Aero Turbine, Incorporated complies with “The California Transparency in Supply Chains Act” per SB 657 Home Page | State of California – Department of Justice – Office of the Attorney General.

Code of Ethics and Business Conduct

Statement of Our Core Values 


Company Vision 

Our vision has its foundation in our aspirational goals, leadership attributes and associate engagement. Together they guide every aspect of our business—from the people we hire our high-performance culture and services we deliver to our business partners and customers.



Our Core Values are centered on People, Purpose and Process: 

We empower our associates: 

  • Exceptional people thrive in Aero Turbine Inc.’s fast-paced, high-performance culture and our values start with our people. 
  • We value our associates and their unique contributions, and we invest in their growth. 
  • We’re passionate about recruiting; developing and retaining the most talented and diverse team possible. 


Our number one Purpose is to value our Customers by: 

  • Being a listening organization. Our customers talk, we listen. 
  • Delight our customers by understanding their challenges and delivering real solutions, proactively 
  • Through our processes and our services, we seek to deliver greater value every day and to improve our customers’ experience beyond their expectations. 


Our Processes are committed to continuous improvement: 

  • Our high-performance culture is based upon our commitment to Lean 
  • Our Delivery and Quality is best in class. 



“To provide the highest quality standard of MRO and consultative services within the U.S. and Internationality to achieve the highest level of customer satisfaction” Douglas R. Clayton, President 


Build Trust and Credibility 

The success of our business is dependent on the trust and confidence we earn from our associates, customers and shareholders. We gain credibility by adhering to our commitments, displaying honesty and integrity and reaching company goals solely through honorable conduct. It is easy to say what we must do, but the proof is in our actions. Ultimately, we will be judged on what we do. 


When considering any action, it is wise to ask: will this build trust and credibility for Aero Turbine Inc.? Will it help create a working environment in which Aero Turbine Inc. can succeed over the long term? Is the commitment I am making one I can follow through with? The only way we will maximize trust and credibility is by answering “yes” to those questions and by working every day to build our trust and credibility. 


Respect for the Individual 

We all deserve to work in an environment where we are treated with dignity and respect. Aero Turbine Inc. is committed to creating such an environment because it brings out the full potential in each of us, which, in turn, contributes directly to our business success. We cannot afford to let anyone’s talents go to waste. 


Aero Turbine Inc. is an equal employment/affirmative action employer and is committed to providing a workplace that is free of discrimination of all types from abusive, offensive or harassing behavior. Any associate who feels harassed or discriminated against should report the incident to his or her manager or to human resources.


Create a Culture of Open and Honest Communication 

At Aero Turbine Inc. everyone should feel comfortable to speak his or her mind, particularly with respect to ethics concerns. Managers have a responsibility to create an open and supportive environment where associates feel comfortable raising such questions. We all benefit tremendously when associates exercise their power to prevent mistakes or wrongdoing by asking the right questions at the right times. 


Aero Turbine Inc. will investigate all reported instances of questionable or unethical behavior. In every instance where improper behavior is found to have occurred, the company will take appropriate action. We will not tolerate retaliation against associates who raise genuine ethics concerns in good faith. 


For your information, Aero Turbine Inc.’s whistleblower policy is as follows: 

Associates are encouraged, in the first instance, to address such issues with their managers or the HR manager, as most problems can be resolved swiftly. If for any reason that is not possible or if an associate is not comfortable raising the issue with his or her manager or HR, Aero Turbine Inc.’s Chief Executive Officer does operate with an open-door policy. 


Set Tone at the Top 

Management has the added responsibility for demonstrating, through their actions, the importance of this Code. In any business, ethical behavior does not simply happen; it is the product of clear and direct communication of behavioral expectations, modeled from the top and demonstrated by example. Again, ultimately, our actions are what matters. 


To make our Code work, managers must be responsible for promptly addressing ethical questions or concerns raised by associates and for taking the appropriate steps to deal with such issues. Managers should not consider associates’ ethics concerns as threats or challenges to their authority, but rather as another encouraged form of business communication. At Aero Turbine Inc., we want the ethics dialogue to become a natural part of daily work. 


