Metric Machining: Ethics Policy

Employees

Our Ethics Policy applies equally to all:

The Ethics Policy applies to everyone at Metric Machining
including the Board of Directors, company officers, employees, agents and contract workers

• Any violation of the Ethics Policy must be reported to Metric Machining.
• Metric Machining will not tolerate threats or retaliation against anyone who makes a good-faith report of a possible Ethics Policy violation.
• Employees are expected to follow the Ethics Policy and assist their fellow employees and Metric Machining partners in understanding and complying with the Ethics Policy.
• Supervisors will help make their employees aware of the Ethics Policy’s importance and requirements, and help implement programs and procedures to promote “integrity every day.”
• Supervisors are responsible for helping their team members comply with the Ethics Policy’s requirements and its spirit.

We safeguard the health and safety of our global team members.

It is essential that our employees work in healthy and safe environments.

• Always follow safety procedures and guidelines.
• 1. Understand and follow the safety policies and procedures related to your work.
  2. Regularly look for ways to improve workplace safety.
  3. Do your best to avoid accidents and to help others avoid them.
  4. Report all accidents, near misses and safety issues.
• Help create a physically and emotionally safe work place.
• Do not commit or permit violence.
• 1. We do not tolerate violent behavior, threats to people or property, or physical intimidation or coercion.
• Never be under the influence of drugs or alcohol at work.
• 1. At work, you must remain free from the influence of illegal drugs, alcohol or any substances that may impair your ability to work safely and effectively.
  2. You must cooperate with any legal company searches of you or your workplace for alcohol or illicit drugs.
  3. Report team members who work under the influence of alcohol or other substances that may impair their ability to work safely and effectively.

We are inclusive, value diversity and support team members in realizing their potential:

Metric Machining provides equal opportunity in hiring, salary, benefits, advancement, discipline, termination and retirement.

• Respect equal opportunity.
• Focus on the value that people add. We do not discriminate on the basis of race, gender, sexual orientation, age, pregnancy, caste, disability, union membership, ethnicity, religious beliefs or any other factors protected by law.
• Oppose harassment.
• Do not tolerate physical or mental harassment or any other harmful behavior.
• Harassment includes language or conduct that others may find derogatory, intimidating or offensive.
• Immediately report all incidents of harassment to your supervisor or Human Resources.

We protect the privacy of our team members.

We use employee data only to support Metric Machining operations and to provide employee benefits. We have safeguards to protect personal data; we limit data access to employees who need it for business purposes; and we follow local data protection and privacy laws.

• Follow data protection policies.
• 1. You’re required to follow Metric Machining policies to protect data and privacy. If you don’t understand a policy or procedure, you’re responsible for getting an explanation.
• Be careful not to breach privacy.
• 1. Make sure you don’t disclose personal data by accessing or sending it.
  2. Gather only the information you need for your work.
  3. Unless you have authorization, you may not access any system or database containing private information, such as employee or personnel records, customer forms, e-mail, or your co-workers’ personal messages.

We respect freedom of association and obey all laws on working hours and compensation.

Every employee has the right of association, working hours consistent with local laws, and fair compensation at the workplace.

• We respect the right to organize and bargain collectively.
• 1. We give workers' representatives the access necessary to carry out their required functions.
  2. We do not discriminate against workers’ representatives.
• Our team members work within the limits established by law.
• 1. When circumstances require you to work beyond normal hours, we provide benefits or overtime compensation as required by law.
  2. You will receive at least the legally required minimum wage or the prevailing industry wage, whichever is higher.
• Metric Machining will give you full details on payroll deductions for taxes and benefits.
• Metric Machining compensation and benefits are designed to enable our employees to meet their basic needs, and provide them the opportunity to improve their skills and capabilities.

Company and Shareholders

We obey the laws, rules and regulations of all countries where we conduct business.

As a global company, Metric Machining must follow the laws and regulations of each country in which it operates.

• Our policies reflect the laws of the countries where we do business, and they’re often more demanding than some laws require.
• Follow the laws that apply to your work.
  - If you’re not sure which laws apply, or you think the laws of two or more countries conflict, ask members of the Legal Department for help right away.
• Report any known or possible violations of the law by Metric Machining employees or its business partners to your supervisor, another supervisor, Human Resources or the Legal Department.

We protect Metric Machining confidential information and respect that of our competitors.

Sharing the company’s confidential information is not allowed.

• 1. Disclose confidential information only on a “need-to-know” basis, even with other Metric Machining employees.
  2. Never disclose confidential information outside of Metric Machining unless you already have a non-disclosure agreement or a confidentiality agreement approved by the Metric Machining Legal Department.
  3. Secure confidential information where others cannot see when you are not reviewing it.
  4. Report all suspected breaches of confidentiality.
• Protect third-party, non-public information.
• 1. Do not seek or receive competitors’ trade secrets or confidential information unless the disclosure is covered by a non-disclosure or confidentiality agreement approved by the Legal Department.
  2. We compete fairly and honestly. Do not use illegal or unethical means to learn a competitor’s confidential information.
  3. If you have non-public, confidential information from previous employment with a competitor, then you must continue to keep that information confidential, even from Metric Machining.
• Protect Metric Machining confidential information.
• 1. Safeguard all intellectual property, including copyrights, patents, licenses, trademarks and other trade secrets.
  2. Protect all Metric Machining confidential information even after you stop working with Metric Machining.

We act in Metric Machining best interests and spend its money solely for Metric Machining business purposes.

You may not give or receive anything of monetary value to influence business judgment unduly, or use Metric Machining information, property or authority for personal gain.

• Think only of Metric Machining best long-term interests in making business decisions.
• Do not seek or receive personal economic gain, beyond your normal company pay, for being a Metric Machining director, officer, employee, agent or contract worker.
• Disclose to your supervisor any situation in which your family, friends or business associates might profit based on their relationship with you.
• Report financial interests you and your family have in entities that do business with Metric Machining.
• Seek Legal Department guidance before beginning any discussions on hiring government officials or their family members.
• Do not pursue any business opportunity you discover through your association with Metric Machining for personal gain or the gain of any entity other than Metric Machining.
• Do not work for a customer, supplier or competitor of Metric Machining while Metric Machining employs you.
• Do not engage in insider trading. If you have valuable information about a company that has not been made public, you may not buy or sell that company’s stock.
• Think about how it will appear if you accept gifts or entertainment from suppliers, customers, agents or others wanting to do business with Metric Machining. Whenever possible, seek guidance before giving or receiving things of value. If you personally accept something of more than minimal value, you must keep a record of it and report it promptly to your supervisor.
• Use company funds prudently.
• 1. You are personally accountable for your use of company funds in any form.
  2. Make sure Metric Machining receives full value for spending you authorize.
  3. Executive officers must immediately disclose to the Audit Committee any material transaction or relationship that may reasonably result in a conflict of interest.

We are committed to providing safe, quality products and services.
We address and do not hide risks and mistakes.

The Ethics Policy includes our commitment to providing safe and quality products, services and solutions.

• You should immediately contact quality management personnel or your supervisor if you believe there is:
• 1. Any deficiency in product design, safety, installation, or maintenance that threatens anyone’s health or safety.
  2. Anything that may harm the quality of our products or services.
  3. Anything that may harm Metric Machining reputation.
  4. Anything that may harm Metric Machining financial interests.

We use Metric Machining assets such as e-mail, Internet access, telephones and computers responsibly and honorably.

Metric Machining computing resources should be used for company purposes.

• Use electronic media properly.
• 1. Information on company computer systems, including e-mail and other Internet-related systems, is the property of Metric Machining, to be used for company business.
  2. Do not use company resources to offend, harass or threaten others or to access or store illegal or generally offensive material.
  3. While you’re at work or using a company computer or mobile device, do not visit Internet sites with offensive content related to sex, race, religion or other protected categories.
  4. Do not use company resources to reproduce, display, distribute, or store materials that violate any party’s trademark, copyright, licensing or other intellectual property rights.
  5. Use assets such as company vehicles properly and legally, for company purposes.

We win business with the integrity of our products, services and personal character. We do not seek business by trying to corrupt the judgment of our customers. We do not tolerate any bribery of private or of public persons. We neither provide nor receive lavish or extravagant gifts.

