Code of Ethics

At AEI, we are committed to satisfying our client’s needs, delivering on our promises, and being their provider of choice. AEI is proud to support our employees personally and professionally, as well as the communities in which we work and live.

This Code of Ethics (the “Code”) is designed to give you guidance in managing these commitments as well as act in a way that mitigates operational, legal and ethical risk. At AEI, we are dedicated to promoting high ethical standards and, above all, compliance with all applicable laws and regulations. We expect all our employees, consultants, partners, and suppliers to operate with these same standards. We hope you review this Code, reference it, and seek guidance when the right answer is not obvious.

If anyone observes behavior that is unethical, unsafe or poses an undue risk to the company, we expect them to report it. Supervisors and the management team are usually the best place to address these concerns. However, we recognize that there may be circumstances when individuals are not comfortable reporting an issue in this manner. If for any reason individuals are not comfortable having a conversation with a supervisor or management, they are encouraged to contact AEI’s legal department or our third-party hotline.

Thank you for all you do for AEI, our clients, and our communities.

Equal Employment Opportunity

At AEI, employees are evaluated on their, talent, skill, and ability to successfully perform their work and contribute to our overall success. When we recruit, hire, develop or promote, we do so based on an individual’s demonstrated qualifications and abilities. Discrimination based on a person’s race, color, religion, sex, gender, disability, age, national origin, genetics, citizenship status, or any other status protected by applicable federal, state, or local law and ordinance is prohibited.

Workplace Harassment

Workplace harassment hurts morale, interferes with an individual’s ability to be productive, and prevents AEI from attracting and retaining qualified people. Sexual harassment and other forms of prohibited harassment are unacceptable and will not be tolerated. Prohibited workplace harassment includes quid pro quo sexual harassment, as well as comments, behaviors or images that can contribute to a hostile work environment based on a person’s protected characteristics.

Employee Health, Safety & Security

AEI is committed to providing a safe and secure work environment for everyone. Each of us is expected to know and follow applicable safety and security rules, procedures and requirements. Never take shortcuts or ignore required safety practices in your planning or business operations.

Commitment to the Environment

At a minimum, all employees at AEI must make certain that our operations are in compliance with applicable environmental protection legislation. In addition, AEI is committed to the conservation and protection of the environment. We take pride in working to minimize our waste and increase our sustainable footprint.

Wages and Working Conditions

At AEI, our number one asset is our employees and we strive to treat all employees with dignity and respect. We are committed to complying with all applicable employment laws, regulations, and ordinances, including minimum wage, overtime, and shall provide all legally mandated benefits. AEI respects the rights of employees to join or refrain from joining worker organizations, such as labor unions. Employees are encouraged to communicate openly with management regarding working conditions without threat of reprisal, intimidation, or harassment. AEI does not use forced or involuntary labor of any kind, child labor, or engage in any form of human trafficking.

Procurement

Vendor and other business relationships are essential to the success of AEI and it is required that they are based solely on appropriate business considerations and fair dealing. Employees must follow applicable sourcing and vendor management policies to ensure compliance with regulatory requirements and adherence to ethical business practices. Offering or accepting kickbacks, bribes, excessive gifts or hospitality are strictly prohibited. Employees are strictly forbidden from soliciting or requesting, directly or indirectly, anything of value from any supplier doing business or seeking to do business with AEI.

Retaliation Prohibited

AEI does not tolerate any acts of retaliation against an employee who identifies a potential breach of any section of this Code, any of AEI’s policies or violations of the law. You are protected from retaliation whether or not your report is proven to be correct. Allegations of retaliation will be taken seriously, investigated promptly, kept as confidential as our policies and law permit, tracked for reasonable progress and closed out in a timely manner. Anyone engaging in retaliation will be subject to disciplinary action, up to and including termination of employment. If you feel you have witnessed or experienced retaliation, contact AEI legal department or the third-party hotline.

Reporting Questions or Concerns

Employees are encouraged to report concerns or violations of this Code. You can talk to your supervisor or a member of the management team, reach out to the AEIs legal department, or call our third-party hotline (844-521-7814) or aei.ethicspoint.com. AEI will strive to keep all concerns as confidential as permitted by law. Once a concern is reported, AEI may investigate the situation and take appropriate action.