DREAMLIFTS LTD t/a ANTONOV AIRLINES

CODE OF BUSINESS ETHICS

Scope of Application

1. Company and Employees

1.1 Recognition and Respect for Human Right

1.2 Non-Discrimination (Equal Employment Opportunities)

1.3 Working Hours and Remuneration

1.4 Labour Safety

1.5 Accident-Free Operations

1.6 Compliance and Labour Discipline

1.7 Inadmissible Behavior – No Harassment

1.8 Theft and Fraud

1.9 Information and Technical Resources

1.10 Confidential and Proprietary Information

1.11 Conflict of Interest

 2. Company and Society

2.1 Anti-Corruption and Anti-Bribery

2.2 Anti-Money Laundering

2.3 Business Meetings, Entertainment and Gifts

2.4 Fair Competition

2.5 Dishonesty

2.6 Government Controls and International Trade

2.7 Financial Integrity

2.8 Environmental Protection

3. General provisions

3.1 Code of Ethics Distribution

3.2 Raising Concerns and Reporting on Violations; Internal Investigations

3.3 Adherence to the Code

 

Scope of Application

This Code of Ethics (the “Code”) applies to all Dreamlifts Limited dba Antonov Airlines (“Dreamlifts Limited” or “Company”) directors, officers, employees, agents, consultants, contractors, suppliers, vendors and other persons acting for and on behalf of the Company (“Employees/Agents”).

This Code shall be in effect and followed in all companies and divisions of Dreamlifts Limited.

All Employees/Agents are required to be familiar with this Code, comply with provisions of this Code and anti-corruption laws, and not to commit or tolerate any violation or abuse of this Code and anti-corruption laws.

In case of questions about this Code and/or applicable laws, the Managing Director should be consulted.

Each employee/agent is required to be familiar with this Code, comply with provisions of this Code and anti-corruption laws, and not to commit or tolerate any violation or abuse of this Code and anti-corruption laws, any violation may lead to disciplinary action being taken.

 

1.1. Recognition and Respect for Human Rights

Dreamlifts Limited recognises and respects human rights and freedoms as defined and guaranteed by the international conventions of the United Nations (UN), the International Labor Organization (ILO), the Organization for Economic Cooperation and Development (OECD) and the UN Global Compact Initiative. The Company expects its business partners to recognize and respect human rights and freedoms, personal dignity and privacy of each individual.

As part of this, Dreamlifts Limited is committed to preventing any form of slavery and human trafficking in their activities with their clients. The Company expects its employees to adhere to all company procedures in place to ensure that the clients with which they do business are meeting the standards required in relation to modern slavery laws. Should you have any concerns you should discuss this with your line manager. The Modern Slavery Helpline can provide advice and guidance 08000 121 700.

The Company respects the desire of its employees to be conscious citizens and participate in social life provided that employees act in conformity with the law, outside working hours and using their own resources, whereas the Company always stays out of politics and religion.

 

1.2. Non-Discrimination (Equal Employment Opportunities)

Dreamlifts Limited positions itself as an organization offering work that brings benefits to the community, and pursues a policy of equal employment opportunities for all its employees, and maintains a strict zero-tolerance policy towards discrimination of any nature: by race, social status, gender, age, religion, political views, sexual orientation, marital status, or disabilities.

 

1.3. Working Hours and Remuneration

Dreamlifts Limited is committed to full compliance with all applicable labour and employment regulations, relating as well to working hours and remuneration for work performed for the benefit of particular customers and society in general.

 

1.4. Labour Safety

Dreamlifts Limited is committed to full compliance with all applicable health and safety laws, and considers continuous improvement of safety at workplace to be its own duty,  whereas each employee should take care of his/her health on his/her own that is considered to be one of the basic elements for safe and efficient labour. Each employee must immediately report on workplace injuries, “near misses” or unsafe working conditions. No Dreamlifts Limited employee will be persecuted for reporting on a workplace situation dangerous to life and health.

 

1.5. Accident-Free Operations

Dreamlifts Limited pursues a policy of aviation accident prevention and flight safety management based on fundamental principles of the ICAO Accident Prevention Manual (Doc 9422-1984).

Prevention of aviation accidents is considered an essential condition for sustainable demand for Dreamlifts Limited services and a foundation of its overall success.

Employees are a key element in the Company’s system of accident prevention and safety management.

Health of employees forms the basis for safety and efficiency of the Company, and caring about health is a joint responsibility of the Company and its employees.

