GE Aerospace : Code of Conduct

The Spirit

& The Letter

The Spirit and The Letter serves as our compass for ethical conduct, reflecting our core values and supporting our long-standing tradition of unyielding integrity. These guiding principles and policies set forth our expectations of all employees and lay the foundation for sound decision-making, ensuring that we act in a compliant manner that is consistent with our code of conduct. By adopting these policies and behaviors, we create an environment where everyone can thrive and deliver the very best of GE Aerospace to our customers and partners.

You have the power to influence GE Aerospace's reputation worldwide by how you embrace the Spirit and the Letter. By committing to these principles, you ensure that the work we do upholds our purpose: We invent the future of flight, lift people up, and bring them home safely.

Melissa Kelly

Vice President & Chief Compliance Officer

Table of Contents

Learn Our Program - THE SPIRIT

Learn Our Policies - THE LETTER

Ethics: The GE Aerospace Way

Who Should Follow These Policies

What Employees Must Do

What Leaders Must Do

Need more help? Visit compliance.geaerospace.net to:

• Find a business compliance leader
• Raise a concern
• Review policies
• Download and view job aids, videos and more!

Respectful Workplace

• Human Rights
• Respectful Workplace
• Human Rights

Win with Integrity

• Fair Competition
• Improper Payments Prevention
• Working with Governments

Commercial Compliance Excellence

• Anti-MoneyLaundering
• International Trade Compliance
• Quality
• Reporting and Recordkeeping

Source Responsibly

• Supplier Relationships

Protect Company Data

• Acceptable Use
• Cyber Security
• Intellectual Property
• Privacy

Protect Yourself

• the Company
• Conflicts of Interest
• Environment, Health and Safety
• Insider Trading and Stock Tipping
• Security

Voice of Integrity

• Open Reporting

Key Principles

• Be honest, fair and trustworthy in all of your activities and relationships.

• Obey applicable laws and regulations governing our business worldwide.

• Fulfill your obligation to be the Voice of Integrity and promptly report any concerns you have about compliance with law, GE Aerospace policy or this Code.

Key Questions

The Spirit & The Letter is not a substitute for your good judgment, and it cannot cover every conceivable situation. You should be alert to signs that you or your colleagues are in an integrity gray area and ask yourself three simple questions if you have any doubts about what you should do:

• How would this decision look to others within GE Aerospace and externally?

2 Am I willing to be held accountable for this decision?

3 Is this consistent with GE Aerospace's Code of Conduct?

This Includes

• GE Aerospace directors, officers and employees.
• Subsidiaries and controlled affiliates. Entities in which GE Aerospace owns more than 50 percent of voting rights, or which GE Aerospace has the right to control, are required to adopt and follow GE Aerospace compliance policies.
  Non-controlled affiliates should be encouraged to adopt and follow GE Aerospace compliance policies.

GE Aerospace employees working with third parties such as consultants, agents, sales representatives, distributors and independent contractors must

• Require these parties to agree to comply with relevant aspects of GE Aerospace's compliance policies.
• Provide these parties with education and information about policy requirements.
• Take action, up to and including terminating a contract, after learning that a third party failed to abide by GE Aerospace's compliance policies.

Be Knowledgeable

• Gain a basic understanding of the Spirit & Letter compliance policies.
• Learn the details of any Spirit & Letter policy that is relevant to your individual job responsibilities.
• Learn about your detailed business and regional policies and procedures and understand how to apply them to your job.

Be Aware

• Stay attuned to developments in your area or industry that might impact compliance with laws and regulations or reputation in the marketplace.
• Understand GE Aerospace may review, audit, monitor, intercept, access and disclose information processed or stored on GE Aerospace equipment and technology, or on personally owned devices permitted GE Aerospace network access.

Be Committed

• Promptly raise any concerns about potential violations of law or policy.
• Cooperate fully and honestly in investigations related to integrity concerns.

The Cost of Noncompliance

• Employees and leaders who do not fulfill their integrity responsibilities face disciplinary action up to and including the termination of their employment. The following examples of conduct can result in disciplinary action.

Examples of Misconduct

• Violating law or policy or requesting that others do the same.
• Retaliating against another employee for reporting an integrity concern.
• Failing to promptly report a known or suspected violation of compliance policies.
• Failing to fully and honestly cooperate in investigations of possible policy violations.
• Failing as a leader to diligently ensure compliance with integrity principles, policies and law.

