Effective Date: June 2023

Fly Raven Jet LLC and its affiliates (collectively, “Fly Raven Jet”) are committed to the highest standards of safety, ethical conduct, customer service, labor practices, and environmental protection. These standards apply equally to Fly Raven Jet’s employees and to its suppliers, contractors, consultants, business partners, and agents (collectively, “Suppliers”).

To ensure that business activities conducted with or on behalf of Fly Raven Jet meet these standards, Fly Raven Jet has established this Supplier Code of Conduct. This Code sets forth binding expectations for all Suppliers engaged by Fly Raven Jet.

Failure by any Supplier to comply with this Supplier Code of Conduct may result in corrective actions, including but not limited to: suspension of work, termination of contracts, disclosure of violations to appropriate regulatory or enforcement authorities, and pursuit of other remedies available under law or equity.

Suppliers are required to: (i) communicate this Supplier Code of Conduct to their employees, contractors, subcontractors, and representatives engaged in dealings with Fly Raven Jet; and (ii) notify Fly Raven Jet promptly of any known or suspected violation. Fly Raven Jet reserves the right to audit or inspect Supplier facilities, records, and practices to verify compliance.

This Supplier Code of Conduct supplements, and does not supersede, the Supplier’s contractual obligations to Fly Raven Jet. All contractual obligations remain in full force and effect.

Legal Compliance

Fly Raven Jet is committed to conducting all operations in accordance with applicable laws and regulations, both domestic and international. Suppliers must act with the highest ethical standards and comply with all applicable federal, state, local, and international laws in jurisdictions where they operate.

1. Antitrust and Fair Competition.
   Suppliers shall comply with all antitrust, competition, and trade practice laws. Suppliers shall not engage in price fixing, bid rigging, market allocation, limiting capacity, or any other anti-competitive conduct, whether express, tacit, written, or oral.
2. Boycotts.
   Suppliers must not participate in, support, or comply with unsanctioned foreign boycotts in contravention of U.S. law.
3. Anti-Corruption and Anti-Bribery.
   Suppliers must strictly comply with the U.S. Foreign Corrupt Practices Act (FCPA), the UK Bribery Act, and all other applicable anti-bribery and anti-corruption laws. Suppliers shall not directly or indirectly offer, promise, authorize, give, solicit, or accept any bribe, kickback, facilitation payment, or anything of value intended to improperly influence business decisions or secure an unfair advantage.

All transactions and payments must be accurately documented in the Supplier’s books and records, and any payments involving government officials must be disclosed fully and transparently.

Labor and Human Rights

Fly Raven Jet maintains a zero-tolerance policy for forced labor, human trafficking, child exploitation, or any abusive labor practices. Suppliers shall:

• Not engage in or support the use of sweatshop labor, forced labor, bonded labor, indentured labor, or abusive child labor.
• Prohibit harassment, abuse, or discrimination based on race, color, gender, religion, sexual orientation, national origin, disability, age, or any other protected status.
• Respect the rights of workers to freely associate, organize, and engage in collective bargaining in accordance with applicable law.
• Provide wages and benefits at least equal to the minimum required by applicable law or prevailing industry standards, whichever is higher.
• Ensure a safe and healthy working environment that complies with all applicable workplace safety and occupational health laws.
• Cap mandatory overtime at no more than 12 hours per week, provide at least one day off in every seven days, and comply with maximum hour laws.
• Employ no person under the age of 16 years, or the minimum age permitted by law, whichever is higher.
• Actively prohibit, monitor, and prevent any participation in human trafficking, sexual exploitation, child prostitution, or child pornography.

Health and Safety

Suppliers shall provide and maintain a safe and healthy workplace and shall perform all services in strict compliance with applicable occupational health, safety, and workplace regulations.

Suppliers shall adopt policies prohibiting hostility, harassment, unwelcome sexual advances, violence, threats of violence, and other unprofessional conduct in the workplace.

Suppliers shall ensure that their employees are informed of, and comply with, Fly Raven Jet’s applicable work rules, including prohibitions against:

• Engaging in unsafe or reckless work practices;
• Possession or use of illegal substances, alcohol, or intoxicants while on Fly Raven Jet premises or while conducting business with or on behalf of Fly Raven Jet;
• Misuse of legal or prescription medications, supplements, or other substances in a manner that impairs safety or job performance;
• Possession or use of weapons, including but not limited to firearms, while on Fly Raven Jet premises or while conducting business with or for Fly Raven Jet.

Fly Raven Jet reserves the right to request, and Suppliers shall provide upon request, worker injury performance data, including but not limited to metrics required under the Occupational Safety and Health Administration (OSHA) or comparable foreign safety standards.

Environmental Responsibility

Fly Raven Jet is committed not merely to compliance with environmental laws and regulations, but to environmental excellence and stewardship. Fly Raven Jet encourages all Suppliers to share in this commitment and to implement practices that reduce environmental impacts and foster sustainability.

