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The Supply Chain Management Code of Ethics is intended as a central reference guide for Triumph Aerospace Systems Group (Triumph) Supply Chain Management personnel and Triumph suppliers. This code is reflective of the larger Code of Business Conduct of the Triumph Group, which can be located on the Triumph Group corporate website at www.triumphgroup.com. Herein, guidelines will be provided for: 1) Triumph employees who are in contact with suppliers, and 2) suppliers that engage or attempt to engage in a business relationship with Triumph and/or interact with Triumph employees. This code addresses many situations that Triumph personnel and suppliers might encounter on a daily or occasional basis and will guide all parties involved in making decisions that align with the highest standards of business conduct.

This code will address the following principles and situations:

• General Conduct
• Compliance with Laws, Rules, and Regulations
• Conflicts of Interest
• Fair Dealing
• Confidentiality
• Gifts and Gratuities

General Conduct
Triumph is committed to the highest standards of ethical conduct in every business relationship. In all circumstances and in all situations, Triumph expects its employees and business partners to do what is right, respect others, and strive to achieve a standard of excellence in all aspects of the relationship.

Compliance with Laws, Rules, and Regulations
Triumph intends to operate its business lawfully in every respect. This includes engaging in business relationships only with suppliers that conduct business in a manner that is lawful and compliant to applicable regulations. All Triumph employees and suppliers must observe the laws of the cities, states and countries in which they conduct business including, but is not limited to, laws and regulations governing export control, the use of insider information, intellectual property rights, labor rights, and environmental protection.

Conflicts of Interest
A conflict of interest occurs when a Triumph employee's private interest interferes (or appears to interfere) in any way with the interest of the Company as a whole. Conflicts of interest are prohibited and Triumph suppliers must not engage in activity that might propagate such a conflict of interest. Such conflicts include, but are not limited to:

• Improper personal benefits such as gifts, services, gratuities, or guarantees of personal obligations.
• Ownership or financial interest in other businesses. A Triumph employee or supplier that has a financial interest in the performance of the other might be an example of a conflict of interest.
• Corporate opportunities that arise in the course of doing business or that are discovered through the use of corporate property should not be used for personal gain.
• Outside employment by a Triumph employee that adversely affects the employee's ability to make sound decisions or motivates the employee contrary to their job performance is prohibited. For example, outside employment with a supplier, competitor, or customer may result in a conflict of interest. Employees and suppliers must refrain from encouraging or engaging in activity that creates such an environment.
• Acting as a consultant to a supplier or customer.

Fair Dealing
Triumph employees are expected to respect the rights of and deal fairly with customers, suppliers, competitors and colleagues. Taking unfair advantage through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any other unfair practice is prohibited. In addition, Triumph does not tolerate violence or threatening behavior when dealing with one another or any of Triumph's business partners.

Confidentiality
Confidential information includes all non-public information that might be of use to competitors or might be harmful to Triumph or its suppliers if improperly disclosed. Triumph employees and suppliers are expected to maintain the confidentiality of information entrusted to them except when disclosure is authorized or legally mandated.

It is the responsibility of every Triumph employee and supplier to maintain the confidentiality of information about the other, not only during the course of the employment or business relationship, but also after any such relationship ceases for any reason.

Gifts and Gratuities
The company will procure goods and services based solely on service and quality. Decisions relating to the procurement and provision of goods and services should always be free from even a perception that favorable treatment was sought, received, or given as the result of furnishing or receiving gifts, favors, hospitality, entertainment, or other similar gratuity. The giving or receiving of anything of value to induce such decisions is prohibited. Gifts, services, travel or entertainment that may be reasonably deemed to affect judgment or actions in the performance of one's duties should not be accepted. Suppliers should also refrain from offering any such gift or service that would reasonably be construed as excessive as stated herein.

Although Triumph employees should not utilize their positions to obtain gifts or services, it is permissible to accept unsolicited meals, refreshments, entertainment, and other business courtesies on an occasional basis provided:

• They are consistent with accepted business practices,
• They are of token or nominal value and in a form that will not be construed as a bribe or pay off,
• They are not prohibited by law or contradictory to generally accepted ethical standards, and
• The employee accepting the gift or service would feel comfortable discussing it with his or her manager or co-worker.

It is the responsibility of Triumph employees and suppliers to ensure that gifts and gratuities could not reasonably be construed in any way as an attempt by the offering party to secure favourable treatment.

Summary
The integrity of every Triumph employee and each Triumph supplier and the commitment to the highest standards of professional conduct underpin the ethical principles of the Triumph Aerospace Systems Group companies. Triumph is determined to succeed and is proud of the reputation it has built amongst its customers, suppliers, and peers and encourages all employees and business partners to do their part to uphold a standard of excellence unparalleled in our industry.