WASI Supplier Code of Conduct
As a worldwide supplier of aerospace and defense articles, Western Aero Services, Inc. (WASI) has a commitment to ensure that its business practices conform to all applicable laws, regulations and ethical business standards and principles, as well as to develop a culture of responsibility, integrity and sustainability.
WASI is committed to its core values in respect of human rights, labor and environmental practices, both within its organization and through its business relationships. In particular, WASI has a zero tolerance for all forms of corruption, modern slavery and child labor, whether public or private.
As a supplier to WASI you are an integral part of the WASI ecosystem and therefore a key contributor to one of its objectives to continuously improve the way supply chains are managed.
The WASI Supplier Code of Conduct is built on the model of the International Forum on Business Ethical Conduct, IFBEC and defines the basic requirements placed on WASI suppliers and third parties. It also represents WASI’s values and principles in line with internationally recognized standards and conventions.
WASI requires commitment to responsible business practices and sustainable development from all its suppliers. Wherever suppliers are located, all business shall be conducted in compliance with this Supplier Code of Conduct. Suppliers are also expected to cascade these principles through their own supply chain and go beyond legal compliance in order to advance in social and environmental responsibility and business ethics. Our joint commitment is a key element in securing our success, conformance to applicable laws and a sustainable future.
Compliance with Laws
Suppliers must comply with all laws and regulations applicable to their business, including the local laws and regulations of all countries outside their home country in which operations are managed or services are provided.
Human Rights
Suppliers are expected to conduct their business and operations in a way that respects human rights by treating their own workers, and those working for their suppliers, with dignity and promoting fair employment practices. This includes providing fair and competitive wages, prohibiting harassment, bullying and discrimination, prohibiting use of child, forced, bonded or indentured labor or prison labor and not engaging in trafficking of persons for any purpose.
Suppliers are expected to identify risks and actual adverse human rights impacts related to their activities and through their business relationships. They should take appropriate steps to reduce risk and ensure their operations do not cause or contribute to human rights abuses and to remedy any adverse impacts directly caused, or contributed to, by their activities or through business relationships.
Child labor
Suppliers must ensure that child labor is not used in the performance of work. The term “child” refers to any person under the minimum legal age for employment where the work is performed, and/or the minimum working age defined by the International Labor Organization (ILO), whichever is higher.
All workers under the age of 18 must be protected from performing work that is likely to be hazardous or that may be harmful to their health, physical, mental, social, spiritual, or moral development.
Modern slavery including human trafficking, forced, bonded or indentured labor
Suppliers must prevent any involvement in all forms of modern slavery, including human trafficking, forced, bonded or indentured labor.
All work should be voluntary on the part of the employee.
Suppliers are expected to provide all employees with a written contract in a language they understand clearly, indicating their rights and responsibilities with regard to wages, working hours, benefits and other working and employment conditions.
Suppliers should not retain any form of employee identification (passports or work permits), nor destroy or deny access to such documentation, as a condition of employment unless required by applicable law.
Suppliers must not charge employees fees, recruitment costs or deposits, directly or indirectly, as a precondition of work.
Suppliers must respect the right of workers to terminate their employment after reasonable notice and to receive all owed salary.
Suppliers must respect the right of workers to leave the workplace after their shift (see also Wages and Benefits, and Working hours).
Employment Practices
Harassment and bullying
Suppliers are expected to ensure that their employees are afforded an employment environment that is free from physical, psychological, sexual, and verbal harassment, intimidation or other abusive conduct.
Diversity and Inclusion
Suppliers are expected to foster a diverse and inclusive work environment where employees are treated with dignity, respect and fairness, regardless of their race, color, religion, gender, age, ethnic or national origin, disability, sexual orientation or preference, gender identity, marital status, citizenship status, political preference or other personal characteristics.
Suppliers are expected to provide equal employment opportunities to employees and applicants for employment without discrimination and comply with all non-discrimination laws and regulations.
Suppliers must ensure employment, including hiring, payment, benefits, advancement, termination and retirement, based on ability and not any personal characteristics.
Wages and Benefits
Suppliers must pay workers at least the minimum compensation required by local law and provide all legally mandated benefits. In addition to payment for regular hours of work, workers must be paid for overtime at such a premium rate as is legally required or, in those countries where such laws do not exist, at least equal to their regular hourly payment rate.
Suppliers must not permit deduction from wages as a disciplinary measure nor permit any other deductions which are not provided by national law.
Working hours
Suppliers are expected to operate in consideration of the International Labor Organization (ILO) standards regulating working, resting hours, maximum consecutive days of work and annual leave. Hours worked beyond the normal work week shall be voluntary and suppliers must provide a rest period of at least 24 consecutive hours in every seven day period to all their employees.
Social Dialogue and Freedom of Association
Suppliers are expected to respect the rights of workers to associate freely and communicate openly with management regarding working conditions without fear of harassment, intimidation, penalty, interference or reprisal.
