Code of Ethics & Business Conduct

Code of Ethics and Business Conduct

1. Introduction

This is code of ethics and business conduct of AHDP-Componentes Automotivos e Aeroportuários Unipessoal, Lda (AHDP) serves as our ethical commitment
and as a guide to proper business conduct for all of our stakeholders. We, at AHDP-Componentes Automotivos e Aeroportuários Unipessoal, Lda are committed to doing
business legally, ethically and in a transparent manner.

This document applies to all staff who work for the AHDP (including officers, directors, managers, team leaders,
employees, temporary, agency, interim, sub-contractor or consultant staff), and
also include other organisations who do business with us.

AHDP expects its staff to be impartial and honest in all affairs relating to
their job. All staff bears a responsibility in general, to be of good faith and
do nothing to destroy the trust necessary for employment.

The success of our business is based on the trust we earn from our
employees, customers and shareholders. We gain credibility by adhering to our
commitment to fairness and reaching our goals solely through ethical conduct.
All staff is expected to adhere to this Code in their professional, as well as
personal conduct, treat everyone with respect, honesty and fairness.

AHDP is open to any questions at any time and will not allow punishment or
retaliation against anyone for reporting a misconduct in good faith.

Managers and leaders have higher responsibility for demonstrating, also through
their actions, the importance of this Code. Managers and leaders are
responsible for promptly addressing every raised ethical question or concern.
Employees must cooperate in investigations of potential or alleged misconduct.

Non-compliance to this Code considered as a misconduct that could
warrant disciplinary action, including termination of employment or other
contract in deserving cases.

We are committed to making efforts to apply our values and norms also throughout
the entire value chain of our own suppliers, sub-contractors, service providers
and business partners.

   2. Ethical / Principles/Values

Our core values at AHDP are:

● Honesty

● Integrity

● Trustworthiness

● Respect for others

● Responsibility

● Accountability

● Reliability

● Obedience to the law

  3. Ethical Decision-making

Ethical conduct is a
value-driven decision-making. Several key questions
can help to identify situations that may be unethical, inappropriate or
illegal.

Ask yourself:

● Is what I am doing legal?

● Does it reflect our company values and ethics?

● Does it comply with the Code and company rules/policies?

● Does it respect the rights of others?

● How would it look if it made the news headlines?

● Am I being loyal to my family, my company and myself?

● Is this the right thing to do?

● What would I tell my child to do?

● Have I been asked to misrepresent information or deviate from normal
procedure?

    4. Compliance with laws and regulations

Our commitment to integrity begins with complying with laws, rules and
regulations. We understand and comply with the legal requirements and
commercial practices of lawful business.

We are committed to adhere to every valid and binding contractual agreement
that we conclude, and we do not abuse our rights.

Our staff must follow applicable laws and regulations, including the
Code at all times and must ensure compliant operation.

     5. Sustainability: People + Profit + Planet

We are committed to meet current requirements without compromising the
needs of future generations. To this, we combine economic, environmental and
social factors in our operation and our business decisions.

     6. Human rights

We are committed to respect human dignity and rights of each individual
and community whom we interact with during the course of work.  We shall not, in any way, cause or contribute
to the violation of human rights. Our staff shall treat everybody with dignity,
respect and care and uphold human rights.

     7. Fair labour practices and working conditions

We are committed to promote equality in our employment practices and to
fair employment and remuneration policy in compliance with applicable laws. We
are firmly opposed to employ or contract child or slave labour or any form of
forced or compulsory or bonded labour. We condemn all forms of illegal, unfair,
unethical labour practice that exploits workforce, destroys social security or
serves as tax evasion, including but not limited to undeclared and “grey” work
or holding back wages.

Our staff shall act with integrity and treat their colleagues and others
through the work with full respect.

     8. Discrimination and harassment

We provide equal opportunity in employment and we do not tolerate any
discrimination or harassment or any type from abuse. No direct or indirect
discrimination shall take place based on any professionally non-relevant trait
or circumstance, like gender, marital status, age, national or social or ethnic
origin, colour, religion and political opinion, disability, sexual orientation,
employee representation, property, birth or other status. Any kind of
discriminatory behaviour, harassment, bullying or victimization is prohibited.

All staff is expected to follow the highest standards of conduct in all
verbal and written communication based on mutual respect, and must refrain from
any form of harassment, slander or any behaviour that could be taken as
offensive, intimidating, humiliating, malicious or insulting.

      9. Health, Safety and Environment

We provide clean, safe and healthy work conditions and we are dedicated
to maintaining a healthy environment. We are committed to minimise the impact
on the natural environment of our operations. We make efforts to reduce the use
of finite resources, like energy or water, and the harmful emissions, like
waste.

   10. Fair competition and business conduct

Our relationships with business partners are built upon trust and mutual
benefits compliant with competition law. We are dedicated to ethical
and fair competition, as we sell products and services based on their 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, nor will we engage or assist in unlawful boycotts of particular
customers. We commit to comply with all applicable
trade controls, restrictions, sanctions and import-export embargos.

We do not allow any violence of the fairness of any tendering process in
any way. We refrain from damaging competition and the reputation of any
business partners and any behaviour that harms competitor’s creditability.

We do not hold back maliciously, unlawfully or unduly payments towards
our partners, and we do not allow such practices in our supply chain, we fight
the unethical practice of “debt chain”.

Our staff is responsible for ensuring fair business during their job and
adhere to every competition, consumer protection and fair marketing rule. Customers
and business partners shall be treated fairly and equally, products and
services shall be displayed in a manner that is fair and accurate (fair
marketingand advertising), and that discloses all relevant information.

