Conflict Materials Policy

Middlesex Aerospace

Purpose

Middlesex Aerospace is committed to conducting its business in an ethical and socially responsible manner. This Conflict Materials Policy outlines our dedication to avoiding the use of conflict minerals that may contribute to human rights abuses, environmental degradation, or unethical practices in conflict-affected or high-risk areas.

Scope

This policy applies to all employees, suppliers, contractors, and stakeholders involved in the sourcing, manufacturing, and distribution processes of Middlesex Aerospace. Conflict minerals, as defined by international standards, include tin, tantalum, tungsten, and gold (3TG).

Definition of Conflict Minerals

Conflict minerals refer to minerals sourced from regions where the extraction and trade of these minerals may contribute to conflict, human rights abuses, and environmental degradation. The 3TG minerals (tin, tantalum, tungsten, and gold) are often linked to such issues, particularly in areas known for armed conflict.

Responsible Sourcing

Middlesex Aerospace is committed to sourcing minerals responsibly. We will strive to identify and source materials from suppliers that share our commitment to ethical and conflict-free practices. Suppliers are expected to comply with this policy and provide assurance that the materials supplied do not originate from conflict-affected or high-risk areas.

Supplier Expectations

Suppliers are expected to:

a. Undertake due diligence to ensure that the materials supplied do not contribute to conflict, human rights abuses, or environmental harm.

b. Provide information about the origin of materials, including the source of 3TG minerals.

 Training and Awareness

Middlesex Aerospace will provide training to relevant employees and suppliers to raise awareness of the issues related to conflict minerals and to ensure compliance with this policy.

Continuous Improvement

We will continuously review and improve our processes and policies to address emerging challenges and opportunities related to conflict minerals. Feedback from stakeholders will be considered in the ongoing development of our responsible sourcing initiatives.

Non-Compliance

Non-compliance with this policy may result in termination of contracts and relationships with suppliers. Middlesex Aerospace is committed to taking appropriate actions to address instances of non-compliance, and we encourage reporting of concerns through established channels.

Middlesex Aerospace is dedicated to upholding the highest ethical standards in its business practices and supply chain operations. By adhering to this Conflict Materials Policy, we aim to contribute to global efforts to eliminate the use of conflict minerals that fund human rights abuses and environmental harm.