Policies

Conflict Minerals Policy Statement

BACKGROUND
Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 requires publicly traded companies in the United States to conduct due diligence on theirs supply chains and to disclose whether the products they manufacture or contract to manufacture contain “conflict minerals”. “Conflict minerals” refers to gold, as well as tin, tantalum, and tungsten (also called 3TG minerals), the derivatives of cassiterite, columbite-tantalite, and wolframite. While AE Techron is not a publicly traded company, we support the goal of ending civil conflict and human rights abuses, and help assure our customers that their CM polices are being supported and complied with.

POLICY
Some of the parts that go into AE Techron products contain Tantalum, Tin and Gold. AE Techron does not purchase tin, tantalum or gold directly from smelters or mines. Furthermore, there are multiple supply chain layers that separate us from smelters and mines from which these minerals are sourced, and these down-chain suppliers may also change smelters without our knowledge or permission. AE Techron endeavors in good faith to ensure that the parts purchased for our final products are consistent with sound CM policy and customer requirements. The effort made by AE Techron is intended to be consistent with our due diligence in support OECD Guidance and related polices.

EXPECTATIONS OF OUR SUPPLIERS
It is our expectation that our suppliers will adopt policies and procedures with respect to conflict minerals that will enable us to reasonably assure products supplied to AE Techron are conflict-free consistent with Section 1502 of Dodd-Frank. Where applicable, suppliers of parts or materials containing conflict minerals will document that they purchase only from CFSI conflict free smelters. AE Techron will incorporate into contracts and agreements the requirement to use and source only CMfree parts and assemblies.

Code of Conduct

AE Techron’s reputation for reliability and high performance is built on more than solid engineering and manufacturing. Our product integrity is built not only on the quality of AE Techron’s products and services but also on our employees’ history of honest, ethical and fair relations with its business partners and our suppliers.

Every AE Techron leader, employee and representative is expected to adhere to this Code of Conduct. If you suspect any violations of the Code of Conduct or any other AE Techron policy, you are encouraged to report such activity to your supervisor or department manager. Please take a few moments to review this document. If you have questions, please contact your supervisor.

INTRODUCTION
This Code of Conduct (the “Code”) describes the standards of conduct required of each officer, director, supervisor and employee of AE Techron, its representatives and agents around the world. The Code sets forth the basic guiding principles and values of AE Techron and all members of the AE Techron organization. These general principles are supplemented by AE Techron’s policies and procedures, which expand upon the objectives in the Code and on your obligations to conduct AE Techron’s business with integrity. A copy of the Code is available on AE Techron’s website at www.AE Techron.com. Other AE Techron policies and procedures are available in the employee manual or can be provided by your supervisor. Any member of the AE Techron organization who fails to comply with the Code or any AE Techron policy or procedure will be subject to appropriate discipline, which may include termination of employment or affiliation with AE Techron. Non-compliance with certain aspects of the Code also may subject the individual offender or AE Techron to civil or criminal liability.

GLOBAL COMPLIANCE POLICY
Unless previously approved by AE Techron Management, in countries where the Code is more restrictive than local law or practice, AE Techron employees are required to follow the Code, and where applicable laws are more restrictive than the Code, AE Techron employees are required to follow applicable laws. Further, where any provision of the Code requires or permits conduct that would be in violation of any applicable law for that area, employees must always comply with all applicable laws.

RESPECT FOR THE INDIVIDUAL
Unlawful discrimination in the hiring, promotion, compensation or retention of employees is strictly prohibited. Abusive, harassing or offensive conduct is not permitted, whether verbal or physical. Examples include unwelcome sexual advances and derogatory ethnic or racial comments. Retaliation against any employee for reporting discrimination or harassment will not be tolerated. Any employee feeling her or his work environment is abusive or unsafe can be assured of immediate attention and that they will not be required to work in any environment in which they feel unsafe or harassed.

HEALTH AND SAFETY
Members of the AE Techron organization must comply with applicable health and safety regulations and AE Techron’s policies, procedures and safety initiatives. While on the job, employees must be free from the influence of any substance, legal or illegal, that could create an unsafe environment.

AVOIDING CONFLICTS OF INTEREST
AE Techron employees must avoid conflicts of interest that may interfere with AE Techron’s business interests or with an employee’s obligations to AE Techron. Situations that may personally benefit the employee, the employee’s
friends or family or that may potentially interfere with AE Techron’s business interests might be construed as conflicts of interest. It would not be possible to reference every scenario giving rise to a potential conflict, however some examples of situations that could create a conflict of interest include:

Competing with AE Techron in another business venture
Owning or investing in a competitor or supplier of AE Techron (other than as a passive investor in a publicly traded company)
Using AE Techron confidential information or other AE Techron assets for personal gain

Any activity that may give rise to a conflict of interest must be promptly and fully disclosed to the AE Techron Management. It will then be determined whether an actual conflict exists.\

FAIR DEALING
All AE Techron employees must deal fairly and in good faith with AE Techron’s customers, suppliers, competitors, and others. AE Techron representatives may not take unfair advantage of a business relationship through illegal conduct, deceit or any other unfair practice. Members of the AE Techron organization are required to comply with all applicable laws protecting fair competition. AE Techron employees shall not enter any agreement, written or implied, with a competitor about pricing, costs, terms, markets, production, customers or any other matter that could impact competition. Employees shall not exchange information about prices or production with a competitor. Any agreement with a competitor must be approved by the Law Department.