   11. Anti-corruption

We firmly condemn and do not
tolerate all forms of corruption. It is prohibited directly or indirectly offering,
promising, giving, asking, soliciting or accepting any unfair advantage or
benefit, in order to obtain, retain or facilitate in any way the business. An
unfair advantage or benefit may include cash, any cash equivalent (e.g.
voucher), gift, credit, discount, travel, personal advantage, accommodation or
services. We do not permit facilitation (or “grease”) payments to government
officials or private business in order to secure or speed up routine actions. Corruption
also covers the misuse of function or position as well, when someone makes that
false appearance that s/he improperly influences a decision maker.

Corruption for either to
obtain or retain business, or to obtain or retain an advantage in the conduct
of business is considered gross misconduct. Similarly accepting or allowing
another person to accept a bribe is considered gross misconduct. Our staff’s has to account for all benefits received in the course of doing
business and must to not give or receive bribes or otherwise act corruptly.

   12. Gifts and Hospitality

We shall avoid any actions that create a perception that favourable
treatment was sought, received or given in exchange for personal benefits.

Business courtesies or benefits include gifts, gratuities, meals,
refreshments, entertainment or other advantage from persons or companies with
whom we do or may do business. We will neither give nor accept such benefits
that constitute, or could reasonably be perceived as constituting, unfair
business inducements that would violate law, regulation or polices, or would
cause embarrassment. Our staff may never use personal funds or resources to do
something that cannot be done with our resources.

We may accept and offer occasional gifts and hospitality that are
customary and conform to reasonable ethical practices of the market, provided
that they are not inappropriately excessive, not frequent and do not reflect a
pattern of frequent acceptance, does not create the appearance of an attempt to
influence business decisions. Only trivial gifts with low value can be
accepted. All other gifts must be politely refused or, if received through
post, returned to the donor. If return is not possible it shall be offered for
charity or community purposes. It is the responsibility of the person offering,
providing, receiving or accepting the gift to decide whether the gift is
appropriate.

   13. Security, protection and proper use of company assets

We are responsible for the security, protection and for the economic use
of company resources. Our resources, including time, material, equipment and
information are provided for legitimate business use only. Occasional personal
use is permissible as long as it is lawful, does not affect job performance or
disrupts workplace morale.

All staff is obliged to follow appropriate security measures and they
should treat company property, whether material or intangible, with respect and
shouldn’t misuse company assets or use it carelessly.

   14. Confidentiality, information security, proprietary information and intellectual property

We are committed to business information confidentiality, integrity and
accessibility, we implement proper technical security measures this and it is
our staff’s obligation to uphold this. Proprietary information includes all
non-public information that might be harmful to the company or its customers,
business partners if disclosed to unauthorised parties. All staff must handle
any such information as secret. It also covers that, no one is entitled to
trade with securities while in possession of non-public information or deliver
non-public information to others that could have impact on the securities.
Every rule ensuring information security must be followed all times.

We respect the property rights of others. We will not acquire or seek to
acquire trade secrets or other proprietary or confidential information by
improper means. We will not engage in unauthorized use, copying, distribution
or alteration of software or other protected intellectual property.

   15. Bookkeeping, true reporting and financial integrity

Our books, records, accounts and financial statements must be maintained
in appropriate detail, must truly and properly reflect our transactions. We
condemn all forms of money laundering, so we are committed to do business with
partners involved in legitimate business activities with funds derived from
legitimate sources.

We commit ourselves to fair taxation and to avoid all tax evasion practices,
including such as failing to issue receipt or accounting fake expense invoices.

All staff must follow accounting procedures, ensure that business
transactions are recorded and documented appropriately and make certain that
all disclosures made in financial reports are full, honest, accurate, timely
and understandable. All staff must not improperly influence, manipulate or
mislead any audit.

   16. Anti-Fraud

Fraud – the act or intent to cheat, steal, deceive or lie – is both unethical
and, in most cases, criminal. Fraud in every form, (including e.g. submitting
false expense reports; forging or altering financial documents or
certifications; misappropriating assets or misusing company property; making
any untrue financial or non-financial entry on records or statements) is
prohibited.

   17. Conflict of Interests

Our decisions shall be based on objective and fair assessments avoiding
the possibility of any improper influence. A “conflict of interest”
exists when an employee’s personal interest (that can be linked to e.g. friends,
family, or customer, competitor, supplier, contractor entity, as well)
interferes or potentially interferes with the best interests of AHDP Determining whether a conflict of interest exists is not always easy to
do, thus anyone with a conflict of interest question should seek advice from
management.

Conflicts of interest could arise:

·       Being employed (you
or a close family member) by, or being in economic relation with an actual or
potential customer, competitor, supplier or contractor.

·       Hiring or supervising
family members or closely related persons.

·       Serving as a board
member for another company or organization.

·       Owning or having a
substantial interest in a customer, competitor, supplier or contractor.

·       Having a personal
interest, financial interest or potential personal gain in any company
transaction.

If co-workers become involved in personal relations with each other, the
onus is on the senior employee concerned to bring this to the attention of his
or her manager to confirm that there is no conflict of interest, nor will a
conflict of interest arise.

   18. Privacy, personal data protection

We respect people’s privacy and we acknowledge customers, employees and
other natural persons’ need to feel confident that their personal data is
processed appropriately and for a legitimate business purpose. We are committed
to comply with all personal data protection laws. We only acquire and keep
personal information that is necessary and we give proper information on these
activities to data owners. We implement proper security measures to assure
confidentiality, integrity and availability of personal information.

Our staff must observe the legal requirements, apply compliant practices
and follow related procedures to ensure legality of personal data handling and
processing activities.

   Adriano Pedrosa / CEO/Founder/Owner