Uphold the Law 

Aero Turbine Inc.’s commitment to integrity begins with complying with laws, rules and regulations where we do business. Further, each of us must understand the company policies, laws, rules and regulations that apply to our specific roles. If we are unsure of whether a contemplated action is permitted by law or Aero Turbine Inc. policy, we should seek the advice from the resource expert. We are responsible for preventing violations of law and for speaking up if we see possible violations. 



We are dedicated to ethical, fair and vigorous competition. We will sell Aero Turbine Inc. products and services based on their merit, superior quality, functionality and competitive pricing. We will make independent pricing and marketing decisions and will not improperly cooperate or coordinate our activities with our competitors. We will not offer or solicit improper payments or gratuities in connection with the purchase of goods or services for Aero Turbine Inc. or the sales of its products or services, nor will we engage or assist in unlawful boycotts of particular customers. 


Proprietary Information 

It is important that we respect the property rights of others. We will not acquire or seek to acquire improper means of a competitor’s trade secrets or other proprietary or confidential information. We will not engage in unauthorized use, copying, distribution or alteration of software or other intellectual property. 


Selective Disclosure 

We will not selectively disclose (whether in one-on-one or small discussions, meetings, presentations, proposals or otherwise) any material nonpublic information with respect to Aero Turbine Inc., its securities, business operations, plans, financial condition, results of operations or any development plan. We should be particularly vigilant when making presentations or proposals to customers to ensure that our presentations do not contain material nonpublic information. 


Health and Safety 

Aero Turbine Inc. is dedicated to maintaining a healthy environment. A safety manual has been designed to educate you on safety in the workplace. If you do not have a copy of this manual, please see the HR department. 


Avoid Conflicts of Interest 


Conflicts of Interest 

We must avoid any relationship or activity that might impair, or even appear to impair, our ability to make objective and fair decisions when performing our jobs. At times, we may be faced with situations where the business actions we take on behalf of Aero Turbine Inc. may conflict with our own personal or family interests. We owe a duty to Aero Turbine Inc. to advance its legitimate interests when the opportunity to do so arises. We must never use Aero Turbine Inc. property or information for personal gain or personally take for ourselves any opportunity that is discovered through our position with Aero Turbine Inc. 


Here are some other ways in which conflicts of interest could arise: 

  1. Being employed (you or a close family member) by, or acting as a consultant to, a competitor or potential competitor, supplier or contractor, regardless of the nature of the employment, while you are employed with Aero Turbine Inc. 
  2. Hiring or supervising family members or closely related persons. 
  3. Serving as a board member for an outside commercial company or organization. 
  4. Owning or having a substantial interest in a competitor, supplier or contractor. 
  5. Having a personal interest, financial interest or potential gain in any Aero Turbine Inc. transaction. 
  6. Placing company business with a firm owned or controlled by an Aero Turbine Inc. associate or his or her family. 
  7. Accepting gifts, discounts, favors or services from a customer/potential customer, competitor or supplier, unless equally available to all Aero Turbine Inc. associates. 


Determining whether a conflict of interest exists is not always easy to do. Associates with a conflict of interest question should seek advice from management. Before engaging in any activity, transaction or relationship that might give rise to a conflict of interest, associates must seek review from their managers or the HR department. 


Gifts, Gratuities and Business Courtesies 

Aero Turbine Inc. is committed to competing solely on the merit of our products and services. We should avoid any actions that create a perception that favorable treatment of outside entities by Aero Turbine Inc. was sought, received or given in exchange for personal business courtesies. Business courtesies include gifts, gratuities, meals, refreshments, entertainment or other benefits from persons or companies with whom Aero Turbine Inc. does or may do business. We will neither give nor accept business courtesies that constitute, or could reasonably be perceived as constituting, unfair business inducements that would violate law, regulation or polices of Aero Turbine Inc. or customers, or would cause embarrassment or reflect negatively on Aero Turbine Inc.’s reputation. 


Accepting Business Courtesies 

Most business courtesies offered to us in the course of our employment are offered because of our positions at Aero Turbine Inc. We should not feel any entitlement to accept and keep a business courtesy. Although we may not use our position at Aero Turbine Inc. to obtain business courtesies, and we must never ask for them, we may accept unsolicited business courtesies that promote successful working relationships and good will with the firms that Aero Turbine Inc. maintains or may establish a business relationship with. 