PROTECTION OF CONFIDENTIAL AND PROPRIETARY INFORMATION
AE Techron employees have a duty to safeguard AE Techron’s property, including proprietary and confidential information. Proprietary and confidential information that must be protected includes without limitation technical information, information about products, operations, personnel, marketing plans, production plans, customer and supplier data, pricing information, trade secrets and other information AE Techron uses to conduct its business. This information must not be disclosed to third parties without prior authorization and must not be used for personal gain. The obligation to protect this information continues after employment with AE Techron ends.

ELECTRONIC COMMUNICATION AND COMMUNICATION EQUIPMENT
AE Techron’s telephones, cellular devices, computers and other communication equipment should be used primarily to conduct company business. AE Techron allows reasonable and limited personal use of AE Techron electronic resources by employees. Employee personal use is a privilege and must not unduly burden AE Techron’s resources and systems. Personal use must also comply with all laws and AE Techron policies, and not interfere with normal business activities or the employee’s ability to meet job expectations. Email, voicemail and other forms of communications stored on AE Techron’s equipment are considered records of AE Techron and may be retrieved and disclosed by AE Techron as necessary and appropriate for business and legal purposes. Employees should not have an expectation of privacy in connection with personal items or information stored on equipment owned by AE Techron.

RECORD CREATION AND RETENTION
AE Techron’s books, records, and reports must be complete and accurate. Non-compliance with this policy must be immediately reported. AE Techron’s records must be retained, discarded or destroyed only in accordance with applicable laws, regulations and AE Techron’s policies and procedures.

Reporting Concerns and Asking Questions:
Contact:
AE Techron
574-295-9495

Anti-Slavery and Human Rights Policy

POLICY STATEMENT
Modern slavery is a crime resulting in an morally abhorrent exploitation of the human rights of vulnerable workers. It can take various forms, such as slavery, servitude, forced or compulsory labor and human rights abuse.

AE Techron is committed to respecting the rights and dignity of all people. AE Techron has a zero tolerance approach to human rights abuses and modern slavery. We are committed to acting ethically and with integrity and transparency in all of our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure that modern slavery and human rights abuse are not taking place anywhere within either our own business or in any of its supply chains, consistent with its obligations under the Modern Slavery Act 2015. AE Techron also expects the same high standards from all of its suppliers, contractors and other business partners and, as part of its contracting processes, it includes specific prohibitions against the use of modern slavery, and expects that its suppliers will in turn hold their own suppliers to the same standards.

This policy applies to all individuals working for AE Techron or on AE Techron’s behalf in any capacity, including employees, directors, officers, agency workers, volunteers, agents, contractors, consultants and business partners.

RESPONSIBILITY FOR THE POLICY
The management has overall responsibility for ensuring that this policy complies with AE Techron’s legal and ethical obligations. The General Manager has day-to-day responsibility for implementing this policy, monitoring its use and effectiveness and auditing internal control systems and policies and procedures to ensure they are effective in preventing or remediating the risk of modern slavery. They are also responsible for investigating allegations of modern slavery in AE Techron’s business or supply chains.

COMPLIANCE
The prevention, detection and reporting of modern slavery in any part of AE Techron’s business or supply chains, is the responsibility of all those working for AE Techron or under the Company’s control. You are required to avoid any activity that might lead to a breach of this policy. If you believe or suspect a breach of or conflict with this policy has occurred or may occur, you must notify your line manager or supervisor or report it to Human Resources. You are encouraged to raise concerns about any issue or suspicion of modern slavery in any part of the Company’s business or supply chains as soon as possible.

If you are unsure about whether a particular act, the treatment of workers or their working conditions within any of AE Techron’s supply chains constitutes any of the various forms of modern slavery, please raise it with your line manager. You can also contact the government’s Modern Slavery Helpline 800 – 0121 – 7000 for further information and guidance on modern slavery. Furthermore, any questionable condition relating to the possible abuse of wages or hourly employees, harassment or sexual abuse, or any activity or condition demeaning to a human being should reported.

AE Techron encourages openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. AE Techron is committed to ensuring no one suffers any detrimental treatment or victimization as a result of reporting in good faith their suspicion that modern slavery is or may be taking place in any part of its business or in any of its supply chains.

BREACH OF THE POLICY
Any employee who breaches this policy will face disciplinary action, up to and including summary dismissal for gross misconduct.AE Techron may terminate its commercial relationship with suppliers, contractors and other business partners if they breach this policy and/or are found to have been involved in modern slavery or other human rights abuses. .

