CODE OF ETHICS

ThermTech’s directors, employees, and officers are committed to conducting business following the highest ethical standards. This Code of Ethics established policies that embody these standards.

Interpersonal Ethics

ThermTech expects all employees to deal with all employees, customers, and vendors with dignity and respect. ThermTech’s Values Statement outlines the ethical responsibilities of employees and the actions taken where ethical shortcomings occur.

Employee and Visitor Safety

ThermTech takes the health and safety of all employees and visitors seriously and enacts policies and procedures to ensure a safe and healthy work environment. ThermTech utilizes a Health and Safety Manual to guide the safety, health, and environmental concerns. ThermTech uses a safety concern system to communicate health and safety issues among employees and management to improve the health and safety system continually.

Safety-Related Components

ThermTech processes safety-related components, understanding that all material passing through ThermTech is essential to our customers and may be safety-critical to the end user. Acknowledging that means ThermTech has an ethical and professional responsibility to meet customer requirements and ensure product quality and safety.

Fair Dealing

ThermTech employees should deal fairly with the Company’s customers, suppliers, competitors, and employees. No employee should take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any other unfair dealing practice.

Conflicts of Interest

Employees should report any personal interests or obligations that could conflict with the conscientious performance of their duties or create any suspicion or perception that decisions they make for the Company might be improperly influenced by their interests. Employees and directors are prohibited from (a) taking for themselves personal opportunities discovered through the use of Company property, information, or position; (b) using Company property, information, or position for personal gain; and (c) competing with the Company. Employees and directors owe a duty to the Company to advance its legitimate interests when the opportunity arises. They should not accept gifts or favors that could compromise their loyalty. Employees should always report potential conflicts of interest to supervisors.

Protection of Company Assets

All ThermTech employees should protect the Company’s assets and ensure efficient use. Theft, carelessness, and waste directly impact the Company’s profitability. All Company assets should be used for legitimate business purposes.

Confidential Information

ThermTech provides heat-treating services to organizations that provide ThermTech access to sensitive and proprietary information. Proper management of confidential information by employees and directors is essential to the Company. Loyalty to the Company includes a commitment not to use or give to others trade secrets or confidential information belonging to the Company or to others with whom the Company does business. Confidential information includes any information not known to outsiders that has value to the Company or whose premature disclosure would help competitors or harm the Company. ThermTech’s cybersecurity program details the protection of proprietary information.

Integrity and Disclosures

Employees and directors will meet all communications’ highest honesty, truthfulness, and integrity standards. The requirement applies to all our dealings as a Company and in our relationships. We will abide by the laws mandated by the government. The Company will provide a working environment in which adherence to these high standards occurs from all employees, and pressures for immediate success never compromise integrity. The Company’s accounting and financial records must be valid, accurate, and complete, with all transactions accurately and promptly recorded in the Company’s books. The chief Executive officer, the chief financial ffficer, and other senior financial officers of the Company shall foster practices and procedures that ensure compliance with all applicable laws and regulations.

Reporting Violations of the Code or Applicable Law

If employees become aware of actions violating this Code or applicable laws, rules, and regulations, they should contact any member of management to address the issue.