Associates who award contracts or who can influence the allocation of business, who create specifications that result in the placement of business or who participate in negotiation of contracts must be particularly careful to avoid actions that create the appearance of favoritism or that may adversely affect the company’s reputation for impartiality and fair dealing. The prudent course is to refuse a courtesy from a supplier when Aero Turbine Inc. is involved in choosing or reconfirming a supplier or under circumstances that would create an impression that offering courtesies is the way to obtain Aero Turbine Inc. business. 


Meals, Refreshments and Entertainment 

We may accept occasional meals, refreshments, entertainment and similar business courtesies that are shared with the person who has offered to pay for the meal or entertainment, provided that: 

  • They are not inappropriately lavish or excessive. 
  • The courtesies are not frequent and do not reflect a pattern of frequent acceptance of courtesies from the same person or entity. 
  • The courtesy does not create the appearance of an attempt to influence business decisions, such as accepting courtesies or entertainment from a supplier whose contract is expiring in the near future. 
  • The associate accepting the business courtesy would not feel uncomfortable discussing the courtesy with his or her manager or co-worker or having the courtesies known by the public. 



Associates may accept unsolicited gifts, other than money, that conform to the reasonable ethical practices of the marketplace, including: 

  • Flowers, fruit baskets and other modest presents that commemorate a special occasion.
  • Gifts of nominal value, such as calendars, pens, mugs, caps and t-shirts (or other novelty, advertising or promotional items). 


Generally, associates may not accept compensation, honoraria or money of any amount from entities with whom Aero Turbine Inc. does or may do business. Tangible gifts (including tickets to a sporting or entertainment event) that have a market value greater than $100 may not be accepted unless approval is obtained from management. Associates with questions about accepting business courtesies should talk to their managers or the HR department. 


Offering Business Courtesies 

Any associate who offers a business courtesy must assure that it cannot reasonably be interpreted as an attempt to gain an unfair business advantage or otherwise reflect negatively upon Aero Turbine Inc. An associate may never use personal funds or resources to do something that cannot be done with Aero Turbine Inc. resources. Accounting for business courtesies must be done in accordance with approved company procedures. 


Other than to our government customers, for whom special rules apply, we may provide nonmonetary gifts (i.e., company logo apparel or similar promotional items) to our customers. Further, management may approve other courtesies, including meals, refreshments or entertainment of reasonable value provided that: 

  • The practice does not violate any law or regulation or the standards of conduct of the recipient’s organization. 
  • The business courtesy is consistent with industry practice, is infrequent in nature and is not lavish. 
  • The business courtesy is properly reflected on the books and records of [Company Name]. 


Set Metrics and Report Results Accurately 


Accurate Public Disclosures 

We will make certain that all disclosures made in financial reports and public documents are full, fair, accurate, timely and understandable. This obligation applies to all associates, including all financial executives, with any responsibility for the preparation for such reports, including drafting, reviewing and signing or certifying the information contained therein. No business goal of any kind is ever an excuse for misrepresenting facts or falsifying records. 


Associates should inform Executive Management and the HR department if they learn that information in any filing or public communication was untrue or misleading at the time it was made or if subsequent information would affect a similar future filing or public communication.


Corporate Recordkeeping 

We create, retain and dispose of our company records as part of our normal course of business in compliance with all Aero Turbine Inc. policies and guidelines, as well as all regulatory and legal requirements. All corporate records must be true, accurate and complete, and company data must be promptly and accurately entered in our books in accordance with Aero Turbine Inc.’s and other applicable accounting principles. We must not improperly influence, manipulate or mislead any unauthorized audit, nor interfere with any auditor engaged to perform an internal independent audit of Aero Turbine Inc. books, records, processes or internal controls. 


Promote Substance over Form 

At times, we are all faced with decisions we would rather not have to make and issues we would prefer to avoid. Sometimes, we hope that if we avoid confronting a problem, it will simply go away. 


At Aero Turbine Inc., we must have the courage to tackle the tough decisions and make difficult choices, secure in the knowledge that Aero Turbine Inc. is committed to doing the right thing. At times this will mean doing more than simply what the law requires. Merely because we can pursue a course of action does not mean we should do so. Although Aero Turbine Inc.’s guiding principles cannot address every issue or provide answers to every dilemma, they can define the spirit in which we intend to do business and should guide us in our daily conduct. 