Suppliers shall:

• At a minimum, comply with all applicable environmental laws and regulations;
• Operate in an environmentally responsible manner;
• Substitute non-hazardous materials where feasible;
• Minimize waste generation and establish effective recycling and waste-management programs;
• Implement pollution prevention or mitigation programs;
• Monitor and reduce greenhouse gas emissions wherever feasible;
• Conduct environmental audits to ensure ongoing compliance.
• Use natural resources efficiently and seek to reduce consumption.

Fly Raven Jet further encourages Suppliers, where appropriate, to obtain product or process certifications demonstrating sustainable practices.

Information Security and Data Privacy

Suppliers shall establish and maintain appropriate information security and privacy programs designed to protect the confidentiality, integrity, and availability of Fly Raven Jet’s data and to comply with all applicable privacy and data protection laws.

Where the nature of the Supplier’s services or products requires it, Fly Raven Jet may, at its sole discretion, require the Supplier to undergo a vendor risk management assessment or a due diligence review of its cybersecurity and privacy practices.

Suppliers shall comply with the Fly Raven Jet Third-Party Cybersecurity and Privacy Policy, which shall be made available to Suppliers upon request.

Protection of Intellectual Property

Fly Raven Jet’s intellectual property includes, without limitation: proprietary and confidential information, copyrighted material, trade secrets, trademarks and service marks, innovations and inventions, and any patentable subject matter.

Suppliers shall not use Fly Raven Jet’s intellectual property, nor represent or reference their relationship with Fly Raven Jet, for promotional purposes, marketing, or any other use except as expressly authorized in writing by Fly Raven Jet or as permitted under an applicable Supplier agreement.

Accuracy of Reporting

Suppliers shall ensure that all data, reports, and records provided to Fly Raven Jet are accurate, complete, and timely. Accurate reporting is essential to Fly Raven Jet’s compliance, safety, service standards, and financial performance.

Supplier-reported information may include, without limitation:

• Lead times;
• Quality specifications;
• Service, maintenance, and shipping data;
• Prices and invoices;
• Productivity and capacity reports;
• Types of goods and services provided;
• Audit-related disclosures;
• Repair requirements and performance measurements;
• Expense reporting;
• Disclosures regarding potential misconduct, hazards, or safety risks.

Insider Information

Suppliers may, in the course of providing goods or services to Fly Raven Jet, gain access to material non-public information regarding Fly Raven Jet or its affiliates.

Suppliers must maintain the confidentiality of such information and are strictly prohibited from:

• Using material non-public information to purchase or sell securities, whether directly or indirectly;
• Disclosing such information to any third party under circumstances where it is reasonably foreseeable that the recipient may purchase or sell securities based on such information.

Suppliers’ access to Fly Raven Jet property, facilities, and information is limited solely to the performance of contractual obligations and may not be used for any other purpose.

Roles and Responsibilities

The Fly Raven Jet Procurement Department, in coordination with business units, shall be responsible for managing Supplier relationships to ensure mutual benefit for Fly Raven Jet, its members, and its customers.

• The Procurement Department shall develop supply chain strategies, conduct solicitations, lead negotiations, select Suppliers, manage corporate-level relationships, and oversee Supplier contracts.
• Procurement shall be notified immediately if a Supplier is approached by any Fly Raven Jet employee outside of Procurement regarding substantial pricing, scope changes, or any other material contractual matters.
• Procurement must be notified of any Supplier site visit related to new business opportunities, material changes to existing business, or contract terminations.
• Business units and Procurement jointly identify operational needs, manage relationships, and measure Supplier performance.
• Business units oversee day-to-day performance and delivery of goods and services.

Suppliers must not exert wrongful or undue influence over Fly Raven Jet personnel. Similarly, Fly Raven Jet personnel must not exert wrongful or undue influence over Suppliers. Violations by either party will result in adverse consequences, up to and including termination of the business relationship and pursuit of legal remedies.

Supplier Performance Program

Suppliers shall participate in Fly Raven Jet’s Supplier Performance Program, which is comprised of a supplier scorecard system and regularly scheduled business reviews. The scorecard, developed jointly by Fly Raven Jet stakeholders and suppliers, evaluates performance across multiple dimensions, including but not limited to:

• Service levels;
• Product lead times;
• Unit costs;
• Operational impact;
• Responsiveness; and
• Quality of goods and services.

The frequency of business reviews shall be determined by (i) the nature of the product or service provided, and (ii) the supplier’s performance against established scorecard metrics. Suppliers are required to meet or exceed the minimum standards as set forth therein. Failure to do so may result in corrective action, contract termination, suspension of business dealings, or any other remedy available at law or in equity to Fly Raven Jet.

Unsolicited Bidding

While Fly Raven Jet encourages innovative proposals designed to enhance efficiency and competitiveness, all suppliers must strictly adhere to Fly Raven Jet’s procurement policies and procedures. Any attempt to circumvent established processes, including but not limited to unauthorized direct proposals, shall constitute a material violation of this Code and may result in immediate disqualification from current and future business opportunities. Both Fly Raven Jet and its suppliers share the responsibility to reasonably ensure compliance with these procurement requirements.

