Values, Ethics, and Compliance

Ethics and Integrity are at the heart of our operations. As part of the TransDigm Group, we are committed to the highest standards of ethical conduct and compliance with global laws and regulations. This includes zero tolerance for bribery, corruption, and fraud, as outlined in our comprehensive Code of Business Conduct and Ethics.

We actively promote transparency, respect, and fairness in everything we do. Through training and robust internal processes, we empower our employees to recognize and address ethical challenges.

Our commitment to compliance extends to safeguarding human rights, protecting data, and ensuring adherence to international trade and anti-corruption standards. We also provide safe, anonymous reporting mechanisms for any unethical or illegal behavior.

At Nordisk, we take pride in creating a positive, responsible, and compliant work environment that reflects our values and builds trust with our customers and stakeholders.

Our Commitment to Human Rights and Decent Work

Nordisk Aviation Products is deeply committed to promoting and respecting human rights and decent work in all aspects of our operations. Guided by the Norwegian Transparency Act and the OECD Guidelines for Multinational Enterprises, our policy on responsible working conditions reflects our dedication to ethical business practices and the well-being of all stakeholders. This policy also aligns with the following UN Sustainable Development Goals:

• Goal 3: Good Health and Well-Being
• Goal 4: Quality Education
• Goal 5: Gender Equality and Non-Discrimination
• Goal 8: Decent Work and Economic Growth
• Goal 16: Peace, Justice, and Strong Institutions

This commitment applies to our entire organization, including our supply chain and all business partners.

Respect for Fundamental Human Rights

At Nordisk, we uphold the highest standards for respecting fundamental human rights:

• Purpose and Obligation: We adhere to internationally recognized charters, such as the UN Universal Declaration of Human Rights, and comply with relevant national laws and regulations.
• Non-Discrimination: All individuals, regardless of race, gender, religion, national origin, age, disability, sexual orientation, gender identity, or other protected characteristics, are treated fairly and equitably.
• Labor Rights: We oppose forced labor, child labor, and workplace discrimination, while supporting employees' rights to organize and engage in collective bargaining.
• Freedom of Expression: Employees are encouraged to share their opinions and ideas freely within the boundaries of our policies and laws.
• Privacy and Data Protection: We respect and protect the personal data of our employees, customers, and stakeholders.
• Fair Business Practices: We conduct our operations ethically and actively work to prevent human rights violations within our business activities and supply chains.
• Training and Awareness: All employees receive training on our human rights principles to ensure awareness and effective implementation.
• Reporting and Response: Concerns regarding potential human rights violations are addressed through clear reporting procedures and follow-up actions.
• Continuous Improvement: We regularly review and enhance our policies and practices to remain aligned with international standards.

Ensuring Decent Work Conditions

We are committed to fostering a workplace environment that upholds respect, safety, and dignity:

• Purpose and Obligation: We recognize the importance of fair and respectful working conditions for employee well-being and productivity.
• Diversity and Inclusion: We promote diversity and inclusion by ensuring equal opportunities and combating discrimination in all forms.
• Fair Compensation: Employees are compensated transparently and equitably, meeting or exceeding industry standards.
• Reasonable Workload: We ensure reasonable workloads to prevent stress and health issues.
• Health and Safety: Employees work in safe, healthy environments, with systems in place to address potential hazards promptly.
• Right to Organize: Employees have the freedom to organize and participate in collective bargaining without fear of reprisal.
• Training and Development: Opportunities for skill enhancement and career advancement are available to all employees.
• Transparent Communication: Open and constructive communication channels enable feedback and dialogue on workplace matters.
• Compliance: We strictly follow all applicable labor laws and regulations.
• Continuous Improvement: Our policies are reviewed and updated regularly to reflect evolving standards and best practices.

Accountability Across Our Supply Chain

We extend these commitments to our suppliers and business partners, requiring them to:

• Comply with all applicable laws and regulations regarding human rights and decent work.
• Eliminate forced labor, child labor, and trafficking from their operations.
• Support workers' rights to organize and collectively bargain.
• Foster diversity and ensure fair treatment in their workforce.
• Provide safe and healthy working environments.
• Maintain transparency in reporting their adherence to these principles.

Nordisk conducts regular due diligence to ensure compliance across our supply chain and collaborates with suppliers to address and improve any deficiencies. Persistent non-compliance may lead to reevaluation of business relationships.

Transparency and Reporting

In line with the Norwegian Transparency Act, Nordisk Aviation Products provides detailed reporting on our efforts to uphold human rights and decent work. We invite our stakeholders to engage with us and hold us accountable for maintaining these standards.

Whistleblower Procedure for Reporting Corruption and Bribery

For employees of Nordisk Aviation Products, TransDigm Group Inc.’s Whistleblower Procedure (CG-003 Whistleblower Policy and Procedures) applies. This procedure is to be used for whistleblowing in the following instances (not an exhaustive list):

• Reporting corruption and bribery.
• Concerns regarding or breaches of information security regulations.
• Violations of ethical standards or other unethical behavior.

All TransDigm companies currently use Convercent's anonymous whistleblowing service for reporting critical concerns. For further details, please refer to the Convercent 24/7 Helpline whistleblower poster.

Information Security and Data Privacy

Nordisk Aviation Products prioritizes robust information security and compliance with the General Data Protection Regulation (GDPR) to safeguard personal data and ensure confidentiality in all operations. Key aspects include:

• Information Security Policies: Guided by TransDigm’s IT framework, we adhere to policies covering IT change control, security access, email and mobile device usage, cybersecurity audits, and incident response plans.
• Employee Awareness Training: All employees undergo annual security awareness training and participate in quarterly phishing simulations to enhance cybersecurity preparedness.
• Supplier Due Diligence: Third-party vendors are subject to strict due diligence, including annual reviews and the evaluation of SOC2 or equivalent reports.
• Data Protection Measures: We implement robust technical and organizational measures to prevent unauthorized access to personal and third-party data.
• Data Privacy: Personal data processing is conducted in line with GDPR principles, ensuring transparency, accountability, and secure data handling.

For more information, refer to the company’s IT policies and GDPR compliance framework.

Download California Transparency in Supply Chain Act

Read our Privacy notice