Each of us is responsible for knowing and adhering to the values and standards set forth in this Code and for raising questions if we are uncertain about company policy. If we are concerned whether the standards are being met or are aware of violations of the Code, we must contact the HR department. 


Aero Turbine Inc. takes seriously the standards set forth in the Code, and violations are cause for disciplinary action up to and including termination of employment. 


Be Loyal 


Confidential and Proprietary Information 

Integral to Aero Turbine Inc.’s business success is our protection of confidential company information, as well as nonpublic information entrusted to us by associates, customers and other business partners. Confidential and proprietary information includes such things as pricing and financial data, customer names/addresses or nonpublic information about other companies, including current or potential supplier and vendors. We will not disclose confidential and nonpublic information without a valid business purpose and proper authorization. 


Use of Company Resources 

Company resources, including time, material, equipment and information, are provided for company business use. Nonetheless, occasional personal use is permissible as long as it does not affect job performance or cause a disruption to the workplace. 


Associates and those who represent Aero Turbine Inc. are trusted to behave responsibly and use good judgment to conserve company resources. Managers are responsible for the resources assigned to their departments and are empowered to resolve issues concerning their proper use. 


Generally, we will not use company equipment such as computers, copiers and fax machines in the conduct of an outside business or in support of any religious, political or other outside daily activity, except for company-requested support to nonprofit organizations. We will not solicit contributions nor distribute non-work-related materials during work hours.


In order to protect the interests of the Aero Turbine Inc. network and our fellow associates, Aero Turbine Inc. reserves the right to monitor or review all data and information contained on an associate’s company-issued computer or electronic device, the use of the Internet or Aero Turbine Inc.’s intranet. We will not tolerate the use of company resources to create, access, store, print, solicit or send any materials that are harassing, threatening, abusive, sexually explicit or otherwise offensive or inappropriate. 


Questions about the proper use of company resources should be directed to your manager. 


Media Inquiries 

Aero Turbine Inc. is a high-profile company in our community, and from time to time, associates may be approached by reporters and other members of the media. In order to ensure that we speak with one voice and provide accurate information about the company, we should direct all media inquiries to the Chief Executive Officer. No one may issue a press release without first consulting with the Chief Executive Officer. 


Do the Right Thing 

Several key questions can help identify situations that may be unethical, inappropriate or illegal. Ask yourself: 

  • Does what I am doing comply with the Aero Turbine Inc. guiding principles, Code of Conduct and company policies? 
  • Have I been asked to misrepresent information or deviate from normal procedure? 
  • Would I feel comfortable describing my decision at a staff meeting? 
  • How would it look if it made the headlines? 
  • Am I being loyal to my family, my company and myself? 
  • What would I tell my child to do? 
  • Is this the right thing to do? 


Workplace Bullying 



The purpose of this policy is to communicate to all associates, including supervisors, managers and executives, that Aero Turbine, Inc. will not in any instance tolerate bullying behavior. Associates found in violation of this policy will be disciplined, up to and including termination. 



Aero Turbine, Inc. defines bullying as repeated, health-harming mistreatment of one or more people by one or more perpetrators. It is abusive conduct that includes: 

  • Threatening, humiliating or intimidating behaviors. 
  • Work interference/sabotage that prevents work from getting done. 
  • Verbal abuse. 


Such behavior violates Aero Turbine, Inc.’s Code of Ethics, which clearly states that all associates will be treated with dignity and respect. 



Aero Turbine, Inc. considers the following types of behavior examples of bullying: 

  • Verbal bullying. Slandering, ridiculing or maligning a person or his or her family; persistent name-calling that is hurtful, insulting or humiliating; using a person as the butt of jokes; abusive and offensive remarks.
  • Physical bullying. Pushing, shoving, kicking, poking, tripping, assault or threat of physical assault, damage to a person’s work area or property. 
  • Gesture bullying. Nonverbal gestures that can convey threatening messages. 
  • Exclusion. Socially or physically excluding or disregarding a person in work-related activities. 


