Code of Business Conduct

This Code of Business Conduct establishes the ethical and legal standards that govern the conduct of all personnel associated with Monarch Space Systems, Inc. It reflects our commitment to integrity, lawful compliance, and institutional responsibility in all aspects of our business.

As an aerospace engineering organization engaged in propulsion technology research and U.S. Government contracting, we recognize our heightened obligation to maintain the trust of government agencies, prime contractors, international partners, and the public.

This Code applies to all employees, officers, directors, consultants, contractors, and any person acting on behalf of Monarch Space Systems. It applies to all activities conducted in connection with company business, regardless of location or medium.

All personnel are required to comply with applicable laws and regulations, including but not limited to federal acquisition regulations, export control laws, employment laws, environmental regulations, and data protection requirements. Ignorance of the law is not a defense for non-compliance.

Personnel engaged in government contracting activities shall comply with all applicable provisions of the Federal Acquisition Regulation (FAR), Defense FAR Supplement (DFARS), and agency-specific supplements. This includes requirements for procurement integrity, truthful representations, accurate cost data, and timely disclosure of potential violations.

Monarch Space Systems strictly prohibits bribery, kickbacks, and corrupt payments in any form. All personnel must comply with the Foreign Corrupt Practices Act (FCPA), the Anti-Kickback Act, and applicable provisions of the OECD Anti-Bribery Convention. This prohibition applies to dealings with government officials, private parties, and international partners.

Personnel must avoid situations where personal interests conflict, or may appear to conflict, with the interests of Monarch Space Systems or its government customers. Potential conflicts must be disclosed promptly to compliance leadership for evaluation and, where necessary, mitigation.

All proprietary, confidential, and government-furnished information must be protected in accordance with applicable regulations, contractual requirements, and company policies. This includes Controlled Unclassified Information (CUI), source selection information, and trade secrets.

Personnel must be aware that certain technical data, software, and defense articles are subject to export control regulations, including the International Traffic in Arms Regulations (ITAR) and the Export Administration Regulations (EAR). Unauthorized disclosure or transfer of controlled items is prohibited.

Monarch Space Systems maintains accurate and complete books, records, and accounts that reflect all transactions and dispositions of assets. Falsification of records, misrepresentation of costs, or concealment of information is strictly prohibited.

Monarch Space Systems competes fairly and ethically for all business opportunities. Personnel shall not engage in bid rigging, price fixing, market allocation, or any practice that violates antitrust laws or procurement integrity statutes.

Monarch Space Systems maintains a professional work environment free from harassment, discrimination, and intimidation. Retaliation against any person who reports a concern in good faith, participates in an investigation, or exercises rights under federal whistleblower protections is strictly prohibited.

Personnel who become aware of potential violations of this Code, company policy, or applicable law are required to report them promptly. Reports may be made to a direct supervisor, the compliance officer, or through an anonymous reporting mechanism. All reports are taken seriously, investigated promptly, and treated with appropriate confidentiality.

Violations of this Code may result in disciplinary action up to and including termination of employment or contractual relationship. Certain violations may also result in civil or criminal liability. Disciplinary measures are applied consistently and proportionally.

Monarch Space Systems leadership bears a heightened responsibility to model ethical conduct, promote compliance, ensure adequate resources for ethics programs, and foster a culture where personnel feel empowered to raise concerns without fear of retaliation.