Polamer Precision, Inc.’s Code of Business Conduct

Polamer Precision, Inc.’s Values

Polamer Precision is motivated by commonly held principles and values that allow us to work toward mutual goals. The core of these values is that Polamer Precision is a company of honesty and integrity. This philosophy is fundamental to our ability to attract and retain the best people, gain and keep the trust of our customers and our partners, support the communities in which we operate, and protect our reputation.

It has always been, and continues to be, our policy to conduct business in compliance with all applicable laws and regulations and in accordance with the highest ethical standards. The Polamer Precision, Inc. Code of Business Conduct is applicable to all our suppliers, their subcontractors and other business partners that do business with Polamer Precision, Inc. We expect that Polamer Precision employees, and the people acting on our behalf, will adhere to these principles.

How to Use the Code of Business Conduct

The Code of Business Conduct is not intended to cover every issue or situation you may face as a Polamer Precision employee. Nor does it replace other more detailed policies. You should use the Code as a reference guide in addition to other Polamer Precision policies, which are included in the Employee Handbook or required for your specific job. Polamer Precision reserves the right in its sole discretion to modify or eliminate any of the Code’s contents without prior notice.

Our values guide our behaviors and our interactions. Polamer Precision employees are great people who share the following values:

  • Honesty and Integrity;
  • Respect for those we do business with and our community;
  • Willingness to take on challenges and see them through; and
  • Accountable for commitments, results, and quality to customers, stakeholders, and employees.

The Polamer Precision Code of Business Conduct summarizes the regulatory requirements and business practices that guide our decision making and business activities. The Code contains basic information about our policies as well as information about how to obtain guidance regarding a particular business practice or compliance concern. It is essential that you thoroughly review this publication and make a commitment to uphold its requirements.

If you need guidance regarding a business practice or compliance issue, or if you want to report a possible violation, talk to your immediate supervisor, manager, another member of management or Human Resources.

Polamer Precision will handle all inquiries discreetly and preserve confidentiality of anyone requesting guidance or reporting a possible violation to the extent possible and within the limits allowed by the law.

Polamer Precision, Inc.’s Code of Business Conduct

Statement of Policy

Polamer Precision manages business in compliance with all applicable laws and regulations of the countries in which we operate, and in accordance with our company’s Code of Business Conduct. All employees are expected to comply with the Polamer Precision Code of Business Conduct, which is essential to maintaining our reputation for honesty, quality, and integrity. It is also each employee’s responsibility to report to the company any situation where our Code or the laws are being violated. Any employee disclosing, in good faith, violations or suspected violations of legal requirements or Polamer Precision Code of Business Conduct will not be subjected to retaliation or retribution. Likewise, failure to comply with the provisions of the Polamer Precision Code of Business Conduct will not be tolerated.

This Code of Business Conduct sets forth our code of conduct for all employees of Polamer Precision. Throughout the Code, “Polamer Precision” is used to refer to the enterprise as a whole, to each person within it, and to any person who represents Polamer Precision or any part of the Polamer Precision organization.

Personal Responsibility: All employees are required to abide by all applicable governmental laws, rules and regulations, Polamer Precision policies, including this Code, and all other Codes of ethical
conduct. In addition, employees must promptly report any violation of such laws, rules, regulations and policies to an appropriate person within the company.

Managerial Responsibility: Managers (defined as employees who supervise others) are expected to exemplify the highest standards of ethical business conduct. Managers are responsible for creating a work environment that promotes honest and ethical behavior and are expected to be familiar with the policies and legal requirements applicable to our organization to ensure employees receive appropriate training and guidance.

Managers must be diligent in discovering unethical or illegal conduct, and must promptly take corrective or disciplinary action when misconduct is substantiated.

Discipline: Employees who violate Polamer Precision policy, including this Code, may be subject to disciplinary action up to and including termination. Employees who commit criminal acts may be subject to immediate termination and/or possible civil or criminal prosecution. Obstructing or undermining investigations, withholding or destroying information, including failing to report a violation, or providing misleading information are violations of this Code.

No Retaliation: Polamer Precision forbids retaliation against any employee who, in good faith, reports a suspected violation of law or policy, including harassment or discrimination. This includes blatant actions, such as firing, transferring, demoting or publicly attacking someone, as well as more subtle retaliation, such as avoiding someone, leaving him or her out of professional or social activities and so on. It includes actions taken by managers and employees alike.