In addition, the following examples may constitute or contribute to evidence of bullying in the workplace: 

  • Persistent singling out of one person. 
  • Shouting or raising one’s voice at an individual in public or in private. 
  • Using obscene or intimidating gestures. 
  • Not allowing the person to speak or express himself of herself (i.e., ignoring or interrupting). 
  • Personal insults and use of offensive nicknames. 
  • Public humiliation in any form. 
  • Constant criticism on matters unrelated or minimally related to the person’s job performance or description. 
  • Public reprimands. 
  • Repeatedly accusing someone of errors that cannot be documented. 
  • Deliberately interfering with mail and other communications. 
  • Spreading rumors and gossip regarding individuals. 
  • Encouraging others to disregard a supervisor’s instructions. 
  • Manipulating the ability of someone to do his or her work (e.g., overloading, underloading, withholding information, setting deadlines that cannot be met, giving deliberately ambiguous instructions). 
  • Assigning menial tasks not in keeping with the normal responsibilities of the job. 
  • Taking credit for another person’s ideas. 
  • Refusing reasonable requests for leave in the absence of work-related reasons not to grant leave. 
  • Deliberately excluding an individual or isolating him or her from work-related activities, such as meetings. 
  • Unwanted physical contact, physical abuse or threats of abuse to an individual or an individual’s property (defacing or marking up property). 


All associates are strongly encouraged to report any bullying conduct they experience or witness as soon as possible to Aero Turbine, Inc. or website or 844-707-1203 Hotline 24/7 before the conduct becomes severe or pervasive, and to take appropriate action. Your complaint will be kept anonymous and confidential. 


Harassment Discrimination and Retaliation Prevention 


Aero Turbine, Inc. is an equal opportunity employer. Aero Turbine, Inc. is committed to providing a work environment free of harassment, discrimination, retaliation, and disrespectful or other unprofessional conduct based on: 

  • Race 
  • Religion (including religious dress and grooming practices) 
  • Color 
  • Sex/gender (including pregnancy, childbirth, breastfeeding or related medical conditions), sex stereotype, gender identity/gender expression/transgender (including whether or not you are transitioning or have transitioned) and sexual orientation
  • National origin (including language use restrictions and possession of a driver’s license issued to persons unable to prove their presence in the United States is authorized under federal law [VehicleCode section 12801.9]) 
  • Ancestry 
  • Physical or mental disability 
  • Medical condition 
  • Genetic information/characteristics 
  • Marital status/registered domestic partner status 
  • Age (40 and over) 
  • Sexual orientation 
  • Military or veteran status 
  • Any other basis protected by federal, state or local law or ordinance or regulation 


Aero Turbine, Inc. also prohibits discrimination, harassment, disrespectful or unprofessional conduct based on the perception that anyone has any of those characteristics or is associated with a person who has or is perceived as having any of those characteristics. 


In addition, the Company prohibits retaliation against individuals who raise complaints of discrimination or harassment or who participate in workplace investigations. 


All such conduct violates Company policy. 


Harassment Prevention 


The Company’s policy prohibiting harassment applies to all persons involved in the operation of the Company. The Company prohibits harassment, disrespectful or unprofessional conduct by any Associate of the Company, including supervisors, managers and co-workers. The Company’s anti-harassment policy also applies to vendors, customers, independent contractors, unpaid interns, volunteers, persons providing services pursuant to a contract and other persons with whom you come into contact while working. 


Prohibited harassment, disrespectful or unprofessional conduct includes, but is not limited to, the following behavior: 

  • Verbal conduct such as epithets, derogatory jokes or comments, slurs or unwanted sexual advances, invitations, comments, posts or messages; 
  • Visual displays such as derogatory and/or sexually oriented posters, photography, cartoons, drawings or gestures; 
  • Physical conduct including assault, unwanted touching, intentionally blocking normal movement or interfering with work because of sex, race or any other protected basis; 
  • Threats and demands to submit to sexual requests or sexual advances as a condition of continued employment, or to avoid some other loss and offers of employment benefits in return for sexual favors; 
  • Retaliation for reporting or threatening to report harassment; and 
  • Communication via electronic media of any type that includes any conduct that is prohibited by state and/or federal law or by company policy. 


Sexual harassment does not need to be motivated by sexual desire to be unlawful or to violate this policy. For example, hostile acts toward an Associate because of his/her gender can amount to sexual harassment, regardless of whether the treatment is motivated by sexual desire. 


Prohibited harassment is not just sexual harassment, but harassment based on any protected category. 




The Company is committed to compliance with all applicable laws providing equal employment opportunities. This commitment applies to all persons involved in Company operations. The Company prohibits unlawful discrimination against any job applicant, Associate or unpaid intern by any Associate of the Company, including supervisors and coworkers. 


