At Iridium, and of its subsidiaries and affiliates (collectively, “Iridium”), we stand firmly behind the values that shape and guide us in our daily operations and relationships to ensure that we conduct ourselves with the utmost integrity, delivering high-quality products and services, while following all applicable laws, regulations, and industry standards of business conduct to avoid even the appearance of impropriety. It’s simply good, responsible business and it’s what our customers, shareholders and employees expect.

Iridium’s success is built on our core values, captured in the words we believe in: teamwork, innovation, integrity, respect, and excellence. Iridium’s Code of Business Conduct and Ethics is our guide for carrying out these values and for following the laws and regulations that govern our operations around the globe.

We are committed to meeting these expectations, and we trust and expect that our suppliers and partners will honor the same values. Our Supplier Standards of Conduct (collectively referred to as the “Standards”) express the expectations we hold for our suppliers and mirror the standards we set for our own employees, officers, board of directors and other business associates.

For the purposes of the Standards, a “supplier” is any third party wherever located that directly or indirectly sells, or offers to sell, any kind of goods or services to our company or on our company’s behalf, including suppliers, contractors, subcontractors, distributors, dealers, sales/marketing representatives, intermediaries, agents, partners, consultants, resellers, systems integrators, or similar entities. The Standards are not intended to conflict with or modify the terms and conditions of any existing contract or agreement. In the event of such a conflict, suppliers should first adhere to applicable laws and regulations, then the contract terms, followed by the Standards.

I. COMPLIANCE WITH LAWS

A. LAWS, REGULATIONS AND CONTRACTS

First and foremost, we expect our suppliers to, at a minimum, conduct business and perform work in compliance with all laws and regulations applicable to their businesses. When performing international business, or if their primary place of business is outside of the United States, we expect suppliers to comply with all applicable local laws and regulations. We also expect suppliers to comply with all terms, conditions, flow-down requirements and other provisions specified in their contracts, subcontracts, purchase orders or other agreements with Iridium.

B. FINANCIAL RESPONSIBILITY / ACCURATE RECORDS

We expect suppliers to create and maintain complete, accurate and current business records. All records, regardless of format, made or received in furtherance of a business transaction are expected to fully and accurately represent the transaction or event being documented. In addition, we expect suppliers performing work under U.S. government contractors (whether direct or indirect) to comply with applicable federal acquisition regulations.

C. ANTI-TRUST / FAIR COMPETITION

We expect our suppliers to conduct business in accordance with applicable anti-trust or competition laws and regulations. This includes avoiding illegal or unethical business practices, such as entry into arrangements that unlawfully restrain competition, improper exchange of competitive information, price fixing, bid rigging, or improper market allocation.

D. SUPPLIER REQUIREMENTS

As supply chain requirements vary by country, our suppliers should be mindful that we often must meet customer-directed supplier goals that may necessitate the use of in-country supply channel providers both by us and our suppliers, including meeting lawful subcontracting goals for small businesses or small socioeconomically disadvantaged businesses.

II. EMPLOYMENT PRACTICES

A. HUMAN RIGHTS / SOCIAL DIALOGUE

We expect our suppliers to treat people with respect and dignity, encourage inclusion and promote equal opportunity. We expect our suppliers 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.

B. NON-DISCRIMINATION

We expect our suppliers to provide equal employment opportunity to employees and applicants for employment without regard to race, ethnicity, religion, color, sex, pregnancy, national origin, age, military veteran status, ancestry, sexual orientation, gender identity or expression, marital status, genetic information, mental or physical disability, when the essential functions of the job can be performed with or without reasonable accommodation, or any other characteristic protected by federal, state or local law.

C. ANTI-HARASSMENT

We expect our suppliers to ensure that employees may perform their work in an environment free from physical, psychological, sexual and verbal harassment, or other abusive conduct.

D. FORCED LABOR, HUMAN TRAFFICKING AND MODERN SLAVERY

We expect our suppliers to abide by all applicable anti-human trafficking and modern slavery laws and not engage in the use of forced, bonded or indentured labor, involuntary prison labor, slavery, or trafficking of persons. This includes transporting, harboring, recruiting, transferring, or receiving vulnerable persons for exploitation by means of threat, force, coercion, abduction, or fraud.