The Company recognises the necessity to continuously train and develop its employees.

All employees participating in the flight safety assurance process are trained and qualified under appropriate programs; the recurrent training/qualification process is continuous.

Dreamlifts Limited achievements and expertise in accident prevention and flight safety management are open for everyone.

 

1.6. Compliance and Labour Discipline

Ethical conduct fundamentally provides for strict compliance with the law. However, this Code may often go beyond and set even higher standards than those established by law.

In case of questions about applicability of any specific law and/or compliance with this Code, the Managing Director should be consulted.

Becoming familiar with this Code of Conduct helps identify issues of unethical conduct and take appropriate action.

Dreamlifts Limited’s managers are personally responsible to ensure compliance with this Code and create an environment that encourages such compliance by Employees/Agents. For making sure the Company continues to maintain high standards of integrity, the following is essential:

  • Periodically circulate the Code of Conduct – Ethics Compliance to all employees to read through and confirm they have done so as to understand their obligations under the provisions of this Code;
  • Where there is a conflict between the integrity and business objectives, the integrity must always come first;
  • Lead by example and encourage employees to act in accordance with these rules of ethics;
  • In the event of a breach of these rules by any employee, make sure other employees do not make the same mistake;
  • Never cover up or ignore any integrity problem. Address the matter in a timely manner and seek guidance from the Managing Director if necessary;
  • Never retaliate against anyone for raising an integrity issue, assisting in an investigation, or participating in any proceeding relating to an alleged violation of any law or the commission of a crime;
  • Report on violations of this Code and applicable anti-corruption laws.
  • Carry out all required checks and audits on clients in relation to any slavery or human trafficking risks.

Upon hiring or contract award, and throughout employment/contract performance, Dreamlifts Limited Employees/Agents may be required to complete and sign a document conforming to the laws of each jurisdiction that the Employee/Agent has read, understood and agrees to abide by this Code and applicable anti-corruption laws. Failure to comply with the principles outlined with this Code may lead to disciplinary action up to and including termination of employment/contract.

 

1.7. Inadmissible Behavior – No Harassment

Dreamlifts Limited considers the relationships based on mutual respect to each other to be beneficial for the Company and community as a whole. That respect extends to coworkers, vendors, customers, or anyone the Company comes in contact with. Any conduct that inappropriately or unreasonably interferes with work performance or creates an environment of intimidation and hostility or otherwise offensive work environment is absolutely inadmissible.

Examples of such inadmissible behavior may include:

  • sexual harassment;
  • creation of intolerable working environment;
  • physical or psychological harassment: humiliation, inappropriate language, gestures, threats or actual physical force.

Each employee shall avoid any conduct that inappropriately or unreasonably interferes with work performance or creates an environment of intimidation and hostility or otherwise offensive work environment

1.8. Theft and Fraud

Theft and fraud, specifically in respect of the Company’s assets, constitute violations of the law and are absolutely unacceptable.

All employees are required to report on fraud or theft, or attempts on these crimes. In the first instance the employee should report to their line manager, should their line manager be involved in the activity then the Managing Director should be contacted.  No employee who makes a good-faith report on theft or fraud will be subject to any detrimental treatment for having done so.

1.9. Information and Technical Resources

Information and technical resources (including email, computer hardware and software, networks, internet and intranet access, cell phones or telephones, and vehicles) provided to employees for business purposes are the Company’s property and should not be used for personal benefit. The Company reserves the right to monitor the use of its resources, including, without limitation, monitoring of communication resources such as email, text messages and visited websites according to applicable legislation.

Each employee should not use for personal benefit information and technical resources which are provided to employees for business purposes

The Company reserves the right to monitor the use of its resources, including, without limitation, monitoring of communication resources according to applicable legislation.

1.10. Confidential and Proprietary Information

Dreamlifts Limited employees have a duty to protect confidential and proprietary information. The Company’s policy and applicable laws regulate the protection of confidential and proprietary information that must not be disclosed, unless and to the extent otherwise expressly stipulated by policies and procedures of the Company. Confidential and proprietary information should only be provided to or discussed with Dreamlifts Limited employees or vendors, suppliers and customers for valid business reasons. Company employees should use extreme caution in public places when talking on mobile phone or viewing information displayed on an electronic device, and never leave data carriers containing confidential information unattended. Company employees should observe information security requirements when working with confidential information in intranet/internet, using corporate email or discussing confidential information (including phone). Under no circumstances shall Dreamlifts Limited employees use confidential information for their own abusive purposes.

