Suppliers

BSC Filters Ltd SUPPLIER CODE OF CONDUCT Dover Corporation, its segments, platforms, operating companies and subsidiaries worldwide (collectively, “Dover”) understand that our success depends on our reputation for ethical business performance and performing our jobs honestly, diligently and with integrity, in compliance with all applicable laws and regulations. Consistent with our commitment to conduct business fairly and honestly, we seek out business partners who share in our culture, values and business practices. This Supplier Code of Conduct (this “Supplier Code”) is an extension of the Dover Corporation Code of Business Conduct and Ethics (the “Dover Code,” and establishes the standards for conducting business with BSC Filters Ltd. For the purposes of this Supplier Code, “Supplier” means any company, corporation or other entity or person that sells, or seeks to sell, goods or services to BSC Filters Ltd, including the Supplier’s employees, agents, subcontractors and other sub-tier sources. Supplier is responsible for communicating the contents of this Supplier Code of Conduct to its officers, directors, employees, agents, subcontractors and sub-tier sources who are involved in the procurement and production process related to products and services provided to BSC Filters Ltd.

COMPLIANCE WITH LAWS AND REGULATIONS BSC Filters Ltd does business throughout the world. Because of BSC Filters Ltd global presence, a Supplier must comply with all laws and regulations applicable to its business in the countries where it does business, including all laws and regulations relating to each subject matter below. The Supplier must recognize that BSC Filters Ltd obligations and requirements extend to all countries where BSC Filters Ltd does business and that in some cases, BSC Filters Ltd - and its suppliers - are required to conduct business in accordance with the laws of other countries in which BSC Filters Ltd operates.

CHILD LABOUR AND FORCED LABOUR Supplier will not intentionally source materials from supply chains associated with human trafficking and will take reasonable efforts to assure that its own suppliers comply with this requirement. Supplier must comply with all applicable local laws with respect to child labor. In the absence of such laws or in the event existing laws permit the hiring of a person younger than 15 years of age, the minimum age for employment or work by Supplier will be 15 years of age or the age for completing compulsory education in that country, whichever is higher. Supplier must not use forced, bonded, involuntary, prison or indentured labor.

WAGES AND WORKING HOURS Supplier must comply with all applicable local laws with respect to wage and hour laws, including those relating to minimum wages, overtime hours, and other elements of compensation, and will provide all legally mandated benefits. Supplier will not require employees to work more than the maximum number of hours permitted under applicable laws.

FREEDOM OF ASSOCIATION Supplier must respect workers’ rights to associate freely, in compliance with existing local laws and without intimidation, reprisal or harassment. Workers’ rights under local laws to join labor unions, seek representation and/or join worker’s councils should be acknowledged by Supplier.

DISCRIMINATION Supplier must not discriminate against any worker in its hiring and employment practices based on race, color, religion, disability, national origin, gender, sexual orientation, marital status, age or other characteristic protected by local law. Supplier must not discriminate against any worker based on political affiliation or union membership in its hiring and employment practices. Supplier will not require a pregnancy test prior to employment or otherwise require workers or potential workers to undergo medical tests that could be used in a discriminatory way, except where required by applicable laws, or where prudent for workplace safety. F

AIR TREATMENT Supplier will treat its workers with dignity and respect. Supplier will maintain a workplace free of harassment and discrimination and shall not threaten workers or subject them to harsh or inhumane treatment, including sexual harassment, sexual abuse, corporal punishment, mental or physical coercion or verbal abuse.

HEALTH AND SAFETY Supplier will conduct its operations in compliance with applicable health and safety laws and regulations and provide its workers with a safe and healthy work environment. Where Supplier also provides accommodations for its workers, such accommodations shall be appropriate for its location and be clean, safe and, at a minimum, meet the basic needs of its workers.

ENVIRONMENT Supplier will comply with all applicable environmental laws, regulations and standards and minimize any adverse impact on the environment. Supplier must endeavor to conserve natural resources and energy, and reduce or eliminate waste and the use of hazardous substances.

CONFLICT MINERALS Supplier will cooperate in due diligence requests made by BSC Filters Ltd with respect to the origin of intermediaries associated with the purchases of materials or products containing Conflict Minerals, whether or not those materials or products may have been mined or produced in the Covered Countries or obtained from recycled sources, in compliance with BSC Filters Ltd reporting requirements under the US Dodd-Frank Section 1502. Where specified in a purchase order or supply agreement, Supplier will comply with any BSC Filters Ltd requirement to provide products, components, parts and materials which are free of Conflict Minerals mined or produced in the Covered Countries in support of armed conflict in the region. “Conflict Minerals” are tin (Cassiterite), tungsten (Wolframite), tantalum (Columbite-tantalite or coltan) and gold, and the derivative metals from these minerals. The “Covered Countries” are the Democratic Republic of the Congo, Angola, Burundi, Central African Republic, The Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda and Zambia.