Anti-Bribery and Anti-Corruption Policy Statement

BACKGROUND
Our company is committed to maintaining the highest ethical standards and vigorously enforces the integrity of its business practices wherever it operates throughout the world. This policy is intended to both reflect the highest standards of ethical business conduct and reduce liability and reduce the risk of reputation damage.

POLICY
This Policy is applicable to every employee of AE Techron, including senior executive and financial officers. The company does not take part in acts of corruption, or pay bribes or receive kickbacks either directly or indirectly. The company prohibits its employees from engaging in acts of corruption, and from paying bribes or kickbacks to, or accepting bribes or kickbacks from, public officials and private individuals such as the personnel of companies with which the company does business.

It is the responsibility of all employees who are involved at any time in engaging the services of external consultants, suppliers, representatives or distributors to ensure that such individuals are made aware of the content of the company’s Anti-Bribery and Anti-Corruption policy at the outset of the relationship and on a regular basis thereafter.

If any employee encounters a requirement for a facilitation payment, or any solicitation for payment that appears irregular, or believe that such requests may be required or immanent, this must be reported to management immediately.

Company employees may not offer to, or accept from, third parties, gifts, hospitality, rewards, benefits or other incentives that could affect either party’s impartiality, influence a business decision or lead to the improper performance of an official duty, or offer any incentive to unfair advantage. Similarly, they may not offer or accept cash donations.

Company employees must avoid situations or transactions in which their personal interests could conflict or might be seen to be in conflict with the interests of the company.

This Policy does not prohibit normal and appropriate gifts, hospitality, entertainment and promotional or other similar business expenditure, such as calendars, diaries, pens, meals and invitations to theatre and sporting events (given and received), for example, to or from Third Parties. Such normal or appropriate gifts are not considered inducements to unfair advantage or bribery.

Restriction of Hazardous Substances Directive

The Restriction of Hazardous Substances in Electrical and Electronic Equipment (RoHS) Directive (2011/65/EU).

AE Techron, Inc. announces that effective June 2011 all of their products listed below are RoHS compliant, and those products listed that are available for export are lead-free and RoHS compliant.

AE Techron is committed to eliminating the use of hazardous substances in the materials, manufacturing and packaging of our amplifier and other test and measurement products in strict accordance with the RoHS directive.

AE Techron RoHS Compliant products:

3110 Standards Waveform Generator
7000 Series Amplifiers (7224, 7548, 7794, 7796)
2100 Series (2105, 2110, 2120)
RLY Series (7212, 7224RLY, 7548RLY, 7796RLY)
T-Series Transformers (T1000, T2000, T3700)
4301 Telcom Test System
Product Accessories, including SIM modules, DB9M cable, Ballast Resistor Kits, Parallel Wiring Kits, BNC Parallel Input Kit, MTL1 MRI Test Load, GCL Ground Current Limiter, and VMON20 Voltage and Current Monitor

AE Techron, Inc. is assuring that all of its products listed above do not contain, or contain within acceptable limits, any material outlined in the RoHS directive. Each individual component of the amplifier and other test and measurement products has been carefully examined. Circuit boards, electronic and mechanical components, powder coats, paints, and manufacturing processes have been examined for RoHS compliancy and updated where necessary.

April 3, 2017

Larry Shank
President

Certificate of Restriction of Hazardous Substances 3 Compliance

This is to certify that all products and components listed below are RoHS 3 compliant, meet the requirements of the RoHS-3 Directive 2015/863/EU directive, and do not contain the substances listed in the table below in concentrations exceeding the Maximum Concentration Value (MCV).

Our suppliers have demonstrated compliance to the material restrictions of RoHS 3 by providing written and/or website accessible declarations for all parts and materials used to manufacture these AE Techron products.

Substances	Maximum Threshold Limit
Cadmium (Cd)	<100 PPM
Lead (Pb)	<1000 PPM
Mercury (Hg)	<100 PPM
Hexavalent Chromium (Cr6+)	<1000 PPM
Polybrominated Biphenyls (PBB)	<1000 PPM
Polybrominated Diphenyl Ethers (PBDE)	<1000 PPM
Bis (2-Ethylhexyl) Phthalate (DEHP)	<1000 PPM
Butyl Benzyl Phthalate (BBP)	<1000 PPM
Dibutyl Phthalate (DBP)	<1000 PPM
Diisobutyl Phthalate (DIBP)	<1000 PPM

AE Techron is committed to eliminating the use of hazardous substances in the materials, components, manufacturing, and packaging of our amplifiers and other test and measurement products in strict accordance with the RoHS 3 directive. Based on the information provided by our suppliers, and the best of our knowledge the listed products are RoHS 3 compliant and conform to the European Union Restrictions of the use of Hazardous Substances.

AE Techron Product/Model: