Corporate Responsibility

Code of Business Conduct and Ethics

AMS Group and its business units are committed to conducting business in a legal, ethical and socially responsible manner. We consistently focus on creating value and innovation to benefit our partners, clients and suppliers while also ensuring the health, safety and welfare of our employees and the communities in which they operate. Further details are described below.

Our Code of Business Conduct and Ethics, which was amended in 2020, reflects our commitment to honesty, integrity and the ethical behavior of company employees, officers, and directors. Our managers and supervisors play an important role in reinforcing our policies and commitment to ethics by setting the example of ethical conduct and providing employees with continuous training, education and resources that support the policies. Employees are encouraged to speak up if they have concerns and contact the identified ethics resources contacts. We continually assess our ethics program and identify training opportunities, modifying the program as necessary.

Code of Ethics

The Code of Ethics governs the actions, interactions, and working relationships of company employees, officers and directors with customers, fellow employees, competitors, government and self-regulatory agencies, investors, the public, and anyone else with whom the company has contact.

The Code of Ethics sets forth the expectation that employees, officers, and directors will conduct business legally. It further addresses conflict of interest situations, international trade compliance, protection and use of company assets, corporate opportunities, fair dealing, confidentiality, human rights and reporting of illegal or unethical behavior. The Code of Ethics expressly prohibits paying, offering, accepting or soliciting bribes in any form—directly or indirectly. Only the Board of Directors may waive a provision of the Code of Ethics with respect to an executive officer or director. Any such waiver will be promptly disclosed on AMS Group’s website and as otherwise required by rule or regulation.

Code of Ethics and Whistleblower Policy

We encourage employees to disclose—without fear of retaliation—alleged wrongdoing that may adversely impact AMS Group, its customers, stockholders, fellow employees or the public. Our Code of Ethics and Whistleblower Policy sets forth procedures for reporting alleged financial and non-financial wrongdoing on a confidential and anonymous basis. It also establishes a process for investigating reported acts of wrongdoing and retaliation. Reports may be made directly to a supervisor, Human Resources, operating unit management, executive management, the Chief Financial Officer or Chief Executive Officer.

Human Rights

We are committed to supporting fundamental human rights and believe in the dignity and worth of all individuals. As such, we treat all people around the world with fairness and respect. We do not use or allow the use of child, slave or forced labor, or human trafficking in our business activities. We condemn any degrading treatment of individuals and are committed to providing safe working conditions.

Promoting a Talented and Diverse Workforce

Talent Development

We value our employees as they are the talent that helps ensure our future success. As we grow, our reliance on our employees and our succession planning becomes more critical. To support the advancement of our employees, we offer training and development programs that encourage advancement from within, and we continue to fill our team with strong and experienced management talent. We leverage both formal and informal programs to identify, foster, and retain top talent.

Growing Our Leadership from Within

As a fast-growing company, we continually need strong leaders, and as our workforce grows and develops, we look internally for emerging leaders. We encourage our employees to learn and develop more advanced skills that will enable them to contribute at a higher level and provide them greater satisfaction within their roles. This approach allows us to identify top performers, improve employee performance and retention, and increase our organizational learning while supporting the promotion of our current employees.

Our executive team also mentors rising talent on a more informal basis. This informal mentorship achieves a number of goals, including accelerating the development of top performers, increasing organizational learning, and improving employee performance and retention. The executive team also commits substantial time to evaluating the bench strength of our leadership and working with our leadership to improve their performance.

Diversity

We are committed to being open, inclusive and supportive to all. Our workforce includes talented people from many backgrounds. We welcome and value new ideas, different experiences and fresh perspectives.

Diversity and inclusion make us stronger as a business so we can effectively serve all our stakeholders. Our businesses that serve as government contractors develop and implement affirmative action plans that promote qualified minorities, women, persons with disabilities, and covered veterans. We are committed to diversity, inclusion and equal employment opportunities in all personnel actions, regardless of race, color, religion, gender, national origin, citizenship status, age, marital status, gender identity or expression, sexual orientation, physical or mental disability, or veteran status.

All employees are prohibited from engaging in discrimination in the workplace based on gender, age, race, creed, national origin, religion, sexual orientation, gender identity, disability, or other personal characteristics protected by law.

Data Security

The security of information pertaining to our customers, employees, suppliers, and other business partners is vitally important to us. We are committed to ensuring that this information is adequately protected.

Security measures employed to achieve this protection vary by operating unit and include third-party cybersecurity assessments, vulnerability assessments and penetration testing. Our cybersecurity incident response plan includes the following measures to support data security:

Each operating unit has one or more individuals responsible for data security and privacy. These individuals are encouraged to share ideas on topics like cybersecurity.
All operating units have undergone cybersecurity assessments conducted by a third party in accordance with NIST 800-171.
All operating units have a number of tools to help enhance data security and privacy, including penetration testing and employee training.

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Health and Safety

We are committed to ensuring the health and safety of our employees, customers and users of our products. Our goal is to build, design, maintain and operate our facilities to ensure safety of operations and minimize process and product risks. We expect our business units to operate in an equally diligent and responsible manner. We also empower our employees to promote a safe environment and expect them to report any risks, potential hazards, incidents and “near misses” so that appropriate action can be taken.

Commitment to Veterans

We honor the legacy of all who have served.

As individuals and corporate citizens, AMS Group works hard to make a difference in our local communities, particularly with respect to our veterans. We have established partnerships with several veteran-related charitable organizations where our employees are contributing their time and monetary support.

We are proud to support the following organizations:

Sentinels of Freedom Scholarship Foundation

Sentinels of Freedom Scholarship Foundation, which assists severely wounded, post-9/11 veterans in their efforts to become productive and self-sufficient members of their communities as they transition back into civilian life.

Navy SEAL Foundation

Navy SEAL Foundation, which provides immediate and ongoing support and assistance to the Naval Special Warfare Community and its families.

Conflict Minerals

We are committed to complying with the requirements regarding the use of “conflict minerals” (i.e., tin, tungsten, tantalum and gold) under rules issued by the U.S. Securities and Exchange Commission. The rules require us to determine the extent to which our products contain conflict minerals originating from the Democratic Republic of the Congo and certain adjoining countries (“Covered Countries”).

We are required to analyze the products we manufacture and the raw materials and components we purchase through supply chain due diligence if conflict minerals are sourced from the Covered Countries. The purpose of these rules is to reduce the funding of armed groups engaged in conflict and human rights abuses.

Accordingly, we commit to:

Work diligently to identify the presence of conflict minerals in our supply chain that are necessary to the function or production of our products.

Develop processes to determine whether conflict minerals in our supply chain originate from Covered Countries or are derived from recycled or scrap sources.

If necessary, perform supply chain due diligence in accordance with the OECD due diligence framework or other similar standards.

Inform our suppliers of the SEC reporting requirements related to conflict minerals.

In addition to the foregoing commitments, we expect our suppliers to perform similar due diligence on the sources of conflict minerals in their supply chains and make their findings available to us.