Prevent

• Incentivize compliance and personally set the example for integrity - not just through words, but more importantly, through actions.
• Never compromise integrity to meet a deadline, satisfy a customer or increase revenue.
• Promote Open Reporting and ensure employees know how to raise concerns and feel safe doing so.
• Ensure your team can recognize "red flags" for key risks and completes assigned compliance training in a timely manner.
• Help employees understand how and where to seek additional guidance and ask questions.
• Understand and follow the policies, laws and regulations that apply to your team. If unsure, ask an expert in Legal or Compliance.

Detect

• Conduct periodic compliance reviews with
  the assistance of business compliance leaders and/or Internal Audit.
• Implement control measures to detect compliance risks and violations.

Respond

• Document and escalate any employee's expressed concern through the appropriate channels.
• Take prompt corrective action to address identified compliance weaknesses.
• Take appropriate disciplinary action.
• Integrate employees' integrity contributions into evaluations and recognition and reward programs.

The GE Aerospace Way

• GE Aerospace is committed to providing a safe, fair, and respectful work environment.
• GE Aerospace does not tolerate any form of harassment, discrimination, or bullying.
• GE Aerospace is an equal opportunity employer and makes all employment decisions based on legitimate business considerations, such as experience, skills, education, performance, and the GE Aerospace Way.

Integrity in Action

1. During a recent team lunch, one of my colleagues made an off-handed joke about an ethnic stereotype. How should I respond to this situation?

1. You have a few different options. (1) Be direct, factual, and professional and inform the person that this is unacceptable: "What you said is inappropriate here" or "I was offended by what you just said" or "I was not offended, but someone else might be"; (2) Disrupt/redirect the conversation: "That wasn't funny" or "We need to focus on the task at hand." Later follow up with the person directly to be clear that the conduct was not acceptable and must stop; or (3) Raise an integrity concern through one of our Open Reporting channels.

Your Role

• Treat employees, applicants, customers, suppliers, contractors, and anyone else you interact with for or on behalf of GE Aerospace with fairness and respect.
• Create and foster a work environment free from discrimination, bullying and harassment.
• Do not refuse to work or cooperate with others because of protected characteristics.
• Never make an unwelcome sexual advance to or create an unwelcome working environment for anyone you interact with.

Policy Spotlight

Protected characteristics under GE Aerospace policy include: race, color, religion, national or ethnic origin, ancestry, sex (including pregnancy and related conditions), gender (including gender identity and expression), sexual orientation, marital status, genetic information, age, disability, military and veteran status

or any other characteristic protected by law.

Help Corner

S&L Respectful

Workplace Policy

Policy Spotlight

Fundamental human rights include decent and safe working conditions, freedom of association, prohibitions on forced and child labor, and respect for community security and the environment.

Help Corner

S&L Human Rights Policy

Human Rights

Statement of Principles

Human Rights

We respect and support human rights.

The GE Aerospace Way

• We respect all internationally recognized human rights in line with theUnited Nations Guiding Principles on Business and Human Rights.
• We seek to treat everyone affected by our business and value chain with fairness and dignity.
• Our commitment is to do our best to identify and address relevant risks by keeping our eyes always open to suspicious conditions and conducting reasonable due diligence.

Suspicious Third-Party Conditions to Report

• Workers who appear below the age of 16 or the local legal working age, whichever is higher
• Unsafe working conditions or unsanitary worker living conditions
• Refusals by management to permit engagement with workers
• Refusals to allow workers to associate freely (formally or informally) to improve their workplace
• Visible signs of workplace abuse, including harassment, bullying, discrimination or violence
• Rumors of workers paying recruitment fees for their jobs, not being paid appropriately, or being coerced into working or remaining on a job through measures such as passport withholding

Your Role

• Immediately notify your compliance leader or use standard Open Reporting channels if you observe any conditions or circumstances that reflect possible mistreatment of workers or other individuals in our value chain.
• Read GE Aerospace's public statements on human rights and participate in company training to understand how we can impact the human rights of our extended value chain.
• Respect the fundamental human rights of those with whom you interact and require the same of our suppliers, contractors and business partners.
• Exercise an "Eyes Always Open" approach at GE Aerospace, customer and supplier sites.