1.11. Conflict of Interest

Dreamlifts Limited employees shall not allow and shall take preventive actions in relation to any conflict of interest where their personal interest and benefit is, or might be, in conflict with interests of the Company while performing their job duties.

Dreamlifts Limited does not welcome financial conflicts of interests, such as the purchase of shares or other investments by its employees in Dreamlifts Limited suppliers or competitors.

Should any employee be considering such a purchase or investment they should notify the Managing Director in writing of this. No purchase or investment should be made until written permission has been given by the Managing Director that there is either (a) no conflict or (b) there is conflict and it has been recorded and can be managed e.g. by removing the employee’s direct involvement or (c) there is a conflict and it cannot be managed and therefore the employee’s role and the purchase / investment are incompatible.

2.1. Anti-Corruption and Anti-Bribery

All Dreamlifts Limited Employees/Agents are required to fully comply with all anti-corruption laws of the countries in which Dreamlifts Limited does business, including the U.S. Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act (UKBA), which apply worldwide.

Dreamlifts Limited does not tolerate any form of bribery or corruption. Specifically Dreamlifts Limited (1) prohibits acceptance by its employees of any rewards from suppliers, customers and competitors of the Company in return for granting them any commercial advantage; and (2) prohibits paying, promising, offering, or authorizing a payment or the transfer of other valuables directly or indirectly to a government official, political party, private person or private entity for the purpose of influencing the content or adoption of an official act or decision in order to obtain or retain business or secure business. The term “government official” includes any person acting in an official capacity for or on behalf of a government or governmental agency or municipal body at any level, a public international organization or a political party or candidate for political or party office.

Each employee is required to fully comply with all anti-corruption laws of the countries in which Dreamlifts Limited does business

The Company does not tolerate any form of bribery or corruption, Further details on Company expectations relating to bribery can be found within the policy in the employee handbook.

 

2.2. Anti-Money Laundering

Dreamlifts Limited strictly follows all applicable anti-money laundering laws. Dreamlifts Limited employees shall be on the lookout for activities that could constitute money laundering, such as: large payments made to avoid governmental accounting requirements; or parties unwilling to provide complete contact and financial information or comply with record and accounts keeping requirements.

Under no circumstances shall Employees/Agents make transactions on behalf of the Company involving assets which, in the opinion of Employees/Agents, might be of illegal origin.

Any suspicious or unusual behavior involving payment offers/requests relating to business relationship with Dreamlifts Limited should be reported to the Managing Director.

Each employee shall be on the lookout for activities that could constitute money laundering; under no circumstances shall employee/agent make transactions on behalf of the Company involving assets which, in his/her might be of illegal origin

2.3. Business Meetings, Entertainment and Gifts

Neither this Code, nor anti-corruption laws prohibit making reasonable and good faith payments with regard to gifts and traveling expenses, which are consistent with customary business practices. However, Dreamlifts Limited employees are required to comply with all legal requirements pertaining to giving and receiving gifts and entertaining business partners and government officials.

Gifts of cash, cash equivalents, stock or other securities must never be accepted by Dreamlifts Limited employees.

Under no circumstances shall gifts be given to any government official, unless permitted under applicable laws and coordinated with the Managing Director.

All business meals must be for legitimate business reasons. In case of doubt regarding giving and receiving gifts, or accepting or providing meals and entertainment, the Managing Director should be consulted.

Further details on Company expectations relating to acceptable gift giving and hospitality can be found within the policy in the employee handbook.

2.4. Fair Competition

Dreamlifts Limited strictly follows applicable antitrust laws of the countries in which Dreamlifts Limited does business.

2.5. Dishonesty

Dreamlifts Limited is committed to high integrity and, consequently, does not permit deceptive, dishonest or fraudulent activities in business. Fraudulent activities are not only unethical but also a direct violation of law. In order to maintain integrity in the Company’s operations to the highest ethical principles, managers shall encourage transparency and honesty with respect to business performance.

2.6. Government Controls and International Trade

Dreamlifts Limited serves customers and engages with business partners all over the world. Meeting requirements of the government/state control bodies, the Company contributes to the well-being of people as individuals and community as a whole.

Dreamlifts Limited Employees/Agents should make every effort to comply with all laws in countries where the Company operates that may apply to the import or export of goods or services.