Pay discrimination between Associates of the opposite sex or between Associates of another race or ethnicity performing substantially similar work, as defined by the California Fair Pay Act and federal law, is prohibited. Pay differentials may be valid in certain situations defined by law. Associates will not be retaliated against for inquiring about or discussing wages. However, Aero Turbine, Inc. is not obligated to disclose the wages of other Associates. 




The Company will not retaliate against you for filing a complaint or participating in any workplace investigation or complaint process, and will not tolerate or permit retaliation by management, Associates or co-workers. 


Reasonable Accommodation 


Discrimination can also include failing to reasonably accommodate religious practices or qualified individuals with disabilities where the accommodation does not pose an undue hardship. 


To comply with applicable laws ensuring equal employment opportunities to qualified individuals with a disability, the Company will make reasonable accommodations for the known physical or mental limitations of an otherwise qualified individual with a disability who is an applicant or an Associate unless undue hardship would result. 


Any job applicant or Associate who requires an accommodation in order to perform the essential functions of the job should contact a Company representative with day-to-day personnel responsibilities and discuss the need for an accommodation. The Company will engage in an interactive process with the Associate to identify possible accommodations, if any, that will help the applicant or Associate perform the job. An applicant, Associate or unpaid intern who requires an accommodation of a religious belief or practice (including religious dress and grooming practices, such as religious clothing or hairstyles) should also contact a Company representative with day-to-day personnel responsibilities and discuss the need for an accommodation. If the accommodation is reasonable and will not impose an undue hardship, the Company will make the accommodation. 


The Company will not retaliate against you for requesting a reasonable accommodation and will not knowingly tolerate or permit retaliation by management, Associates or co-workers.


Complaint Process 


If you believe that you have been the subject of harassment, discrimination, retaliation or other prohibited conduct, bring your complaint to your supervisor or to: 

  • Any other Company supervisor 
  • The HR Manager, the office manager 
  • The president 
  • The vice-president 
  • To a complaint hotline at (800) 884-1684 DFEH 


as soon as possible after the incident. You can bring your complaint to any of these individuals. If you need assistance with your complaint, or if you prefer to make a complaint in person, contact the HR Manager or Sr. Management. Please provide all known details of the incident or incidents, names of individuals involved and names of any witnesses. It would be best to communicate your complaint in writing, but this is not mandatory. 


The Company encourages all individuals to report any incidents of harassment, discrimination, retaliation or other prohibited conduct forbidden by this policy immediately so that complaints can be quickly and fairly resolved. 


You also should be aware that the Federal Equal Employment Opportunity Commission and the California Department of Fair Employment and Housing investigate and prosecute complaints of prohibited harassment, discrimination and retaliation in employment. If you think you have been harassed or discriminated against or that you have been retaliated against for resisting, complaining or participating in an investigation, you may file a complaint with the appropriate agency. The nearest office can be found by visiting the agency websites at  and


Supervisors must refer all complaints involving harassment, discrimination, retaliation or other prohibited conduct to the HR Manager or Sr. Management of the Company so the Company can try to resolve the complaint. 


When the Company receives allegations of misconduct, it will immediately undertake a fair, timely, thorough and objective investigation of the allegations in accordance with all legal requirements. The Company will reach reasonable conclusions based on the evidence collected. 


The Company will maintain confidentiality to the extent possible. However, the Company cannot promise complete confidentiality. The employer’s duty to investigate and take corrective action may require the disclosure of information to individuals with a need to know. 


Complaints will be: 


  • Responded to in a timely manner 
  • Kept confidential to the extent possible 
  • Investigated impartially by qualified personnel in a timely manner 
  • Documented and tracked for reasonable progress
  • Given appropriate options for remedial action and resolution 
  • Closed in a timely manner 


If the Company determines that harassment, discrimination, retaliation or other prohibited conduct has occurred; appropriate and effective corrective and remedial action will be taken in accordance with the circumstances involved. The Company also will take appropriate action to deter future misconduct. 


Any Associate determined by the Company to be responsible for harassment, discrimination, retaliation or other prohibited conduct will be subject to appropriate disciplinary action, up to, and including termination. Associates should also know that if they engage in unlawful harassment, they can be held personally liable for the misconduct.