FAIR DEALING AND COMPETITION LAWS Supplier will not engage in collusive bidding, price fixing, price discrimination or other unfair trade practices in violation of applicable antitrust or competition laws. Supplier will uphold fair business standards in advertising, sales and competition.

PROTECTION OF INTELLECTUAL PROPERTY Supplier must respect intellectual property rights, including patents, trademarks, copyrights and process designs, and safeguard BSC Filters Ltd confidential and proprietary information. Any transfer or sharing of technology or know-how must be done in a manner that protects intellectual property rights and is in compliance with local laws, including export laws, concerning data privacy and security.

DATA PRIVACY AND SECURITY Supplier will comply with all local laws concerning data security and privacy, and will protect and safeguard data provided by BSC Filters Ltd, which may include private and sensitive personal information. Any transfer or sharing of data must be done in a manner that protects such information from inadvertent or unauthorized disclosure and any disclosure must be in compliance with local laws. IMPROPER PAYMENTS Supplier is prohibited from engaging in any corruption, extortion or embezzlement, in any form. Supplier must comply with all applicable anti-corruption laws and regulations of the countries in which they operate, the U.S. Foreign Corrupt Practices Act, the UK Anti-Bribery Act, the OECD Anti-Bribery Convention and any international anti-corruption conventions. Supplier will not offer or accept bribes or employ other means to obtain an undue or improper advantage. Bribes, kickbacks, facilitating payments and similar payments to government officials or to BSC Filters Ltd employees or agents acting on BSC Filters Ltd behalf are prohibited. BSC Filters Ltd employees are discouraged from accepting gifts or entertainment from suppliers, including gifts or entertainment of nominal value. When business meals are appropriate to further business relationships, those meals may not be extravagant in nature. BSC Filters Ltd is required to maintain a register of gifts and hospitality received and offered.

MONITORING AND RECORD KEEPING Supplier must maintain all documentation necessary to demonstrate its compliance with this Supplier Code and provide BSC Filters Ltd with access to those documents upon BSC Filters Ltd request for review. Neither BSC Filters Ltd nor any of its affiliates or authorized agents assumes any obligation or duty to monitor or ensure compliance with this Supplier Code. Supplier is solely responsible for compliance with this Supplier Code by its officers, directors, managers, employees, representatives and agents. BSC Filters Ltd March 2014.

Dow-Key Microwave – a Microwave Products Group company and a subsidiary of Dover Corporation – is committed to the highest ethical standards and to conducting business with the highest level of integrity. These values drive our behavior as we aspire to earn and keep the respect and trust of our shareholders, customers and employees.

The documents adopted by the Board of Directors and its committees set forth the principles for the governance of our activities.

Dover’s Code of Business Conduct & Ethics, which is evaluated and updated on a regular basis, embodies high ethical standards and provides the framework for our conduct, our interactions with others, and our decision-making. The Code applies to all of our employees, regardless of location, position or operating company, and is published in 18 different languages. It is the foundation on which our ethics and compliance policies are built and together, the Code and our policies represent a significant element of our ethics and compliance program.

Transparency in Supply Chain Disclosure

Quality PO Requirements

Purchase Order Terms and Conditions

PS-1 Approved Plating Process Specification

Espy’s products and services are ITAR controlled and require authorization by the U.S. Department of State prior to export.

Please check back periodically for updates to this page.

K&L Microwave, Inc. designs and manufactures a complete line of RF and microwave filters, duplexers and integrated assemblies. K&L offers customers the most extensive range of filter-based products in the industry. Supplying quality parts to our customers is a top priority at K&L and the Supply Chain plays a key role in making that happen. K&L’s Supply Chain Strategy is to develop a global supply chain process that focuses on product excellence with our suppliers of choice. Providing defect-free products every time is one of the main goals of the supply chain.

In order to achieve this goal, K&L needs the support of all our suppliers. We select suppliers who are capable of continually providing process, system, and organization improvements, as well as defect-free products and services. We believe that it is the supplier’s responsibility to provide product, material, and service with consistently high and ever improving quality, and to demonstrate conformance and control. Our Quality Policy (listed in our Supplier Policy Manual referenced below) reinforces the focus and commitment to quality. We expect our suppliers to share our mission and commitment toward quality and take steps to ensure processes are set up to achieve these goals.

The following downloadable documents are provided to our suppliers in an effort to define the Purchasing and Quality requirements necessary to ensure a successful partnership between K&L Microwave and our suppliers.

Supplier Policy Manual: The Supplier Policy Manual documents the required quality standards for products and services purchased from suppliers, and outlines K&L’s overall expectations.

Confidentiality Agreement: Completion and return of the Non-Disclosure Agreement form to K&L establishes a confidentiality agreement between K&L and the recipient for confidential and proprietary information shared between the two parties.

