Supplier Code of Conduct

Impulse’s mission is to empower every person and every organization to achieve more – this is done through our commitment to upholding the highest standards of business ethics in all our dealings. It is critical to our Company’s stature to maintain strong ethical, legal and social standards by adhering to all applicable laws and avoiding the perception of impropriety or conflict of interest. Similarly, Impulse expects its business partners to conduct their business using the highest degree of ethical, legal, and socially responsible practices.

Compliance with the Code

We expect you as Supplier to adhere to these principles, either by complying with this Impulse Supplier Code of Conduct (“Code”) or your own code of conduct or policies that embrace these standards. Suppliers are responsible for ensuring that their employees, affiliates, directors, distributors, subcontractors, agents, or other representatives who provide products/services to Impulse – or to Impulse’s customers on our behalf – read and comply with this Code.

Supplier Evaluation, Qualification and Selection

Impulse Suppliers have the responsibility to ask questions, seek guidance, and report suspected violations of this Code. When selecting Suppliers, Impulse applies a system of checks and balances to minimize risk and maximize performance in our supply chain. Current and prospective Suppliers should expect to undergo the following selection, qualification and evaluation steps outlined below:

Our relationship with you as a Supplier is based on mutual transparency, trust, respect and responsibility. Additionally, Impulse may ask you to verify your compliance by any of the following methods and to take corrective action in case of any concerns:

1. Self-Assessments: At the request of Impulse, Suppliers will be asked to complete a compliance questionnaire
2. Third-Party Assessments: Impulse may solicit a third party, such as a data provider, to evaluate your compliance and performance.
3. Certifications/Statements: Impulse may ask a Supplier for a certification or statement confirming compliance, including AS9100 / ISO 9001- Aerospace Standard – Quality Management Systems - Requirements for Aviation, Space and Defense Organizations & AS5553 - Counterfeit Electronic Parts; Avoidance, Detection, Mitigation, and Disposition.
4. On-Site Audits: Occasionally, Impulse or an authorized third party acting on Impulse’s behalf may contact a Supplier and ask for permission to verify compliance.

Human Rights and Fair Labor Practices

• PROHIBIT USE OF CHILD LABOR: Suppliers will not directly or indirectly employ workers that are under the age of 15 or younger than the applicable required minimum age, whichever requirement is greatest.
• HUMAN TRAFFICKING AND INVOLUNTARY LABOR: Suppliers will not knowingly source materials from supply chains associated with forced, bonded, indentured labor, or trafficking of persons, and will take reasonable efforts to ensure that their own suppliers comply with this requirement. Suppliers or labor dispatch agencies shall not receive deposits or fees (e.g. recruitment or hiring fees) from workers. Suppliers’ workers’ contracts shall clearly convey the conditions of employment in a language understood by the workers. Third-party recruitment agencies used by Suppliers shall be prepared to be compliant with the provisions of this Code and applicable laws and regulations.
• NON-DISCRIMINATION: Impulse expects its suppliers to treat their employees with respect and dignity and to refrain from any unlawful discrimination. To the extent prohibited by applicable law, Suppliers will not discriminate against any person because of their race, color, sex, religion, national origin, age, disability, sexual orientation, gender identity, genetic information, pregnancy, veteran status, political affiliation, or any other prohibited basis.
• NO HARASSMENT: We expect our Suppliers to ensure their employees can perform work in an environment free from physical, psychological and verbal harassment, or other abusive conduct.
• WAGES AND WORKING HOURS: Suppliers must comply with all applicable wage and hour laws, including those relating to minimum wage, overtime hours, and other elements of compensation, and must provide all legally mandated benefits. Suppliers will not require employees to work more than the maximum number of hours permitted under applicable laws.
• HEALTH AND SAFETY TRAINING AND COMMUNICATION: Suppliers shall provide workers with appropriate workplace health and safety requirements and training in their primary language. Suppliers shall clearly post in their facilities health and safety related information.

Environment

• ENVIRONMENTAL, HEALTH AND SAFETY (EHS) LAWS: Suppliers must comply with all applicable environmental, health and safety laws and regulations and must provide workers with a safe and healthy work environment. Suppliers must strive to reduce their negative impact on the environment through the conservation of natural resources, reduced energy consumption and other means. While a Supplier, its affiliates, agents or representatives are on-site at any Impulse location or at a Impulse customer location on behalf of Impulse, Supplier shall comply with Impulse policies and applicable site requirements.
  