• Do not offer, pay, give or promise any favor, service, entertainment, meal, gift or other thing of value to any private or governmental customer to get business, or to any government or political official or their family members to get preferential treatment for Metric Machining.
• 1. Before you make a gift or offer, ensure that the value of the gift would not reasonably be seen as an attempt to influence an official decision. Talk with the Legal Department to see if the recipient is considered a “government official.” Get the Legal Department’s approval before you act.
  2. Do not offer employment, benefits or other profitable opportunities to government officials or to private citizens who have authority over Metric Machining without first consulting with the Legal Department.
• Obey all local anti-corruption and bribery laws.
• Accurately record in Metric Machining books all of your transactions including your expenses and any gifts or entertainment you provide.
• Do not associate with business partners who engage in corrupt practices. Regularly screen business partners and stop working with them if you reasonably suspect corruption.
• Do not provide gifts, entertainment or other favors to a union representative without consulting the Legal Department.

We ensure our books and records are accurate, complete and maintained according to the law and industry best practices.

Keep trustworthy books, accounts and records.

• Company books and records must be complete, accurate and reliable, following Generally Accepted Accounting Principles.
• 1. Be precise and complete when you record transactions.
  2. Don’t make false or misleading entries, or omit or conceal required information such as the payment amount or its actual purpose.
  3. Follow laws, regulations, industry standards and company policies when you produce, store or destroy records and documents.
  4. Don’t keep hidden or unrecorded funds, accounts or assets.
• Anyone who falsifies, hides or manipulates records, faces disciplinary action, termination and personal liability.
• If you find errors, or can’t reconcile an account, notify management so the account can be corrected.
• Follow the law and Metric Machining policies on document and record retention.
• 1. When destroying records or documents, follow procedures required by local law and Metric Machining document retention policies.

Customers, Competitors and Suppliers

We believe in vigorous competition and do not use illegal or unethical means to gain an advantage over a competitor.

• Using illegal or unethical means to obtain competitive advantage is prohibited.
• Follow all antitrust and competition laws in countries where Metric Machining operates.
• Do not join Metric Machining competitors or business partners in agreements or understandings that limit competition.
• 1. For example, do not agree to fix prices; rig bids; divide up products, territories, customers or markets; or limit production or sale of products.
• Do not make false, baseless, or misleading remarks about Metric Machining, its competitors or their products.

We comply with international trade laws.

We follow the trade laws of all countries where Metric Machining conducts business, including laws concerning:

• Importing or exporting specific goods, services or technology.
• Prohibiting transactions with specific countries, entities or people.
• Participating in international boycotts.
• Government approval, licenses or other requirements necessary to complete a transaction or sale.
• Product labeling.
• Keep accurate records of all international transactions.
• Follow all Metric Machining policies and processes when selling and shipping products to other countries or when importing anything.
• Make efforts to ensure customers, business partners, vendors, service providers, agents, consultants and distributors follow Metric Machining policies and procedures.
• Engage companies and business partners who agree to obey international trade laws.

We believe that what’s good for the environment is good for Metric Machining.

Metric Machining products, services and manufacturing methods reflect our long tradition of caring for the environment.

• Follow environmental law and regulations, as well as Metric Machining policies for protecting the environment.
• Follow environmentally responsible practices such as waste management, source reduction, recycling and energy conservation.
• Work to minimize toxic and greenhouse gas emissions.
• Use and produce environmentally friendly products, and address community concerns about the environment.

The Public and Our Communities

We strictly limit the use of company resources to support political campaigns or causes.

Generally, Metric Machining does not get involved in political campaigns or political issues. Decisions on whether the company will support a political candidate or issue must be made at a high level within Metric Machining.

• Never offer contributions, payments or anything of value from Metric Machining to government officials or political candidates with the intent to influence them orgain an improper advantage for the company.
• Always get Legal Department approval before offering or using any Metric Machining funds, services or other resources to support any official, political organization or candidate.
• Document accurately in Metric Machining records any donation or contribution to any campaign, political organization or candidate.

We communicate accurately with the public.

We ensure our communications are truthful and accurate. We do not release misleading information.

• Take care when discussing Metric Machining outside the company, in public places, with friends and family, with the media and on the Internet, in public forums, blogs and social networking sites.
• Never disclose private company information without prior and proper authorization.
• Neither say nor imply that you represent the company unless you’re authorized to do so.
• Only those expressly authorized by the Communications Department may speak on behalf of Metric Machining.
• Those who are authorized to speak for Metric Machining must provide accurate information to the public and should avoid speculating.