ETHICAL CODE OF CONDUCT

OUR MOTIVATION AND PARTNERSHIP

EGAT is a certified and reputable airframe, engine and component Maintenance, Repair and Overhaul service provider. An award-winning service provider, EGAT’s unwavering commitment to airline safety and customer satisfaction with its many airline partners is the foundation to sustainable corporate well-being, and long term growth. This commitment is underpinned by EGAT being a good corporate citizen, through corporate integrity and honesty.

To maintain EGAT’s corporate well-being, an Ethical Code Of Conduct (“Code”) is applied to all personnel. This code serves to define guidelines on personnel behavior when engaging in business activities with customers, suppliers and stakeholders on behalf of EGAT.

All personnel are to be bound by this Code. Breach of this Code, and misconducts in violation of the spirit and letter of this Code, will result in investigations on all affected personnel, and if substantiated, will result in prompt disciplinary action in accordance with the Personnel Management Guidelines governing employees of the Evergreen Group. Specifics of this Code are listed below. All personnel of EGAT are expected to learn, understand, and abide by the specifics of the Code.

Chairman Signature

ETHICAL CODE OF CONDUCT POLICIES

1 - Integrity, Accountability, and Loyalty

• All personnel are to apply high integrity in carrying out business transactions on behalf of the company. They are to fully accountable to the activities that they are tasked with and remain loyal to protect the assets, reputation, well-being and interests of the company.

• In their accountability and loyalty to above Para. 1a, no company personnel is to derive any monetary or tangible personal gain at all times.

• Corporate non-monetary gifts to other parties given on behalf of the company, either directly or indirectly, are to be proposed and approved formally with written documentation by management and leadership. Where appropriate, such gifts shall bear the company logo affixed on them or with a company name card denoting the sender.

• Monetary gifts may be given only in a culturally acceptable contexts and occasions such as lunar new year, weddings, funerals etc. proposed and approved formally with written documentation by management and leadership, regardless of the quantum value of such monetary gifts.

2 - Compliance

• In all business transactions with customers and suppliers, besides adherence to local laws and regulations, all personnel shall not knowingly offer or accept bribes and kickbacks, neither in the form of monies nor in-kind, to any other party.

• Pursuant to Para. 2a, all employees are to refrain from disclosing sensitive information, belonging either to the company or to the company’s suppliers or customers, to any other party outside of the company unless the other party has been bound by a Non-Disclosure Agreement. All disclosure of information shall be made on a need-to-know basis only.

• All personnel are not permitted to obtain information on the competition or competitive data through bribes and kickbacks.

3 - Work Quality and Safety Ethic

• All personnel shall carry out their duties in the company in compliance with the technical standards set forth by the company, the regulatory agencies, and the original equipment manufacturers.

• All personnel shall apply the Six Working Principles when working in the company to perpetuate quality in workmanship and aircraft safety, both on the air as well on as the ground.

• All personnel shall adhere to processes and procedures to carry out their maintenance tasks and business activities sequentially on a step-by-step basis. Such activities shall include making and keeping accurate, completed records.

4 - Environmental Protection and Conservation

• The company is committed to the protection of the environment and to conservation, through education, investment in pollution reducing equipment, reduction in carbon footprint, and recycling.

• All personnel are to abide by the corporate commitment in Para. 4a to work on initiatives and continuous improvement plans to reduce waste, increase recycling, conserve energy and / or resources.

5 - Mutual Respect

• Personnel are the company’s valued assets. The company endeavors to create a safe, conducive working environment based on merit.

• All personnel are work together collectively as a team for positive, timely and mutually beneficial outcomes to all parties on all business and maintenance activities. These outcomes are to be achieved through consensus building and mutual trust with one another, with suppliers and with customers.

• All personnel are not to discriminate against another individual because of race, religion, color, rank or gender.

6 - Safety Policy

• EGAT possesses a well-defined, CAA-endorsed, Safety Management System with policies, structure and processes deployed throughout the organization. Safety is both a corporate and personal commitment. Risks are evaluated on matrices based on severity of the hazard consequence and potential occurrence levels. A predictive / pro-active approach to safety risks is encouraged and increasingly adopted.

7 - Environmental Protection Through Aggressive Recycling

• EGAT is committed to a sustainable future to reduce its carbon footprint through aggressive recycling efforts. The positive upward trend in recycling measures up well with EGAT's continuing recycling efforts.