  To meet these objectives, at a minimum, it is important that all Suppliers:
  • are aware of their environment, health and safety responsibilities and obligations and are compliant with relevant national and local safety and environment legislation, and other legal requirements (as applicable)
  • have a written environment and health and safety policies
  • have a system to record, monitor and manage environment, health and safety risks and incidents
  • comply with all BDA site specific environment, health and safety requirements
  • comply with BDA’s Drug and Alcohol Management Plan (DAMP) where applicable.
• ENVIRONMENTAL PERMITS AND REPORTING: Suppliers shall obtain, maintain, and keep current all required environmental permits, approvals and registrations and follow applicable operational and reporting requirements.
• TRADE COMPLIANCE: Suppliers must comply with all export-import laws, customs duties, sanctions regulations and all other laws pertaining to their international business activities.
• HAZARDOUS SUBSTANCE MANAGEMENT AND RESTRICTION: Suppliers shall implement a systematic approach to identify, manage, reduce, and responsibly dispose of or recycle hazardous substances, in accordance with applicable laws and regulations

Ethical Business Practices

• CONFLICT OF INTEREST: Suppliers are expected to avoid all conflicts of interest or situations giving the appearance of a potential conflict of interest. A Supplier should never use a third-party’s property or information for personal gain, or personally take for themselves any opportunity that is discovered through their position in a competitive market. Suppliers are expected to provide notification to all affected parties if an actual or potential conflict of interest arises. This includes a conflict between the interests of Impulse and personal interests or those of close relatives, friends, or associates.
• DISCLOSURE OF INFORMATION: Suppliers shall accurately record information regarding their business activities, labor, health and safety and environmental practices and shall disclose such information, without falsification or misrepresentation, to all appropriate parties.
• ANTI-CORRUPTION, GIFTS AND IMPROPER PAYMENTS: Suppliers are prohibited from engaging in corruption, extortion or embezzlement in any form. Suppliers must comply with all applicable anticorruption laws and regulations of the countries in which they operate such as the U.S. Foreign Corrupt Practices Act, and as applicable any other international anti-corruption conventions. Suppliers will not offer or accept bribes or employ other means to obtain an undue or improper advantage. Bribes, kickbacks, facilitating payments and similar payments to government officials or to Impulse employees or agents acting on Impulse’s behalf are prohibited. Impulse employees are discouraged from accepting gifts of more than minimal value or lavish entertainment from suppliers. When business meals and entertainment are appropriate to further business relationships, those expenses may not be extravagant in nature.
• FAIR DEALINGS AND COMPETITION LAWS: Suppliers should not take unfair advantage of anyone else through manipulation, concealment, abuse, misrepresentation of material facts or any other unfair dealing. Supplier will not engage in collusive bidding, price fixing, price discrimination or other unfair trade practices in violation of applicable antitrust and competition laws. Supplier will uphold fair business standards in advertising, sales and competition.
• RESPONSIBLE SOURCING OF MINERALS: Suppliers must comply with applicable laws and regulations regarding conflict minerals which include tin, tungsten, tantalum and gold. Suppliers should establish a policy to reasonably assure that such minerals which may be contained in the Effective Date: 03/15/2024 Page 4 of 4 products they manufacture do not directly or indirectly finance or benefit armed groups that are perpetrators of serious human rights abuses. Suppliers should exercise, as may be directed by law, due diligence on the source and chain of custody of these minerals and therefore at a minimum require the same from their next tier suppliers.
• PRIVACY: Suppliers shall protect the personal information of everyone they do business with, including sub-suppliers, customers, consumers, and employees. Suppliers shall comply with applicable privacy and information security laws and regulatory requirements, such as the GDPR, when personal information is collected, stored, processed, transmitted, and shared.
• CONFIDENTIALITY: Suppliers must protect the Confidential Information entrusted to them by Impulse, its affiliates, customers or suppliers. Confidential Information may only be used and disclosed in a manner authorized by Impulse. Confidential Information includes any business information of Impulse, its customers or suppliers that is not generally known to the public.
• INTELLECTUAL PROPERTY: Suppliers must respect the property rights and transfer of technology rights of others. Impulse expects that Supplier will not acquire or seek to acquire improper means of a competitor’s trade secrets or other proprietary or confidential information. Suppliers must respect and refrain from knowingly or negligently infringing upon the intellectual property rights of others, including patents, trademarks, copyrights and other proprietary rights.

Risk Management System

• RISK ASSESSMENT AND RISK MANGEMENT: Suppliers shall establish and maintain a process for identifying the risks associated with its business operations. This process should include the identification, monitoring, and mitigation of legal, compliance, ethical, environmental, health, safety, and labor practice risks. Suppliers are expected to implement appropriate mitigation plans based on their exposure to each risk.
• TRAINING: Suppliers shall establish and continue to operate programs for training managers and workers to implement Supplier’s policies, procedures, and improvement objectives and to meet applicable legal and regulatory requirements. Suppliers shall have an ongoing process to evaluate practices and conditions covered by this Code and to foster continuous improvement.
• COMMUNICATION: Suppliers shall establish and operate using a process for communicating clear and accurate information to Impulse about Supplier’s policies, practices, expectations and performance to workers, subs and customers. We would encourage the sharing of Suppliers’ social responsibility commitment, standards and related reports with key internal and external stakeholders.

Disclaimer: This Supplier Code of Conduct does not confer rights on any Supplier, nor does it impose obligations on Impulse. The expectations set forth in this Code are not intended to conflict with or modify the terms and conditions of your Goods or Services contracts with Impulse. If a contract term or condition requirement is more restrictive than this Code, you must comply with the more restrictive contract requirement. The Supplier Code is subject to modification from time to time, and the most current version is kept on Impulse’s public website.