Any person involved in retaliation will be subject to disciplinary action up to and including discharge.

Compliance: This Code of Business Conduct will be audited, monitored, rapidly responses to reported issues, and steps to prevent further similar offenses to ensure compliance. President, Vice President, and Office Director will provide oversight and support to The Code of Business Conduct process and compliance.

Polamer Precision, Inc.’s Code of Business Conduct

Laws and Regulatory Requirements

Integrity: Polamer Precision employees interact with a variety of individuals and groups—including our customers, competitors, co-workers, suppliers, government and regulatory agencies, and the communities in which we operate. We are committed to interacting with all of these audiences in a respectful, ethical manner and in compliance with applicable laws and regulatory requirements.

Regulatory Compliance: We are aware of and obey the laws and regulations that govern the management of our business. We are responsible for understanding these laws and regulations as they apply to our jobs and for preventing, detecting, and reporting instances of non-compliance to a member of Polamer Precision management or Human Resources.

Regulatory Investigations, Inspections, and Inquiries: We are direct, honest, and truthful in our discussions with regulatory agency representatives and government officials. During investigations, inspections, and inquiries we will fully cooperate by responding to appropriate requests for information.

International Business Activities: Polamer Precision acknowledges and respects the diverse cultures, customs, and business practices it encounters in the international marketplace. Polamer Precision will comply with both the applicable U.S. laws and regulations that govern its operations and local laws wherever it does business.

Bribery and Anti-Corruption: Polamer Precision prohibits corruption of government officials and the payments of bribes or kickbacks of any kind, whether in dealings with public officials or individuals in the private sector. Polamer Precision is committed to observing the Code of Conduct set forth in the United States Foreign Corrupt Practices Act and the applicable anti-corruption and anti-money laundering laws of the countries in which we operate.

Anti-Boycott Requirements: Polamer Precision complies with U.S. law that prohibits participation in international boycotts that are not sanctioned by the U.S. government.

Trade Controls: Polamer Precision is committed to maintaining compliance with all laws and regulations governing the import, use, export and re-export of its products, components, goods, services and technical data.

Fair Competition and Antitrust: Polamer Precision encounters laws and regulations designed to promote fair competition and encourage ethical and legal behavior among competitors. Antitrust laws and fair competition laws generally prohibit any activity that restrains free trade and limits competition. We conduct our business in compliance with these laws.

Internal Controls: Polamer Precision believes reliable internal controls are critical for proper, complete and accurate accounting and financial reporting. All employees must understand the internal controls relevant to their positions and follow the policies and procedures related to those controls. Employees are strongly encouraged to talk to their managers or supervisors immediately if they ever suspect that a control does not adequately detect or prevent inaccuracy, waste or fraud.

Audits: Polamer Precision believes that audits performed by our internal and external auditors help ensure compliance with established policies, procedures and controls. Audits also help identify potential weaknesses so they may be remediated promptly. Every employee is required to cooperate fully with internal and external audits. This means always providing clear and truthful information and cooperating fully during the audit process.

Fraud: Engaging in any scheme to defraud anyone —of money, property or honest services — violates Company policy and the law and carries severe penalties. Those consequences apply to any dishonest or fraudulent activities, including misusing or stealing Company assets or falsifying a travel and

Polamer Precision, Inc.’s Code of Business Conduct

entertainment expense report, among other violations. Polamer Precision relies on its internal controls and the personal integrity of all its employees, contractors and directors to protect Company assets against damage, theft and other unauthorized use.

Reporting Possible Violations: Polamer Precision expects any employee to speak up promptly if there is any reason to suspect that anyone at Polamer Precision or in any company in the supply chain has violated Company policies and/or local laws. Employees must also report any activity that could damage the Company’s reputation to their supervisor, Human Resources or anyone in management. You can submit a report via www.polamer.us website which is accessible 24 hours a day, seven days a week.

Trust and Respect

Responsible Leadership: We manage our business responsibly in order to maintain the confidence, respect, and trust of our customers, consumers, partners, and stakeholders. We are committed to acting with integrity, being responsive and accountable to our customers and partners, and remaining a leader in our field.

