficking
TPA does not tolerate slavery, forced labor, or human trafficking in any form. TPA requires Suppliers to fully comply with the applicable legal requirements of slavery, forced labor and human trafficking laws (e.g., UK Modern Slavery Act 2015 and Canada’s Modern Slavey Act,), and expects Suppliers to enact practices to ensure compliance with such laws.
Child labor
TPA does not tolerate child labor in any form. Suppliers must act in compliance with all laws regulating the minimum working age for each position, including any laws pertaining to the employment, apprenticeships, and internships of youths and students.
Respect and dignity
TPA expects Suppliers to enact practices to maintain a respectful and safe workplace. TPA expects Suppliers to not tolerate physical violence, threats, corporal punishment, mental coercion, verbal abuse, disrespectful behavior, bullying or harassment of any kind.
Employment laws
Suppliers must comply with all applicable local wage and labor laws. TPA expects Suppliers to provide employees with a timely and understandable wage statement that includes sufficient information to verify accurate compensation for work. All use of temporary, dispatch and outsourced labor shall be in accordance with local law.
TPA expects Suppliers to implement sound health and safety practices across business operations.
Health and safety
Suppliers must comply with all applicable health and safety laws and regulations. TPA expects Suppliers to adopt practices to minimize health and safety risks, support accident prevention, and ensure a safe workspace for all workers.
TPA is committed to reducing the impact of its operations on the natural environment and working with its Suppliers to do the same.
Environmental footprint
Suppliers must comply with all applicable environmental laws and regulations. TPA expects Suppliers to address Suppliers’ environmental risk and impact. TPA expects Suppliers to measure, manage, and address energy usage and greenhouse gas (GHG) emissions. And, where applicable, TPA expects its Suppliers to measure, manage and reduce water and waste in its operations.
Violations
Suppliers are required to promptly report any legal violations or violations of the Code or other TPA applicable policies to TPA. Suppliers must promptly forward to TPA, if permitted by law, any subpoenas, regulatory requests, media inquiries, or other third-party requests concerning TPA. To report a violation or other information, please email SCM@tpaerospace.com (monitored in office hours, Monday – Friday). TPA will keep the reported information confidential, subject to any investigations from relevant authorities and provided TPA is permitted by law to disclose the information.
TPA also enables anonymous reporting of misconduct or violations through TPA’s whistleblower portal which can be accessed via TPA’s website.
In the event of non-compliance with, or violation of, the Code, TPA may give the Supplier a reasonable opportunity to respond with proposed corrective actions, unless the violation is severe or incurable, or there is a violation of law. TPA may suspend or terminate its relationship with the Supplier and/or disclose the matter to the appropriate authorities if there is a violation of law.
The Supplier shall ensure that its subcontractors, if any, comply with the Code, and acknowledge that it is responsible for its subcontractors’ violations.
TPA’s Rights
TPA reserves the following rights to ensure and enforce Suppliers’ compliance with the Code.
Supplier selection
TP Aerospace
Kirsten Walthers Vej 12 • 2500 Valby • Denmark • Phone +45 8993 9929 • www.tpaerospace.com
TPA will evaluate Suppliers’ compliance with the Code during the Suppliers’ evaluation and selection process, or upon TPA’s discretion.
Supplier assessment
During the Supplier certification process, Suppliers may be required to complete a self-assessment questionnaire on compliance with the Code. Suppliers may be asked to re-affirm compliance with the Code periodically or to keep themselves informed about the current code in force by visiting www.tpaerospace.com. Upon request, Supplier will provide written information on its policies and practices related to compliance with the Code. TPA is committed to working with Suppliers to improve performance on topics addressed by this Code and expects Suppliers to agree to work together with TPA to jointly address applicable and relevant topics.
Order of Precedence; Changes to the Code
The Code is not meant to, and does not, supersede any applicable law, or any term in an agreement between TPA and a Supplier. To the extent there is any conflict between this Code and any applicable law or provision of any agreement, the applicable law or agreement controls. TPA reserves the right to update or change the Code requirements, so the Supplier is obliged to abide by the Code which is in effect from time to time as published on www.tpaerospace.com.
Date of last review/update: December 2024
Kirsten Walthers Vej 12
DK-2500 Valby
Denmark
Phone: +45 8877 9494
AOG Hotline: +45 8993 9929
Email: sales@tpaerospace.com
CVR: 31604206
Cage Code: #R6114
Copyright 2025, TP Aerospace. All Rights Reserved.
