PRIME AEROSPACE basic policy is and has always been to conduct our business in a lawful and ethical manner. This Code of Business Conduct sets forth our commitment to integrity as the cornerstone for behavior of PRIME AEROPSACE employees and all others who act on our behalf. Our ethical standards are based on respect for the dignity of each individual, a commitment to honesty and fairness and our desire to be a good corporate citizen.

All PRIME AEROSPACE employees are responsible for ethical behavior. Questions regarding legal or ethical situations should be directed to the employee’s manager, Managing Director or any member of the Board of Directors. Employees will not suffer any adverse effects to their jobs or careers as a result of raising such issues.

PRIME AEROSPACE intends to conduct its business in a way that not only conforms to the letter of the law, but also promotes the spirit of fairness and honesty behind the laws.

PRIME AEROSPACE will deal fairly with our customers, suppliers, business partners and fellow employees.

PRIME AEROSPACE has a policy prohibiting sexual, racial, or other unlawful harassment of any kind. PRIME AEROSPACE is committed to equal employment opportunity.

PRIME AEROSPACE will comply with all laws which apply in the countries where we do business. In countries where common business practices are less restrictive than those outlined in our Code of Business Conduct, we will follow the more restrictive policies in the Code of Business Conduct.