Product and Service Quality: Polamer Precision products are manufactured to meet the expectations of our customers, consumers, and partners for high quality and exceptional service. We continually seek new ways to improve our products, service, and responsiveness.

Communication: We apply full, fair, accurate, timely, and understandable disclosure in reports and documents that are required by state and/or federal laws and in other public communications as well. We establish and maintain clear, honest, and open communications; listen carefully; and build our relationships on trust, respect, and mutual understanding. We are accountable and responsive to the needs of our customers and take our commitments to them seriously. Our advertising, sales, and promotional literature seeks to be truthful, accurate, and free from false claims.

Obtaining Competitive Information: Polamer Precision has an obligation, and is entitled, to keep up with developments in our industry, including obtaining information about our competitors. We obtain information about our competitors through honest, ethical, and legal methods.

Fair Information Practices: Our business uses technology to manage information, and we treat that information with confidentiality and integrity. We have adopted privacy practices and operate in a manner that complies with local, state and federal privacy laws.

Customer Relations: We compete fairly and in accordance with the Code of Business Conduct in all of our customer relationships. We want to earn business on the basis of superior services and products and competitive prices, not through improper, unethical, or questionable business practices.

Our credibility with our customers depends on our ability to fulfill our commitments. Any time we fail to live up to a commitment, hard-earned customer trust is damaged.

To preserve our customer relationships:

  •  We do not misrepresent our services or products in any sales or promotional efforts.
  •  We communicate clearly, so that our customers understand the terms of our businessrelationships, including contracts, performance criteria, schedules, prices, and responsibilities.
  •  We protect our customers’ confidential information.
  •  We only make promises to customers that we believe we will be able to keep.

Polamer Precision, Inc.’s Code of Business Conduct

Doing Business with the Government: Doing business with the government is not always the same as doing business with private parties. Activities that might be appropriate when working with private sector customers may be improper, or even illegal, when a national or local government is our customer. For example, business courtesies or entertainment that might be acceptable when dealing with private parties, like paying for meals or drinks, may not be appropriate when working with government officials. In addition, due to complex legal requirements, some types of bid-related information, which might be proper in a transaction with a private party, may not be requested or received when dealing with governments or their officials.

Choosing Suppliers and Consultants: Polamer Precision strives to be fair in our choice of suppliers and consultants and is honest in all business interactions with them. We choose our suppliers and consultants based on appropriate criteria, such as qualifications, competitive price, and reputation. Anyone responsible for buying or leasing materials or services on behalf of Polamer Precision must conscientiously guard their objectivity.

We also expect our suppliers and consultants, and others who do business with us or on our behalf , to conduct their business on behalf of Polamer Precision in compliance with all applicable laws and regulations and in accordance with the highest ethical standards. Suppliers are expected to provide high- quality services and products while maintaining flexibility and cost-effectiveness. All suppliers are required to train their employees and representatives to ensure that they are aware of expectations regarding their behavior. We do not engage in any unethical or illegal conduct with our suppliers. We do not accept incentives such as kickbacks or bribes in return for conducting business with them.

Company Assets

Financial Integrity: Polamer Precision honestly and accurately records and reports business information. We comply with all applicable local, state, and federal laws regarding record completion and accuracy. We require that financial transactions be executed in accordance with management’s authorization, and recorded in a proper manner in order to maintain accountability for Polamer Precision assets. Our financial information reflects only actual transactions and is in compliance with all applicable local, state and federal laws.

Use and Protection of Assets: Polamer Precision wisely uses and protects the assets of the Company, including property (both physical and intellectual), supplies, consumables, and equipment. These assets are used exclusively for Polamer Precision business purposes.

Fiscal Responsibility: Polamer Precision employees exercise good stewardship over and spend Polamer Precision funds in a responsible manner.

Use of Information Technology: At all times, we strive to use good judgment and common sense; conduct ourselves ethically, lawfully, and professionally; and follow applicable authorization protocols while accessing and using company-provided information technology and its contents. In using these company assets and systems, we do not create, access, store, print, solicit, or send any material that is intimidating, harassing, threatening, abusive, sexually explicit, or otherwise offensive or inappropriate, nor do we send any false, derogatory, or malicious communications.

Intellectual Property: Polamer Precision complies with the laws and regulations that govern the rights to and protection of our own and others’ copyrights, trademarks, patents, trade secrets, and other forms of intellectual property.

