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Contractor and Sub-Contractor
Code of Conduct

Last updated:
31st March 2025

1    PURPOSE
SKY Mobility is committed to maintaining the highest ethical, environmental, and social standards across its supply chain. This Supplier Code of Conduct sets forth the principles and expectations for all suppliers, contractors, and business partners working with SKY Mobility. Compliance with this Code is essential for establishing and maintaining a business relationship with SKY Mobility.

2    COMPLIANCE WITH LAWS AND REGULATIONS
Suppliers must comply with all applicable local, national, and international laws and regulations, including but not limited to:

  • Environmental protection laws

  • Labor and human rights regulations

  • Anti-bribery and anti-corruption laws

  • Fair competition and antitrust regulations

  • Data protection and privacy laws

  • Compliance with trade laws, including import/export regulations and sanctions, is required.

  • Regulatory standards relevant to aviation safety and procurement, including SKY Mobility’s ISO 9001 certification requirements and ICAO Annex 19 (Safety Management Systems), EASA UAS.LUC Part C of Regulation (EU) 2019/947 obligations for aviation-related contracted activities.
     

3    ETHICAL BUSINESS PRACTICES
Suppliers are expected to uphold high ethical standards and demonstrate integrity in their business dealings. This includes:

  • Prohibiting bribery, corruption, and fraudulent activities.

  • Ensuring fair competition and avoiding conflicts of interest.

  • Respecting intellectual property rights.

  • Maintaining transparency in financial transactions and business records.

 

4    LABOR AND HUMAN RIGHTS
Suppliers shall respect human rights and ensure fair working conditions. This includes:

  • Prohibiting forced labor, child labor, and human trafficking.

  • Ensuring fair wages, reasonable working hours, and safe working conditions.

  • Providing a workplace free from discrimination, harassment, and abuse.

  • Recognizing employees' rights to collective bargaining and freedom of association.


5    ENVIRONMENTAL RESPONSIBILITY 
Suppliers shall adopt environmentally responsible practices that align with SKY Mobility’s sustainability commitments. This includes:

  • Suppliers are expected to comply with SKY Mobility’s Sustainability (ESG) Policy (OMM 1.2.3).

  • Complying with environmental laws and regulations.

  • Suppliers must strive to reduce their environmental footprint, including energy consumption, emissions, waste and supporting net-zero transition plans. 

  • Implementation of sustainable procurement practices for the reduction of Scope 1, 2, and 3 greenhouse gas emissions is encouraged.

  • Minimizing waste and promoting circular economy principles.

  • Sustainable materials and circular economy principles should be prioritized where feasible.

  • Implementing responsible sourcing practices.

  • Adhering to environmental management standards such as ISO 14001 and ISO 50001.


6    OCCUPATIONAL HEALTH AND SAFETY
Suppliers shall provide a safe and healthy working environment for their employees and stakeholders. This includes:

  • Suppliers must provide a safe and healthy work environment, minimizing risks and hazards.

  • Implementing risk management measures to prevent workplace accidents and injuries.

  • Ensuring product and service safety in accordance with SKY Mobility’s ISO 9001 quality management requirements.

  • Adhering to ICAO Annex 19 Safety Management System standards for aviation-related activities.


7    DATA PROTECTION AND CONFIDENTIALITY

  • Suppliers must protect SKY Mobility’s confidential information and comply with data privacy regulations, including EU GDPR.

  • Security and Cybersecurity measures must be in place to prevent unauthorized data access or breaches.

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8    SUPPLY CHAIN AND PROCUREMENT STANDARDS
Suppliers are responsible for ensuring that their own supply chains comply with this Code of Conduct. This includes:

  • Conducting due diligence on their suppliers and subcontractors.

  • Adhering to SKY Mobility’s procurement and quality assurance standards.

  • Meeting industry-specific certification requirements, including ISO 9001, AS9100, and regulatory approvals from EASA and FAA (if applicable).


9    REPORTING AND COMPLIANCE MONITORING
SKY Mobility and its authorities reserves the right to audit and assess contractor compliance with this Code of Conduct. Contractors must:

  • Maintain accurate records demonstrating compliance.

  • Cooperate with SKY Mobility’s audits and provide relevant documentation.

  • Report any safety related occurrences (Just Culture Policy), violations or unethical behavior through SKY Mobility’s grievance mechanism or via email at compliance@skymobility.aero  promptly.

Failure to comply with this Code of Conduct may result in corrective action, suspension, or termination of the business relationship.


10    ACKNOWLEDGMENT AND COMMITMENT
All suppliers must acknowledge and commit to adhering to this Supplier Code of Conduct. This commitment reflects SKY Mobility’s dedication to ethical, sustainable, and responsible business practices across its supply chain, contributing to mutual success and long-term resilience.
 

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