Supplier Code of Conduct

LinQuest Corporation is an ISO 9001:2015 certified company and we are committed to providing excellence, from concept to capability. LinQuest expects our suppliers to maintain the highest standards of business conduct and procurement integrity during the procurement process. As such, LinQuest, and its suppliers, will fully comply with all applicable laws (federal, state and local, including the laws of any country in which we operate), regulations (including FAR 52.203-13 thru FAR 52.203-16) and contract requirements as well as LinQuest’s own high standards of integrity and quality.

LinQuest’s senior management fosters a positive culture around supply chain management which enables the participants in the procurement process at all levels of the enterprise, including suppliers, to understand their roles in supply chain management. The following explains how we must conduct ourselves when representing or acting on behalf of our company:

Laws, Regulations, and Contracts

Our suppliers must, at a minimum, perform all duties and expectations in compliance with all laws and regulations applicable to their business. Suppliers must comply with all flow down terms, conditions, and other provisions specified in the LinQuest purchase order.

Anti-Corruption

We have a zero-tolerance policy for corruption, and prohibit anyone conducting business on our behalf, including suppliers, from offering or making any improper payments of money or anything of value to government officials, political parties, candidates for public office, or other persons. This includes the offer and/or receipt of any bribe or kickback to and/or from any customer, supplier or others. We expect our suppliers not to make any illegal, improper or corrupt payments.

Gifts/Business Courtesies

We compete on the merits of our excellence in service to our customers and do not use the exchange of business courtesies to gain an unfair competitive advantage. We expect the same of our suppliers in the offering or receipt of any gift or business courtesy, including cash and cash equivalents. In particular, our team members who are in any way involved in procurement decisions are subject to even more strict limitations, and may not accept any business courtesies, with the exception of very low value promotional items. In any business relationship, our suppliers must ensure that the offering or receipt of any gift or business courtesy is permitted by law and regulation; does not violate the rules and standards of the recipient’s organization; is consistent with reasonable marketplace customs; and will not adversely impact the reputation of LinQuest.

Fair Competition/Antitrust

Our suppliers must conduct business in accordance with all applicable antitrust or competition laws and regulations. This includes avoiding business practices such as entry into arrangements that unlawfully restrain competition; improper exchange of competitive information; price fixing, bid rigging, or improper market allocation.

Commercial Item Procurement

LinQuest procures commercial items and services whenever practicable to fulfill Government requirements. This applies to all procurements under U.S. Government contracts and high-tier subcontracts. LinQuest also requires its suppliers to procure commercial items and services whenever practicable.

Conflicts of Interest

Our suppliers must avoid all conflicts of interest or situations giving the appearance of a potential conflict of interest in their dealings with LinQuest. We expect our suppliers to report to LinQuest, any situations of potential or apparent conflicts between their personal interests and the interests of LinQuest.

Export/Import Control

Our suppliers must ensure that their business practices are in accordance with all applicable laws and regulations governing the export and import of domestic and foreign origin parts and components and related technical data. Suppliers shall provide complete and accurate information and obtain export licenses and/or authorizations when necessary.

Protecting Information

Our suppliers must take proper care to protect information, including confidential, proprietary, and personal information, in accordance with applicable laws and their contractual obligations with LinQuest. Information maintained on electronic systems should be protected against cyber intrusions and other unauthorized use or access, through appropriate physical and electronic security procedures. LinQuest information should not be used for any purposes beyond the scope of the business arrangement with our company, without prior authorization. In addition, we expect our suppliers to comply with insider trading laws and take steps to prevent their employees from trading in the securities of any company while in possession of material nonpublic information about such company.

Financial Responsibility/Accurate Records

Our suppliers must accurately record, maintain, and report business documentation, including but not limited to, financial accounts, quality reports, time records, expense reports, resumes and submissions to LinQuest, the customer or regulatory authorities.

Human Rights

Our suppliers must treat people with respect and dignity, encourage diversity and diverse opinions, promote equal opportunity for all, and help create an inclusive and ethical culture.

Human Trafficking

Our suppliers may not engage in the use of forced, bonded (including debt bondage) or indentured labor, involuntary prison labor, slavery, or trafficking of persons. This includes transporting, harboring, recruiting, transferring, or receiving vulnerable persons by means of threat, force, coercion, abduction, or fraud for the purpose of exploitation.

Child Labor

Our suppliers must ensure that child labor is not used in the performance of work. The term “child” refers to any person under the minimum legal age for employment where the work is performed.

Non-Discrimination

In accordance with LinQuest policy, our suppliers must provide equal employment opportunity to employees and applicants for employment without regard to race, ethnicity, religion, color, sex, pregnancy, national origin, age, military veteran status, ancestry, sexual orientation, gender identity or expression, marital status, family structure, genetic information, any characteristic protected by state or local law, or mental or physical disability, when the essential functions of the job can be performed with or without reasonable accommodation.

Harassment

Our suppliers must ensure that employees perform their work in an environment free from physical, psychological and verbal harassment, or other abusive conduct.

Drug-Free Workplace

Our suppliers must maintain a workplace free from illegal drugs. Such a workplace includes the illegal use, possession, sale or distribution of controlled substances or illegal substances.

Reporting

Our suppliers must implement proper non-retaliation policies to provide their employees with avenues for raising legal or ethical issues or concerns without fear of retaliation.

Supplier Diversity

Our suppliers shall be mindful that we often have customer-directed supplier inclusion goals. These may be defined as small/medium-sized business, small disadvantaged business, woman owned small business, HUBZone certified business, or veteran-owned small business.

Codes of Conduct and Sub-tier Suppliers

Commensurate with the size and nature of their business, our suppliers must have management systems in place to support compliance with laws, regulations, and expectations related to or addressed expressly within this Supplier Code of Conduct. We encourage our suppliers to implement their own written code of conduct, and to flow down the principles of a code of conduct to the entities that furnish goods and services to the supplier.