Creation, Retention, and Disposal of Records and Information Assets: Polamer Precision creates, retains, and disposes of our business records and information assets, both written and electronic, as part

Polamer Precision, Inc.’s Code of Business Conduct

of our normal course of business in compliance with Polamer Precision policies and applicable regulatory and legal requirements.

Confidential and Proprietary Information: All employees have ethical and legal responsibilities to protect Polamer Precision confidential and proprietary non-public information and communicate it only as necessary to conduct Polamer Precision business. Employees do not use this information for personal advantage or for non-Polamer Precision business use, and maintain this confidentiality even after leaving Polamer Precision’s employment.

Third-Party Software: Software and other content information is used only in accordance with their associated licenses and/or terms of use. Polamer Precision prohibits the making or using of copies of non-licensed copyrighted material, including software, documentation, graphics, photographs, clip art, animation, movie/video clips, sound, and music.

Insider Information and Securities Trading: In the course of doing business for Polamer Precision or in discussions with one of its customers, suppliers, or partners, we may become aware of material non- public information about that organization. Information is considered “material” if there is a substantial likelihood that a reasonable investor would consider it important in making a decision to trade in the public securities of the company. Individuals who have access to this type of information are called “insiders.” This information is discussed on a limited, “need to know” basis internally, and is not shared with anyone outside of Polamer Precision. We do not buy or sell the public securities of a company on the basis of such information, and we do not share (“tip”) this information with others.

Purchasing Decisions and Practices: In our purchasing decisions, negotiations, contract development, and contract administration Polamer Precision complies with the applicable laws and regulations that govern those relationships.

Our People

Openness, Honesty, and Respect: In our relationships with each other, we strive to be open, honest, and respectful in sharing our ideas and thoughts, and in receiving input.

Diversity: Polamer Precision promotes and supports a diverse workforce at all levels of the company. It is our belief that creating a work environment that enables us to attract, retain, and fully engage diverse talents leads to enhanced innovation and creativity.

Polamer Precision values and demonstrates respect for the uniqueness of individuals and the varied perspectives and talents they provide. Polamer Precision has an inclusive work environment and actively embrace a diversity of people, ideas, talents and experiences.

Equal Opportunity: Polamer Precision promotes a cooperative and productive work environment by supporting the cultural and ethnic diversity of its workforce and is committed to providing equal employment opportunity to all qualified employees and applicants. We do not unlawfully discriminate on the basis of race, color, sex, sexual orientation, gender identity or expression, religion, national origin, marital status, age, disability, veteran status, or genetic information in any personnel practice, including recruitment, hiring, training, promotion, and discipline.

Freedom from unlawful discrimination includes freedom from any form of discriminatory harassment. Prohibited harassment includes conduct that is intended to interfere or that has the effect of unreasonably interfering with a fellow employee’s work performance or creating an environment that is intimidating, hostile, or offensive to the individual. Polamer Precision takes allegations of harassment and unlawful discrimination seriously and address such concerns that are raised regarding this policy.

Workplace Health & Safety: The health and safety of our people are of utmost importance to Polamer Precision and the company is committed to protecting the health and well-being of every employee. We

Polamer Precision, Inc.’s Code of Business Conduct

strive to protect our people, customers, and the public from injury and illness. Polamer Precision actively promotes the health and safety of its employees through compliance with applicable laws and regulations. Polamer Precision expects its employees to support this commitment by complying with all Polamer Precision practices, rules and regulations regarding safety and by actively striving to identify opportunities for improvement in Polamer Precision’s health and safety programs.

Employees are required to advise the company of any workplace injury, instance of non-compliance, or any situation presenting a danger of injury. This information will assist in preventing injuries, and will ensure that appropriate medical attention is provided. Through investigation of such reports, we can identify contributing factors and determine if our policies and processes are effective and adequately communicated. When an unsafe condition, practice, or non-compliant action is identified, prompt and appropriate action must be taken to correct the condition and prevent it from happening again.

Drug and Alcohol Policy: It is Polamer Precision’s policy to maintain a drug-free and alcohol-free work environment. Use of alcohol and/or illegal drugs creates serious health and safety risks in the workplace. The use, sale, or possession of alcohol, illegal drugs, or other illegal substances is strictly prohibited while at work, on company property, or while on company business. This prohibition also includes illegal or improper use of controlled substances.