Suppliers are expected to recognize and respect any rights of workers to exercise lawful rights of free association, including joining or not joining any association of their choosing within the appropriate national legal framework.
Disciplinary and Grievance Mechanism
Suppliers are expected to have an employee disciplinary process in place to address concerns regarding employee work, conduct or absence.
Suppliers are expected to have a grievance mechanism for employees to raise a workplace problem or concern or to appeal a disciplinary decision.
Migrant workers
The term “migrant worker” refers to a person who is to be engaged, is engaged or has been engaged in a remunerated activity in a State of which he or she is not a national. Suppliers must ensure that migrant workers are employed in full compliance with the immigration and labor laws of the host country.
Integrity & Business Ethics
Anti-Corruption Laws
Suppliers shall comply with all anti-corruption laws and regulations applicable to the performance of their obligations and activities in their relationship with WASI.
Suppliers are expected to put in place a compliance program tailored to the risks of their business and to conduct reasonable due diligence to prevent and detect corruption in all business arrangements, including purchasing contracts, partnerships, joint ventures, offset agreements, and the use of third parties such as agents or consultants.
Illegal Payments
Suppliers must not offer, promise, make, accept or agree to accept any improper payments of money or anything of value to government officials, political parties, candidates for public office, or other persons. This includes a prohibition on so called ‘facilitation’ or ‘grease’ payments intended to expedite or secure performance of a routine governmental action like obtaining a visa or customs clearance, unless there is a formal legal governmental fee schedule for such expediting services and the government provides receipts. Personal safety payments are permitted where there is an imminent threat to health or safety.
Suppliers must not offer any illegal payments to, or agree to receive any illegal payments from, any customer, supplier, their agents, representatives or others. We expect suppliers to prohibit their employees from receiving, paying, and/or promising sums of money or anything of value, directly or indirectly, intended to exert undue influence or improper advantage. This prohibition applies even in locations where such activity may not violate local law.
Fraud and deception
Suppliers must not seek to gain an advantage of any kind by acting fraudulently, deceiving people, making false claims or allowing anyone else representing them to do so. This includes defrauding or stealing and any kind of misappropriation of property or information.
Competition and antitrust
Suppliers must not enter into formal or informal anti-competitive arrangements that fix prices, collude, rig bids, limit supply or allocate/ control markets. They must not exchange current, recent, or future pricing information with competitors. Suppliers must not participate in a cartel or any activity that would unlawfully restrain or impact competition.
Gifts/business courtesies
Suppliers are expected to compete on the merits of their products and services. Suppliers must not use the exchange of business courtesies to gain an unfair competitive advantage. In any business relationship, suppliers must ensure that the offering or receipt of any gift or business courtesy is permitted by applicable laws and regulations, and that these exchanges do not violate the rules and standards of the recipient’s organization, and are consistent with reasonable marketplace customs and practices. No cash gifts or cash equivalent should be offered or accepted.
Insider trading
Suppliers and their personnel must not use any material or non-publicly disclosed information obtained in the course of their business relationship with WASI as the basis for trading or for enabling others to trade in the stock or securities of any company.
Conflict of interest
Suppliers are expected to avoid all conflicts of interest or situations giving the appearance of a conflict of interest. Suppliers will provide immediate notification to all affected parties in the event that an actual or potential conflict of interest arises. This includes a conflict between WASI and personal interests or those of close relatives, friends or associates.
Environment, Health & Safety
Environmental, health & safety management system
Suppliers are expected to conduct their business in a manner that actively manages environmental risks across their operations, products and supply chain.
Suppliers should take reasonable steps to provide a hygienic working environment and must ensure that employees’ performance and safety is not impaired by alcohol, controlled substances, legal and illegal drugs.
Substances and chemical management
Suppliers are expected to communicate to WASI up to date information in regards to environmental, health and safety (EHS) matters of their products to enable safe usage of the products in the whole life cycle.
Suppliers are further expected to cooperate with WASI to enable downstream requirements in relation to suppliers’ products and/or services to be fulfilled.
Sustainable product and process development
WASI suppliers shall actively support the sustainability strategy of WASI and make their best effort to develop, manufacture and deliver innovative products and processes that have the lowest possible environmental impact throughout the lifecycle.
Product Safety
Suppliers are expected, by their own organization and processes, to actively support the WASI Product Safety strategy and contribute to the continued airworthiness and safety regulations.
Safety engagement
Suppliers are expected to ensure that each of their employees is fully engaged and never forgets that lives of passengers, airlines personnel and fellow employees depend on their personal commitment for product safety.
Safety first
Suppliers are expected to ensure that the “Safety First” principle is fulfilled and promoted at all levels within their organizations and that each of their employees does their utmost to ensure that product safety is never compromised.
Alertness and sharing in the regulatory framework
Suppliers shall maintain continued airworthiness and safety and shall duly report potential safety issues to WASI as per applicable regulation.
Suppliers are expected to support Safety issue analysis in an acceptable time frame.
Suppliers shall support accident/incident investigation as per applicable regulations.
