BUSINESS ETHICS POLICY

INTRODUCTION

Since its founding, Atom Adhesives as an ISO certified company has offered a variety of standard and custom formulated Grease and epoxy, Urethane, UV and Silicone Systems as well as related Dispensing Accessories. With an objective to offer the highest quality and most innovative systems, our AA-Bond product series has developed a reputation of durability under extreme conditions in aerospace, defense, marine, industrial and civilian applications. Our in-house manufacturing and distribution system allows fast custom packaging and formulation of products to our clients' specific applications. We continue to innovate as one of the most professional and reliable epoxy suppliers aiming to provide the highest quality and most competitive products with professional technical after-sale service.

Our US made products along with manufacturing capacity allow us to meet our customers most demanding timeline and budgets. The organization has secured a sizeable domestic and international customer base by continuing to exceed customer expectations. Our supply chain is optimized to scale up production per customer demand. Atom Adhesives maintains a domestic multiple supplier channels for raw materials to mitigate the risk of supply chain interruptions.

Atom Adhesives’ Business Ethics Policy, which is embodied in the following standards, is a guide to ethical decision-making. We are committed to uncompromising integrity in all that we do and in the way in which we relate to each other and to people outside the company. While the standards in this policy are mainly based on laws, they also reflect the values which define us and our Company. We must constantly strive to avoid any circumstances which may create a conflict, or the appearance of a conflict, between our personal interests and those of the company. Each of us is personally responsible for making sure that our business decisions and actions comply at all times with the spirit as well as the letter of this policy. All supervisory and management employees, including all officers and directors of the company, have a special responsibility to lead according to the standards in this policy, in both words and action. Our supervisory and management employees are also expected to adhere to and promote our “open door” policy. This means that they are available to anyone with ethical or other concerns, questions or complaints. We also maintain a confidential “hotline” that we can call in those circumstances, the details of which are set out at the end of this Policy. All concerns, questions and complaints will be taken seriously and handled promptly, confidentially and professionally. No retaliation will be taken against any employee for raising any concern, question or complaint in good faith.

IT DIVISION

COMPLIANCE WITH LAWS, RULES AND REGULATIONS

It is the company’s policy to be a good “corporate citizen.” Wherever we do business, employees and directors of the company are required to comply with all applicable laws, rules and regulations. Employees are also responsible for honoring and abiding by the contracts that we have entered into with other parties, including intellectual property licenses (e.g., custom adhesive applications, special formulations, ….etc. related to products used in our business), confidentiality agreements, contracts with our customers and suppliers, and undertakings and other commitments we may have with government authorities. The standards in this policy must of course be interpreted in the context of applicable law and practice of the countries where we operate, as well as good common sense. Any suspected or actual violation of any applicable law, rule or regulation or our contractual obligations or undertakings should be reported immediately to the General Counsel.

GLOBAL CITIZENSHIP

The health of our planet and its people is of the utmost importance to our mission. All products manufactured by Atom Adhesives are sourced from DRC conflict-free areas and are EICC compliant.

CONFIDENTIAL INFORMATION

Information is a valuable corporate asset. All employees and directors have an obligation to safeguard confidential information about the company and confidential information that our suppliers and customers have entrusted to us. Generally speaking, confidential information is information that has not been disclosed to the general public or that gives our business an advantage over our competitors or could expose us to harm or liability if released prematurely or inappropriately. For a more detailed explanation of the definition of “confidential information” and the proper treatment of such information, please see the Company’s Policy and Procedure on Confidential Information. Employees and directors who are unsure about whether information should be treated as confidential must consult with their immediate supervisor or the General Counsel.

FAIR DEALING

Atom Adhesives is committed to having its employees deal fairly and honestly with the company’s customers, suppliers, competitors & other employees.

Our Competitors

It is company policy to compete aggressively for new and existing business based on our superior product quality, innovation, technical competence, marketing support and service, and competitive pricing. Accordingly, false, misleading, or disparaging statements or innuendo about our competitors, their products or their services, or false or misleading statements about our company and its products and services, will not be tolerated. All comparisons of our products and services with those of our competitors, and all claims about our products and services, must be accurate and factually supported.

Employees are strictly forbidden from using any illegal or unethical methods to gather competitive intelligence. This includes stealing confidential or trade secret information of our competitors, or attempting to induce former or current employees of competitors to disclose such information through misrepresentation or other means. Anyone with even the slightest concern about the legality of information he or she possesses, or the means by which it was gathered, should consult with the General Counsel.