E. CHILD LABOR

We expect our suppliers to 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.

F. EMPLOYEE SAFETY AND HEALTH

We expect our suppliers to comply with applicable safety and health laws, regulations, policies, and procedures and to provide for the health, safety, and welfare of their people, visitors, and others who may be affected by their activities.

G. DRUG-FREE WORKPLACE

We expect our suppliers to maintain a workplace free from the use, possession, sale or distribution of illegal or controlled substances.

H. WAGES AND BENEFITS

We expect our suppliers to pay workers at least the minimum compensation required by applicable law and provide all legally mandated benefits. In addition to payment for regular hours of work, workers are expected to be paid for overtime as legally required.

III. ANTI-CORRUPION

A. ANTI-CORRUPTION AND ANTI-BRIBERY

We compete on the merits of our products and services and do not use the exchange of business courtesies to gain an unfair competitive advantage, and we expect the same from our suppliers. We have a zero-tolerance policy for corruption, and we prohibit anyone conducting business on our behalf, including suppliers, from offering or making any improper payments or anything of value to government officials, political parties, candidates for public office, or other persons. This includes the offer and/or receipt of any bribe or kickback to and/or from any customer, supplier or others.

We expect our suppliers not to make any illegal, improper or corrupt payments. We also expect our suppliers to comply with applicable anti-corruption laws that govern operations in the countries in which they do business, such as the U.S. Foreign Corrupt Practices Act and the U.K. Bribery Act, and other similar laws prohibiting bribery, kickbacks and corruption in business dealings. We further expect our suppliers to exert appropriate due diligence and monitoring to prevent and detect corruption in all business arrangements, including partnerships, joint ventures, offset agreements, and the engagement of third parties.

B. GIFTS, GRATUITIES AND BUSINESS COURTESIES

The exchange of business courtesies may not be used to gain an unfair competitive advantage or exercise improper influence. In any business relationship, we expect our suppliers to ensure that the offer or receipt of any gift or business courtesy is permitted by law and regulation; does not violate the rules and standards of the recipient’s organization; is consistent with reasonable marketplace customs; and will not adversely impact the reputation of Iridium.

C. CONFLICTS OF INTEREST

We expect our suppliers to avoid all conflicts of interest or situations giving rise to the appearance of a potential conflict of interest in their dealings with Iridium. We also expect our suppliers to promptly report to Iridium any situations of potential, apparent or actual conflicts between their business or personal interests and the interests of Iridium.

IV. SECURITY AND PROTECTING INFORMATION

A. CYBERSECURITY, DATA PRIVACY AND INFORMATION SECURITY

Suppliers should safeguard and protect information entrusted to them, information generated or developed by them in support of business activities, and the underlying systems that process this information from risks to confidentiality, integrity, and availability. Suppliers should have risk-based cybersecurity programs, consistent with established security frameworks, designed to mitigate established and emerging threats to their information systems, products and services, people, facilities and supply chains. Our suppliers’ cybersecurity programs should be periodically assessed, with timely remediation of issues identified. Our suppliers should establish responsible personnel to protect information, including Iridium’s confidential, controlled, proprietary and personal information from unauthorized access. Suppliers should ensure that any data processing of personal information is done in accordance with legal requirements, including data privacy laws, and sound industry practices. If our supplier determines any actual or suspected cybersecurity or privacy incidents, those should be reported to us without delay. To decrease the risk of these incidents, suppliers should apply strict access controls, engage in vulnerability management, and use secure methods for data storage and transmission.

B. INTELLECTUAL PROPERTY AND SENSITIVE INFORMATION

We expect our suppliers to comply with all contractual obligations and applicable laws, including intellectual property and other binding obligations governing safeguarding intangible property rights and confidential, proprietary or other sensitive information. We also expect our suppliers to maintain the confidentiality of all information entrusted to them by us, our customers or other third parties, except where disclosure is authorized or legally required (and then only after notice with an opportunity to object). We further expect our suppliers to properly handle, label/classify, and protect different types of sensitive information from improper access. Iridium information should not be used for any purpose other than the business purpose for which it was provided unless there is prior written authorization from the information’s owner.