Safety enhancement
As per Safety Management System principles, Suppliers are expected to proactively report to WASI, based on their own judgement, all events which may potentially impact the product safety and/or the safety of the product operations.
Information Protection
Protecting sensitive, confidential and proprietary information
Suppliers are expected to ensure that all sensitive, confidential and proprietary information is appropriately protected.
In its relationship with WASI, Suppliers must comply with all applicable data privacy laws and regulations.
Suppliers must protect the sensitive, confidential and proprietary information of others, including personal data/information, from unauthorized access, destruction, use, modification and disclosure, through appropriate physical and electronic security procedures, including mitigating emerging risk to information systems by implementing appropriate IT cyber security programs.
Suppliers must report to WASI any suspected or actual data breach or security incident as soon as they are aware.
Intellectual property
Suppliers must comply with all the applicable laws governing intellectual property rights assertions, including protection against disclosure.
Global trade and export control
Import
Suppliers must ensure that their business practices are in accordance with all applicable laws, directives and regulations governing the import of parts, components, technical data and services.
Export
Suppliers must ensure that their business practices are in compliance with Export Control laws and regulations including the US, EU and any applicable national regulations, including compliance with Sanctions and Embargoes legislations. Suppliers shall provide truthful and accurate export control classification, information and obtain export control licenses or otherwise authorizations when required and must communicate any declarations where necessary.
Responsible sourcing of minerals
Suppliers must comply with applicable laws and regulations regarding direct and indirect sourcing of critical material and conflict minerals (i.e. when integrated in purchased products). Those materials include “conflict minerals” (tin, tungsten, tantalum and gold), rare earth elements, as well as other minerals or metals (e.g. bauxite, cobalt, titanium, lithium). Suppliers shall establish a policy and a management system to reasonably assure that the “conflict minerals” as well as critical material, which may be contained in the products they deliver are sourced responsibly (i.e. with limited environmental impacts and not detrimental to Human Rights).
Suppliers shall support efforts to eradicate the use of any conflict minerals which directly or indirectly finance, or benefit armed groups that are perpetrators of serious human rights abuses. Suppliers are expected to conduct due diligence and provide WASI with supporting data on their sources and supply chain of custody for these minerals when requested, and to identify to WASI any potential doubt on the origin and/or on the production means.
In the event that the material ‘chain of custody’ supplied is “indeterminable” or otherwise unknown, the supplier is expected to either attain the appropriate certifications or phase out that source of mineral.
Payment of taxes
Suppliers must ensure they comply with all applicable tax laws and regulations in the countries where they operate and be open and transparent with the tax authorities. Under no circumstances should suppliers engage in deliberate illegal tax evasion or facilitate such evasion on behalf of others.
As such, suppliers must put in place effective controls to minimize the risk of tax evasion or its facilitation, and provide appropriate training, support and whistleblowing procedures to ensure their employees understand and implement them effectively and can report any concerns.
Payment practices
Suppliers are expected to be fair and reasonable in their payment practices and pay undisputed and valid invoices on time in accordance with agreed contractual payment terms and applicable laws.
Maintain Accurate Records
Suppliers are expected to create, store and maintain business records, and not alter any record entry to conceal or misrepresent the underlying transaction represented by it.
Suppliers are expected to have in place appropriate related controls to ensure the above activities are accurately and securely performed.
All records, regardless of format, made or received as evidence of a business transaction must fully and accurately represent the transaction or event being documented. Records should be retained based on the applicable retention requirements.
Governance & Management Systems
Speak up culture and whistleblower protection
Suppliers are expected to provide employees and third parties with access to adequate reporting channels to seek advice or raise legal or ethical concerns without fear of retaliation, including opportunities for anonymous reporting. Concerns about WASI or its personnel may be reported to Western Aero HR at WesternAeroHR@WesternAero.com.
We expect suppliers to take action to prevent, detect and correct retaliatory actions.
Consequences for violating the code
In the event that the expectations of this Code are not met, the business relationship may be reviewed and corrective action pursued subject to the terms of the related procurement contract(s).
Supplier Commitment
The Supplier agrees that it shall comply with the principles of the WASI Supplier Code of Conduct either by applying this WASI Supplier Code of Conduct or by ensuring that the Supplier’s own code of conduct and current sustainability practices towards its supply chain are consistent with the principles set out in the WASI Supplier Code of Conduct.
The Supplier shall take the necessary actions to flow down the WASI Supplier Code of Conduct principles to its affiliates, subsidiaries and to their subcontractors involved in business with WASI.
These WASI Supplier Code of Conduct principles shall be incorporated into any routine sustainable business practices.
Upon accepting an order from WASI, the Supplier accepts that this document shall be a commitment to the principles set out herein for all existing Contracts (if any), and for all business and contractual relationship with WASI.
The WASI Supplier Code of Conduct represents a minimum standard of best practices. It shall be governed by the laws of the State of Colorado, unless otherwise stated in the applicable purchase order or repair order.
Revision [1] – Effective [10/02/2026]