Reporting to work under the influence of any such substance is strictly prohibited. No one is permitted to go on duty or remain on duty if they possess or have the presence of an illegal or unauthorized controlled substance or alcohol in their system. Employees are not permitted to go on duty or remain on duty if they are impaired by the presence of an authorized controlled substance. In addition, we must comply with all laws and regulations regarding the use or possession of alcohol, illegal drugs, and controlled substances.

Training / Awareness: Polamer Precision will provide training of new employees and ongoing awareness of our employees on The Code of Business Conduct and compliance requirements.

Workplace Violence Prevention: Polamer Precision is committed to a safe working environment, free of threats, intimidation and physical harm. Everyone has a right to work in a safe environment and shares the responsibility for assuring each other’s safety. Polamer Precision has adopted a zero tolerance workplace violence policy. This means we will investigate and take appropriate action against any threat to a safe workplace.

Polamer Precision prohibits violent behavior including, but not limited to, physical assaults, fighting, threatening comments, intimidation, and the intentional or reckless destruction of company, employee, or customer property. Any comments or behavior that reasonably could be interpreted as intent to do harm to people or property will be considered a threat. We also prohibit the unauthorized possession and/or use of weapons by any employee while at work, on company property, or while on company business.

Any employee who believes that he or she may be the target of violence or threats of violence, or is aware of violent or threatening conduct by, or directed at, a Polamer Precision employee that could result in injury to a person or the destruction of property, has a responsibility to immediately report the situation to his or her immediate supervisor, manager, any member of management or Human Resources.

Conflicts of Interest: All employees are expected to give our undivided business loyalty to Polamer Precision when conducting our job-related duties. Accordingly, employees must be careful to avoid conflicts of interest – situations where private interests conflict, or even appear to conflict, with the interests of Polamer Precision as a whole. Therefore, employees should not place themselves in situations that might force them to inappropriately choose between their own personal or financial interests and the interests of Polamer Precision.

Conflicts of interest can arise in many common areas, despite best efforts to avoid them. However, such conflicts can generally be resolved by promptly notifying your manager of any actual, perceived, or

Polamer Precision, Inc.’s Code of Business Conduct

potential conflict of interest situation. The manager can then provide guidance on how best to resolve the conflict. If needed, an employee also may contact Human Resources for guidance.

All Employees must avoid conflicts of interest or situations giving the appearance of a conflict of interest in dealing with our customers.

Gifts and Entertainment: All employees and representatives of Polamer Precision should understand the legal and ethical issues associated with gifts and entertainment and how they can affect our relationship and reputation with our customers, suppliers, and the general public. The decision to offer or to accept gifts or entertainment should be made only in compliance with legal requirements and ethical considerations, and with the involvement of a manager if unsure of the appropriate course.

The issue of gifts and gratuities may have legal implications when the government, or government entity is involved, and serious consequences can result from mishandling these relationships. Offering or accepting bribes and pay-offs is always prohibited.

Business gifts and entertainment are courtesies designed to build goodwill and sound working relationships among business partners. We do not, however, want to obtain business through improper means as to gain any special advantage in a relationship. Business gifts that compromise, or even appear to compromise, our ability to make objective and fair business decisions are inappropriate.

Solicitation of gifts is never appropriate, even for charitable purposes. All gifts and entertainment, other than infrequent items of nominal value, must be disclosed to a manager.

Doing Business with the Company: A conflict of interest could arise if an employee, a spouse, a relative, or a close personal friend, has a personal stake in a business that supplies or seeks to supply goods or services to Polamer Precision , is a Polamer Precision customer or potential customer, or competes with Polamer Precision. Accordingly, the following Code applies in such situations:

  •  If a Polamer Precision employee, spouse, relative, or close personal friend is an employee of, or has a significant interest in a business that provides or is seeking to provide goods or services to Polamer Precision, the Polamer Precision employee must not attempt to use his or her position with Polamer Precision to influence the bidding process or negotiation in any way. Similarly, the Polamer Precision employee must not use personal relationships to improperly influence dealings with a customer or a potential customer.
  •  If the position of a relative or friend who works for a competitor is such that a potential conflict of interest could arise, the Polamer Precision employee should seek guidance from a manager.Employment Outside of Polamer Precision: Although employment outside of Polamer Precision is not necessarily a conflict of interest, depending upon an individual’s position with Polamer Precision and Polamer Precision’s relationship with the other organization, a conflict could arise. Outside employment also could be a conflict of interest if it causes, or might be perceived by others to cause, an employee to choose between that interest and the interests of Polamer Precision. If a situation arises, either through scheduling or other potential conflicts, our undivided business loyalty requires that we resolve the conflict in favor of Polamer Precision.

