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Code of Ethics


Last modified: January 02, 2023

Our Principles

Compliance with laws and regulations

Our commitment: To ensure that associates act in compliance with laws and regulations.

At all times, Astran associates must comply with international, federal, state, local and professional ethics regulations relevant to their business, as well as Astran's ethics policies.

With respect to these specific rules, as a structuring element of Astran's identity, all associates must respect their substance, subject to the mandatory provisions of applicable laws.

Respect for the rights and dignity of individuals

Our commitment: To conduct our business in a manner that respects the rights and dignity of all persons.

We will strive to prevent, mitigate and remedy adverse effects on human rights in our workplace, in our business activities and in the communities in which we work. We want to protect people from abuse by those who are more powerful.

Astran believes that a sustainable company is one that combines economic development with human progress, and therefore attaches the utmost importance to the values of tolerance and respect for others, which are binding on all employees in the course of their professional activities and which govern the relationship of every Astran manager with them. Respect for others implies treating each other fairly, valuing each other equally, and calls for reciprocity, as each person has rights to assert but also duties to fulfill, towards others, his team, Astran and the company as a whole.

This principle includes respecting, in all circumstances, the rights of individuals, their dignity, their uniqueness and the respect of different cultures.

It also applies to tangible and intangible assets belonging to others and, more generally, to the preservation of heritage and the environment.

It guides Astran's policy in terms of equality men and women, respect for privacy, promotion of diversity and the fight against all forms of discrimination, protection of health and safety in the workplace and, in particular, the prevention and punishment of all situations of harassment.

Diversity and Inclusion

Our commitment: To create a diverse and inclusive environment that treats all associates with dignity and respect.

We will educate our staff about inclusion and provide all associates with equal opportunities to contribute to our company and advance their careers.

Fair Employment Practices

Our commitment: To create a safe workplace where all our associates have an equal opportunity to succeed.

We do not tolerate discrimination, harassment, retaliation, bullying or uncivil behavior. We value the contributions of all our employees and encourage them to speak freely and express their opinions in a professional manner.

Loyalty

Our commitment: To be fair.

For Astran, the quality of a relationship depends on the loyalty of the people we deal with, especially in the execution of contracts. This includes keeping commitments and not making promises that the Company cannot keep.

Each time an Astran partner communicates with its interlocutors, it does so in good faith, in a constructive spirit, respectful of the interests of each party and with a concern for sincere information.

The principle of transparency, which guides a young innovative company such as Astran, does not prevent associates from respecting business secrecy, within the framework of applicable laws. Astran, which expects its associates to respect the principles laid down in this Charter, provides them in return with the necessary protection when they are called into question, provided that they have acted in good faith within the framework of their duties.

Culture of integrity

Our commitment: To ensure that honesty and integrity govern our business relationships, interpersonal relationships and day-to-day professional practices.

It is imperative that everyone acts with honesty in all circumstances and contributes to a culture of honesty and integrity. Based on this principle, Astran attaches the highest importance to the exemplary behavior of its associates.

In the choice of its partners, Astran is careful to maintain a high standard of honesty and respect for human rights.

Consequently, Astran encourages the reporting of ethical incidents, and no associate may be sanctioned for having used, in a disinterested and good faith manner, a reporting system for such incidents, or for having refused to carry out an act that appears to be contrary to the Company's ethical principles.

Conflicts of Interest

Our Commitment: Ensure that our business judgment is not influenced by personal interests.

We will disclose and manage potential, perceived and existing conflicts of interest.

Use of Data

Our commitment: To use personal information entrusted to us responsibly.

We will adhere to our data privacy principles and ensure that our external service providers are also committed to these principles.

Information and Cybersecurity

Our commitment: Protect our data and technology and ensure that information is protected from theft, loss, misuse or disclosure.

We will take responsibility for the information and technology we handle.

Insider Trading

Our Commitment: Do not engage in insider trading.

We do not misuse insider information or other non-public information that could affect the price of Astran securities or the securities of any other company.

Professional Practices

Our Commitment: Maintaining high standards of ethical business conduct.

We are committed to the same high standards of business ethics wherever we operate.

Research and Development

Our Commitment: To conduct research and development activities for the right reasons.

We will respect the rights, safety and dignity of individuals and communities. We will ensure that any data or information we create or are responsible for is true, accurate and fair. We do not make false or misleading statements.

Managing Third-Party Risk

Our commitment: To work with third parties whose activities are consistent with our values and ethical principles.

We select the parties best suited to our business and the company based on objective criteria, highlighting their competence, integrity and other relevant merits. We will strive to ensure that, throughout our relationship, the third party continues to meet the same standards.

Our responsibilities

Meeting our commitments will require leadership from each of us. We are all personally responsible for adhering to the Astran Code of Ethics.

Violations

Violations of this Code of Ethics, as well as our policies, guidelines or local laws, will result in corrective or disciplinary action up to and including termination of employment. It is the obligation of each of us to report any actual or suspected incidents of misconduct.

Astran guarantees non-retaliation and confidentiality, to the extent legally possible, for good faith reports of such misconduct.

Every complaint is taken seriously.

Any employee who raises a potential issue of misconduct, assists or provides information during an investigation, or acts in good faith in the interest of Astran, will be protected from retaliation.

Applicability

This Code of Ethics shall be implemented by all Astran affiliates.

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