General Policies & Procedures

1. Code of Business Ethics and Conduct

1.1 Ethical Standards

PDI conducts all business activities with honesty, integrity, and in compliance with applicable laws and regulations. Our ethical standards include:

• Honesty: Truthful and accurate representation in all business dealings
• Integrity: Adherence to moral and ethical principles in all circumstances
• Fairness: Equitable treatment of all stakeholders
• Respect: Dignity and respect for all individuals
• Accountability: Responsibility for actions and decisions

1.2 Conflicts of Interest

Employees and representatives must avoid situations where personal interests conflict with PDI's interests. All potential conflicts must be disclosed to management and resolved appropriately.

1.3 Anti-Corruption and Anti-Bribery

PDI strictly prohibits bribery, kickbacks, and corrupt practices in any form. We comply with the U.S. Foreign Corrupt Practices Act (FCPA) and all applicable anti-corruption laws.

2. Government Contracting Compliance

2.1 Federal Acquisition Regulations

PDI complies with all applicable Federal Acquisition Regulations (FAR) and Defense Federal Acquisition Regulation Supplement (DFARS) requirements in government contracting activities.

2.2 Procurement Integrity

We maintain strict procurement integrity in all government contracting activities, including:

• Prohibition on obtaining or disclosing contractor bid or proposal information
• Prohibition on obtaining or disclosing source selection information
• Compliance with organizational conflict of interest requirements
• Accurate cost and pricing data submissions

2.3 Truthful Cost or Pricing Data

PDI certifies the accuracy, completeness, and currency of cost or pricing data submitted in connection with government contracts as required by the Truth in Negotiations Act (TINA).

2.4 Small Business Subcontracting

PDI supports small business participation in government contracting and maintains small business subcontracting plans in compliance with applicable requirements.

3. Security Policies

3.1 Facility Security

PDI maintains appropriate physical security measures to protect personnel, facilities, and assets. Access to PDI facilities is controlled and monitored.

3.2 Information Security

We implement comprehensive information security controls to protect sensitive data, including:

• Access controls and authentication requirements
• Encryption of sensitive data in transit and at rest
• Regular security assessments and penetration testing
• Incident response and breach notification procedures
• Employee security awareness training

3.3 Cybersecurity

PDI complies with NIST 800-171 requirements for protecting Controlled Unclassified Information (CUI) and is committed to achieving Cybersecurity Maturity Model Certification (CMMC) compliance.

3.4 Personnel Security

Employees with access to classified or sensitive information undergo appropriate background investigations and maintain required security clearances.

4. Export Compliance Program

4.1 ITAR Compliance

PDI is registered with the U.S. Department of State Directorate of Defense Trade Controls (DDTC) and complies with the International Traffic in Arms Regulations (ITAR) for defense articles and services.

4.2 EAR Compliance

We comply with the Export Administration Regulations (EAR) administered by the Bureau of Industry and Security (BIS) for dual-use items.

4.3 Sanctions Compliance

PDI complies with economic sanctions administered by the Office of Foreign Assets Control (OFAC) and does not engage in prohibited transactions with sanctioned parties or countries.

4.4 Export Screening

All transactions involving foreign parties are screened against applicable denied party lists and restricted entity lists.

5. Employment Policies

5.1 Equal Employment Opportunity

PDI is an equal opportunity employer. We do not discriminate on the basis of race, color, religion, sex, national origin, age, disability, genetic information, veteran status, or any other protected characteristic.

5.2 Harassment-Free Workplace

PDI maintains a workplace free from harassment, including sexual harassment. All complaints are investigated promptly and appropriate corrective action is taken.

5.3 Workplace Safety

We are committed to providing a safe and healthy work environment in compliance with OSHA and applicable safety regulations.

5.4 Drug-Free Workplace

PDI maintains a drug-free workplace in compliance with the Drug-Free Workplace Act and applicable regulations for government contractors.

6. Quality Management

6.1 Quality Policy

PDI is committed to delivering products and services that meet or exceed customer requirements and applicable standards. Our quality management system is designed to ensure consistent quality and continuous improvement.

6.2 Quality Standards

We maintain quality management systems aligned with:

• ISO 9001:2015 Quality Management Systems
• AS9100D Aerospace Quality Management Systems
• Applicable military specifications and standards

6.3 Counterfeit Parts Prevention

PDI implements counterfeit parts prevention procedures in compliance with DFARS requirements to ensure the authenticity and reliability of components used in our products.

7. Environmental, Health & Safety

7.1 Environmental Compliance

PDI complies with all applicable environmental laws and regulations and is committed to minimizing our environmental impact through responsible business practices.

7.2 Sustainability

We incorporate sustainability considerations into our operations and product development, including energy efficiency, waste reduction, and responsible materials sourcing.

8. Reporting and Whistleblower Protection

8.1 Reporting Violations

Employees and stakeholders are encouraged to report suspected violations of law, regulation, or company policy. Reports may be made to:

• Direct supervisors or management
• Human Resources Department
• Legal/Compliance Department
• Ethics Hotline (anonymous reporting available)

8.2 Non-Retaliation

PDI prohibits retaliation against any individual who reports suspected violations in good faith. Retaliation will result in disciplinary action up to and including termination.

8.3 Investigation Process

All reports of suspected violations are investigated promptly and thoroughly. Appropriate corrective action is taken based on investigation findings.

9. Supplier and Partner Requirements

PDI expects suppliers and business partners to maintain ethical standards and compliance programs consistent with our own. Key requirements include:

• Compliance with applicable laws and regulations
• Ethical business practices and anti-corruption compliance
• Appropriate quality management systems
• Information security and data protection measures
• Export control compliance
• Respect for human rights and fair labor practices