Polamer Precision encourages the use of good judgment, discretion, and moderation when giving or accepting gifts or entertainment in business settings. Any gifts and entertainment given or received must be in compliance with law, must not violate the giver’s and/or receiver’s policies on the matter. We do not solicit gifts, entertainment, or favors of any value from persons or firms with which Polamer Precision actually or potentially does business. Nor do we act in a manner that would place any supplier or customer in a position where he/she may feel obligated to make a gift, provide entertainment, or provide personal favors in order to do business or continue to do business with Polamer Precision.

Polamer Precision, Inc.’s Code of Business Conduct

In some cases, Polamer Precision employees may be involved in outside businesses that are not Polamer Precision competitors or suppliers. These situations do not necessarily constitute a conflict of interest, but it is the employee’s responsibility to ensure that these activities do not conflict with Polamer Precision’s interests.

This requires keeping the two activities strictly separated by adhering to the following standards. A Polamer Precision employee:

  •  May not do work relating to other organizations on Polamer Precision time.
  •  May not use Polamer Precision equipment and supplies, or the time of any Polamer Precisionpersonnel for outside work.
  •  May not promote products or services from an outside business to other Polamer Precisionemployees during working hours or on Polamer Precision property.
  •  May not attempt to sell products or services from an outside business to Polamer Precision.
  •  May not use his or her position in the company to promote an outside business.Our Community

    Political Activities and Contributions: Polamer Precision encourages all employees to be informed voters, but personal participation in the political process, including contributions of time or financial support, is completely voluntary.

    Environmental Protection: Polamer Precision is committed to conducting business in a manner that protects the environment. Our commitment to the environment goes beyond complying with environmental laws and includes a commitment to advancing programs that promote improvement of the environment.

    Our environmental responsibilities include:

    • Properly storing, handling, and disposing of hazardous and other waste;
    • Managing wastewater and storm water in compliance with applicable regulations;
    • Complying with laws regarding clean air;
    • Protecting against and appropriately responding to spills and releases; and
    • Seeking ways to minimize waste, reduce energy consumption and prevent pollution.

    In addition, Polamer Precision must provide timely, truthful, and accurate information required in connection with applications for environmental permits and other reports called for under permits or regulatory requirements.

    Prohibition Against Human Trafficking: Polamer Precision condemns all forms of human trafficking and commercial exploitation, including the sexual exploitation of men, women or children. Polamer Precision is committed to a work environment that is free from human trafficking, forced labor and unlawful child labor. Polamer Precision requires its supply chain partners to observe the law and conduct business in an ethical and responsible manner.

Freely Chosen Employment: Forced, bonded or indentured labor or involuntary prison labor shall not to be used. All work will be voluntary, and employees shall be free to leave. Employees shall not be required to hand over government-issued identification, passports or work permits as a condition of employment.

Polamer Precision, Inc.’s Code of Business Conduct

Child Labor Avoidance: Child labor is not to be used in any stage of manufacturing. The term “child” refers to any person under the age of 15 (or 14 where the law of the country permits), or under the age for completing compulsory education, or under the minimum age for employment in the country, whichever is greatest. The use of legitimate workplace apprenticeship programs, which comply with all laws and regulations, is supported. Employees under the age of 18 shall not perform work that is likely to jeopardize their health or safety.

Citizenship and Community Service: Polamer Precision has a strong and demonstrated commitment to the improvement of society as well as the communities we serve and in which we operate. We encourage the support of charitable, civic, educational, and cultural causes.

How to Suggest Changes to the Code of Business Conduct

If you have any suggestions for changes to the Polamer Precision Code of Business Conduct, please submit them promptly, as indicated below, while they are fresh in your mind. This form is included for your convenience in submitting recommendations for changes. If you prefer, you may use your own words, stationary, and format. Please submit suggestions to Human Resources.