2.7. Financial Integrity

Dreamlifts Limited financial records and accounts are kept in accordance with applicable laws and accounting principles. No information shall be entered in the Company’s books or tax records or documentation that intentionally hides, misleads or disguises the true nature of any financial or non-financial transaction or result.

Dreamlifts Limited finance and accounting officers and employees, as well as all members of senior management, have a special fiduciary responsibility to ensure finance and tax accounting practices support the full, fair, accurate, timely and understandable disclosure of Dreamlifts Limited financial results and condition.

Any violations of this financial integrity policy should be reported immediately to the Managing Director. No employee who makes a good-faith report on violations will be subjected to persecution.

2.8. Environmental Protection

Dreamlifts Limited acknowledges its responsibility to the community for preserving healthy environment and considers environmental protection as an integral part of business, both in the short and longer term.

The Company’s primary environmental objective is to ensure high levels of environmental safety of its operations, specifically through minimisation of impact on environment.

Dreamlifts Limited efforts in support of this objective are based on the following guiding principles:

  • plan and implement any activity in strict compliance with applicable domestic and international laws and regulations on protection of environment;
  • ensure reliable records, analysis and reporting on actual environmental effects of its business;
  • introduce and use equipment, technologies, materials and processes which take into account environmental requirements and allow the reduction of environmental impact;
  • maintain an effective environment management system as the basis for continuous reduction of environmental impact of its business;
  • improve environmental knowledge, consciousness and awareness of Dreamlifts Limited employees, specifically regarding environmental aspects of the Company’s core, supporting and management processes;
  • ensure that the Company’s activities with regard to environmental protection are always open to all parties concerned.
3.1. Code of Ethics Distribution

Dreamlifts Limited requires that each and every Employee/Agent be provided with the Code of Conduct – Ethics Compliance upon joining the Company and required to sign to say they have read and understood their obligations regarding the content and policies contained within this Code.

Dreamlifts Limited requires its business partners to strictly comply with applicable laws and abide by principles contained in this Code. Dreamlifts Limited business partners are required to certify in writing that they fully understand the requirements of this Code and commit to comply with such requirements as a condition precedent to remain active contractors with the Company.

Each employee/agent must be issued with a copy of this Code.

3.2. Raising Concerns and Reporting on Violations; Internal Investigations

Dreamlifts Limited pays special attention to open and transparent communication, as well as to creating an environment that fosters such open and candid communication in accordance with the Company’s principles of interpersonal relations.

Dreamlifts Limited expects and encourages its employees to report (including anonymously) on violations of the law to the Managing Director. The Managing Director will ensure that there is a prompt and thorough investigation of the reported allegations or concerns. Employees should act in good faith and avoid intentionally false allegations. Employees who make intentionally false allegations may be subject to disciplinary action, up to and including termination of employment.  Dreamlifts Limited employees who, in good faith, report on violations of the law or Dreamlifts Limited policies will not be the subject of reprisals, retaliation, or other punishment as a consequence of reporting the violation.

The Managing Director will be responsible to ensure that any retaliation is duly addressed and, where appropriate, subject to disciplinary action.

Employees who make unfounded accusations or otherwise ignore Dreamlifts Limited policies in bad faith are subject to disciplinary action, up to and including termination of employment.

Where appropriate, the Company may conduct an internal investigation to determine the fact and nature of any violation of this Code. The Company shall make every effort to keep confidential the name of the employee who reports on a violation. The Company or its Employees/Agents may disclose information about the employee who reports on a violation to the extent necessary to conduct a thorough and effective investigation, or as required by law or court order.    All information relating to an investigation will be kept confidential. If an investigation reveals one or more violations, the Company management will take appropriate action to eliminate any recurrence of similar violations in future, including additional training. All questions concerning such internal investigations should be directed to the Managing Director.

The Company expects and encourages its employees to report (including anonymously) on violations of the law to the Managing Director.

The Company’s Whistleblowing Policy found within the Employee Handbook gives details of how employees can disclose concerns or allegations with some examples of external regulatory bodies that employees may approach should they believe it necessary. However, employees are strongly encouraged to report or disclose concerns or allegations internally in the first instance as Dreamlifts Limited believes that it has, or has access too, the relevant and appropriate resources to investigate, respond too and resolve any allegations or concerns reported.

3.3. ADHERENCE to the Code

The Company shall review and distribute the Code annually to all employees. They shall be expected to read the Code and sign to signal their acceptance to act within the Code during their employment.