Any sharing of information with subcontractors or third parties must be carefully controlled and consistent with contract requirements and assessment of the subcontractor or third parties’ risk, ensuring that these parties also adhere to our intellectual property, security, and privacy obligations.

C. PROCUREMENT INTEGRITY

We expect our suppliers to maintain the integrity of our procurement and acquisition processes. Suppliers should not improperly use or misuse competitors’ or customers’ confidential, proprietary or other competitively sensitive information for their own benefit. If a supplier becomes aware of any such information that was improperly or erroneously disclosed, they should promptly take steps to avoid its improper use and inform Iridium as appropriate.

V. GLOBAL TRADE COMPLIANCE

A. EXPORT / IMPORT CONTROL, SANCTIONS, AND ANTI-BOYCOTT

We expect our suppliers to ensure that their business operations are in accordance with all applicable laws and regulations governing the export and import of domestic and foreign origin parts, components, software and related technical data. Likewise, we expect suppliers to utilize appropriate due diligence measures to avoid prohibited transactions with parties subject to financial sanctions and trade embargoes. Suppliers should provide complete and accurate information in their dealings with Iridium and applicable regulatory agencies and obtain export licenses and/or authorizations when necessary. Our suppliers should not participate in, cooperate with, or further the cause of any unsanctioned foreign economic boycott in accordance with existing U.S. law or regulation.

B. QUALITY / COUNTERFEIT PARTS

Suppliers should ensure their work products meet applicable quality and safety standards. Suppliers should implement quality assurance processes to identify defects and implement corrective actions. We expect our suppliers to develop, implement, and maintain methods and processes appropriate to our suppliers’ products and services to minimize the risk of introducing counterfeit parts and materials into supply chains and deliverable products. Effective processes should be in place to detect and identify counterfeit parts and materials, and mark parts imitation or obsolete as appropriate.

C. CONFLICT MINERALS

We expect our suppliers to take steps to determine if their products contain conflict minerals (gold, tantalum, tin and tungsten) and, if so, implement supply chain due diligence processes to identify sources of these minerals and support efforts to eradicate the use of conflict minerals that directly or indirectly finance or benefit armed groups in the Democratic Republic of Congo or adjoining countries.

VI. ENVIRONMENTAL MANAGEMENT

We expect our suppliers to comply with all applicable environmental laws, regulations and directives. We also expect our suppliers to operate as responsible stewards of the environment and in a manner that actively and responsibly manages risk, conserves natural resources, prevents pollution, and protects the environment. To those ends, suppliers should:

• obtain and keep current all required environmental permits and registrations;
• reduce, control and/or eliminate wastewater, waste and pollution at the source;
• reduce, control and/or eliminate emissions of volatile chemicals, corrosives, particulates, aerosols and combustion products;
• conform to applicable labeling and warning requirements; and
• identify, manage, store, move, handle, and dispose of hazardous substances in accordance with law.

VII. ETHICS EXPECTATIONS

A. STANDARDS OF CONDUCT AND SUB-TIER SUPPLIERS

Commensurate with the size and nature of their businesses, we expect our suppliers to have management systems in place to comply with applicable laws, regulations, policies and the expectations of the Standards. We encourage our suppliers to implement their own written code or standards of conduct, and to flow down their principles to the entities that furnish goods and services to our suppliers.

B. ETHICS AND COMPLIANCE POLICIES

Commensurate with the size and nature of their businesses, we expect our suppliers to have management systems in place to support compliance with laws, regulations, performance requirements and the expectations related to or addressed expressly within the Standards. This should include measures to address compliance within the Standards and steps to take appropriate action to correct identified deficiencies.

C. REPORTING AND WHISTLEBLOWER PROTECTION

We expect our suppliers to provide their employees with avenues for raising legal or ethical issues or reporting concerns without fear of retaliation. We also expect our suppliers to take action to prevent, detect, and address any retaliatory actions.

D. CONSEQUENCES FOR VIOLATING STANDARDS

In the event of a violation of the Standards, we may pursue corrective action to remedy the situation. In the case of an actual or possible violation of law or regulation, we may be required to report the matter to the proper authorities. We reserve the right to terminate our relationship or take any other appropriate action with any supplier under the terms of our existing contract or agreement to address a violation of the Standards.