Supplier–Furnished Gifts, Meals, and Entertainment

Fly Raven Jet acknowledges that reasonable business courtesies may arise in the ordinary course of commerce. However, improper or excessive gifts, meals, or entertainment may create undue influence or the appearance thereof, and could give rise to violations of applicable law. Accordingly, all suppliers must comply with the following standards:

(a) Gifts

• Fly Raven Jet does not encourage the provision of gifts and expressly prohibits gifts intended to influence or that may reasonably be perceived as influencing business decisions.
• Suppliers shall not provide gifts exceeding a fair market value of USD $50 to any Fly Raven Jet employee.
• Corporate gifts commemorating significant milestones may be accepted only with the prior written approval of a Vice President of Fly Raven Jet, and under no circumstances during an active bid or negotiation.
• Gifts of cash or cash equivalents (including, without limitation, gift cards, stock, or loans) are strictly prohibited.
• Where declining a gift would cause cultural offense or impracticality, the employee may accept such a gift but must report it immediately to Fly Raven Jet’s Human Resources Department, which may require donation of the gift to a Fly Raven Jet–sponsored charitable organization.

(b) Business Meals and Entertainment

• Occasional, modest meals for legitimate business purposes may be accepted.
• Occasional entertainment (e.g., sporting events, golf, theater) is permissible only if attended by both the supplier and the Fly Raven Jet employee, is not transferable, and has supervisor approval.
• Suppliers shall not pay travel expenses for Fly Raven Jet employees under any circumstances.

(c) Premium Gifts, Entertainment, or Travel

• Premium gifts, entertainment, or travel (e.g., Super Bowl, Masters Tournament, World Cup, Academy Awards) are prohibited absent compelling business justification and prior written approval from the relevant Fly Raven Jet Senior Leadership Team member.
• For any such approved engagement, Fly Raven Jet employees must fund their own travel expenses and expense such costs internally through Fly Raven Jet.

(d) Overarching Conditions
Regardless of value or intent, Fly Raven Jet employees may never:

• Accept illegal or unlawful benefits;
• Accept cash or equivalents;
• Enter into quid pro quo arrangements;
• Accept gifts or entertainment during a live negotiation or bid;
• Participate in entertainment deemed unsavory, sexually oriented, or inconsistent with Fly Raven Jet’s standards of dignity, safety, and mutual respect.

Suppliers are expected to exercise prudent judgment at all times and shall be held strictly accountable for compliance with these provisions.

Conflicts of Interest

Suppliers shall avoid any situation, whether actual, potential, or perceived, that creates or could reasonably be construed as creating a conflict of interest in dealings with Fly Raven Jet.

• Suppliers must promptly disclose to Fly Raven Jet all financial or personal relationships between supplier personnel (or their immediate family members) and Fly Raven Jet employees (or their immediate family members) that could reasonably be perceived as influencing business decisions.
• Former Fly Raven Jet employees employed by suppliers may not, for a period of two (2) years following termination of employment, assume any responsibility in connection with Fly Raven Jet’s business absent the prior written consent of Fly Raven Jet’s Chief Legal Officer.
• Additionally, for one (1) year following separation, any individual formerly employed by Fly Raven Jet at the Director level or above (outside Procurement) may not, on behalf of a supplier, engage in communications, meetings, RFPs, or negotiations with Fly Raven Jet personnel, unless expressly authorized in writing by the Chief Legal Officer.
• Nothing herein shall limit Fly Raven Jet’s rights under applicable law, enforceable agreements, or internal policies concerning the protection of confidential, proprietary, or trade secret information.

Failure to comply with this Section 13 shall constitute grounds for immediate termination of business, pursuit of all legal and equitable remedies, and, where applicable, referral to governmental or regulatory authorities.

Duty to Report Violations; Non-Retaliation Policy

Suppliers are required to promptly report to Fly Raven Jet LLCany known or suspected violations of these Standards committed by their own employees, contractors, or representatives, or by any employee, contractor, or representative of Fly Raven Jet. Reports of violations, complaints, or concerns may be submitted anonymously (where permitted by applicable law) by sending an email to kwame@flyravenjet.com.

Fly Raven Jet strictly prohibits any form of retaliation, reprisal, or adverse action against any supplier, employee, or representative who, in good faith, reports suspected misconduct, violations, or breaches of these Standards.

Notwithstanding the foregoing, a supplier’s disclosure to Fly Raven Jet of misconduct by such supplier’s personnel does not create any guarantee that such misconduct will not adversely affect Fly Raven Jet’s evaluation of the supplier or Fly Raven Jet’s decision to continue or terminate the commercial relationship with such supplier.

However, Fly Raven Jet will generally consider such voluntary disclosure as a demonstration of the supplier’s good faith intent to comply with these Standards and maintain integrity in the supplier relationship. Suppliers are expected, as a condition of continued engagement, to cooperate fully, promptly, and truthfully in any investigation of potential misconduct conducted by Fly Raven Jet or its duly authorized representatives.