Supplier Self-Evaluation Form: K&L is dedicated to providing defect-free products on time to internal and external customers. Therefore, the quality of purchased and subcontracted supplies, materials and services must fully support our goals. It is the intent of K&L to buy only from those suppliers who exhibit a high degree of internal control of their manufacturing processes and who have implemented an adequate quality management system. As part of our Supplier Management Program, we need each supplier to complete document 1001147, Supplier Self-Evaluation, to assess your capabilities to satisfy our customers. It will also be used as a basis for a preliminary evaluation of your facility.

Supplier Size & Classification Certification: In order to comply with our subcontracting plan, K&L needs to verify each supplier's business size and classification. We ask your cooperation by completing and returning document 1009618, Supplier Size and Classification Certification, to K&L as promptly as possible to ensure unnecessary delays in future business transactions.

Purchase Order Quality Requirements: The Purchase Order Quality Requirements document specifies all flow down requirements. All requirements stated in the purchase order with K&L shall be flowed down to all the suppliers’ sub-tier suppliers, including any key characteristics that have been identified. The requirements provided in this document with their terms and conditions become an integral part of the purchase order and become a supplement to the presently existing terms and conditions of the purchase order.

First Article Inspection: Please review the First Article Inspection of Purchased Product document (#1022778) for guidelines to adhere to for First Article Inspection requirements.

Supplier Corrective Action Requests: Please see the K&L Microwave Quick Start Guide for Supplier Corrective Action Requests and the complete K&L Microwave Guide for Supplier Corrective Action Requests as resources.

Statement on Conflict Minerals: Please see K&L's Conflict Mineral Statement.

Counterfeit Electronic Parts Avoidance: Please see K&L's Counterfeit Electronic Parts Avoidance Plan .

Supplier Code of Conduct: Please see K&L's Supplier Code of Conduct

Waiver and Deviation Request Form Please see our Waiver and Devitation Request Form.

Bank References References will be provided upon request.

Contactor Breifing: Our Contractor Briefing presentation provides training information to contractors who will be working in or around K&L’s facilities. The presentation defines K&L’s expectations for our contractors for protecting the environment and for safeguarding K&L personnel and contractor personnel working on our company’s behalf.

Supply Management

Pole/Zero Corporation designs and manufactures a complete line of tunable filter products that are ideal for solving a variety of RF filter requirements. Our approach to business has made us one of the fastest growing companies in our field. At Pole/Zero, we know that our success in the marketplace is tied directly to our ability to design and manufacture quality products. Our goal is to set the standard for quality in the markets we serve.

To achieve this goal, we need the full cooperation and participation of the organizations that supply us with materials, components, assemblies and production-related services. We look to these selected suppliers for technological leadership in design, manufacturability, and continuous improvement. Our official Quality Policy stated following, underscores this point. We are committed to providing defect-free products and services to our customers. Because we work in cooperation with our suppliers, we expect them to adopt a commitment toward quality and customer service that is similar to our own.

The following downloadable documents are provided to our suppliers in an effort to define the Procurement and Quality requirements necessary to ensure a successful partnership between Pole/Zero Corporation and our suppliers.

Supplier Policy Manual

The Supplier Policy Manual documents the required quality standards for products and services purchased from suppliers, and outlines Pole/Zero’s overall expectations.

First Article Expectations are defined here for Pole/Zero suppliers. Helpful resources include a First Article Checklist and the required AS 9100 First Article Form.

Supplier Code of Conduct

The Supplier Code of Conduct documents the expectations of Pole/Zero (Dover) suppliers to perform their jobs honestly, diligently and with integrity, in compliance with all applicable laws and regulations.

Procurement Provisions

The Procurement Provisions document specifies all flow down requirements. All requirements stated in the purchasing agreement with Pole/Zero shall be flowed down to all the suppliers’ sub-tier suppliers, including any key characteristics that have been identified. The provisions provided in this document with their terms and conditions become an integral part of the purchase order and become a supplement to the presently existing terms and conditions of the purchase order, available here: Purchase Order Terms and Conditions.

Confidentiality Agreement

Completion and return of the Non-Disclosure Agreement (NDA) form to Pole/Zero establishes a confidentiality agreement between Pole/Zero and the recipient for confidential and proprietary information shared between the two parties.

Bank References

References will be provided upon request.

Supplier Size & Classification Certification

In order to enter your company into our supplier database, Pole/Zero needs to verify each supplier’s business size and classification. We ask your cooperation by completing and returning form PUR-032-F, “Supplier Size and Classification Certification/Recertification” to Pole/Zero as promptly as possible to ensure unnecessary delays in future business transactions.

Supplier Quality System Survey

Pole/Zero is dedicated to providing defect-free products on time to internal and external customers. Customer satisfaction, quality, and continuous improvement are the personal responsibility of each employee. To that end, the quality of purchased and subcontracted supplies, materials and services must fully support our goals. It is the intent of Pole/Zero to buy only from those suppliers who exhibit a high degree of internal control of their manufacturing processes and who have implemented an adequate quality management system. This survey will help PoleZero determine the effectiveness of your systems and will be used as a basis for a preliminary evaluation of your facility.