| Document | Human Rights Policy Statement |
| Issued by | Foxtrot LLC (Arizona, United States) | EIN 85-3091805 |
| Version | 1.0 |
| Effective date | 10 September 2026 |
| Approved by | Founder and Managing Member |
| Next review | Annually, or upon material change to operations |
1. Purpose and Commitment
Foxtrot LLC respects internationally recognised human rights in everything it does. This statement sets out the standards the company holds itself to, the standards it expects of the people and businesses it works with, and how it identifies, prevents and addresses adverse human rights impacts connected to its activities.
Foxtrot LLC is a technical services and software company serving the commercial aviation sector. Its work consists of engineering and airworthiness services, technical representation, records and asset inspection, and the development and licensing of software. The company does not manufacture goods, operate production facilities, or extract raw materials. Its human rights risk profile is accordingly low, but the commitment set out here is unconditional and applies regardless of scale.
2. Scope
This policy applies to the company, its officers and members, all employees, and all contractors, consultants and temporary personnel engaged by the company, wherever they are located and whatever the duration of the engagement. It also sets the expectations the company applies to its suppliers, subcontractors, agents and other business partners, including those in its extended supply chain.
3. Standards and Frameworks
This policy is informed by and aligned with the following instruments:
- The United Nations Universal Declaration of Human Rights.
- The United Nations Guiding Principles on Business and Human Rights.
- The International Labour Organization Declaration on Fundamental Principles and Rights at Work, and the ILO core conventions, including those addressing forced labour, child labour, discrimination, freedom of association and collective bargaining.
- The OECD Guidelines for Multinational Enterprises on Responsible Business Conduct.
- The United Nations Global Compact principles on human rights and labour.
Where local law sets a lower standard than these instruments, the company applies the higher standard to the extent permitted by law. Where local law conflicts with them, the company seeks ways to honour the principles of internationally recognised human rights without breaching applicable law.
4. Governance and Accountability
Accountability for this policy sits with the Founder and Managing Member of Foxtrot LLC, who owns human rights due diligence, approves this policy, oversees its implementation, and is the designated point of contact for human rights matters. Given the size of the company, this responsibility is held directly rather than delegated to a committee. As the company grows, a named human rights officer will be appointed and this policy updated accordingly.
5. Commitments
Foxtrot LLC commits to the following, and expects the same of its business partners.
Forced labour, modern slavery and human trafficking
The company prohibits forced, bonded, indentured and involuntary prison labour, and any form of human trafficking, in its own operations and in its supply chain. No worker is required to surrender identity documents, pay recruitment fees, or lodge deposits as a condition of employment. All employment is entered into freely and workers are free to leave on reasonable notice.
Child labour and young workers
The company does not employ anyone below the applicable minimum working age or below the age of completion of compulsory schooling, and in no case below fifteen years. It does not engage anyone under eighteen in hazardous work. It expects the same of its suppliers and subcontractors.
Non-discrimination, harassment and dignity at work
The company does not discriminate on the basis of race, colour, ethnicity, national or social origin, religion or belief, sex, gender identity, sexual orientation, age, disability, marital or family status, political opinion, union membership, or veteran status. Recruitment, pay, training, promotion and termination decisions are based on ability and performance. Harassment, bullying, intimidation, retaliation, corporal punishment and any form of physical or verbal abuse are prohibited.
Health and safety
The company provides a safe working environment and complies with applicable occupational health and safety law. Because much of its work is carried out at customer, maintenance and airport facilities, personnel are briefed on and comply with the site safety rules of the host organisation, and are equipped and trained for the tasks assigned to them. Personnel have the right and the obligation to stop work they reasonably believe to be unsafe, without fear of reprisal.
Freedom of association and collective bargaining
The company respects the right of workers to form and join trade unions and worker representative bodies of their choosing, to bargain collectively, and to engage in lawful industrial action, without discrimination, reprisal or interference. Where these rights are restricted by law, the company does not obstruct alternative lawful means of worker representation.
Wages, benefits and working hours
The company pays at least the applicable legal minimum or prevailing industry wage, whichever is higher, together with all legally mandated benefits, and pays in full and on time. Wage deductions as a disciplinary measure are prohibited. Working hours, rest periods and leave comply with applicable law, and with aviation duty and rest limitations where these apply. Terms of engagement are documented in writing in a language the worker understands.
Privacy and data protection
The company handles personal data of employees, customers and end users lawfully, proportionately and securely, and designs its software products so that personal data is collected only where there is a legitimate operational purpose. It does not build or supply capabilities intended for unlawful surveillance of individuals.
Land rights, communities and security arrangements
The company does not acquire, use or develop land in a way that deprives any person of the basis of their livelihood, and does not engage private or public security forces. Should it ever do so, it will require that any such arrangement respects the prohibition on torture, cruel or degrading treatment, and on injury to life or limb, and complies with the Voluntary Principles on Security and Human Rights.
Environment-related human rights
The company complies with applicable environmental law and with the obligations of the Minamata Convention on mercury, the Stockholm Convention on persistent organic pollutants, and the Basel Convention on the transboundary movement of hazardous waste, insofar as they apply to its activities. It does not cause harmful soil change, water or air pollution, harmful noise emission or excessive water consumption that would impair a person’s health, food production or access to safe drinking water.
6. Business Partners and Supply Chain
Foxtrot LLC expects its suppliers, subcontractors, agents and business partners to meet the standards in this policy and to hold their own suppliers to equivalent standards. These expectations are communicated at the point of engagement and, where appropriate, reflected in contract terms. The company takes account of a partner’s human rights conduct when awarding and renewing work.
Where the company becomes aware that a business partner has caused or contributed to an adverse human rights impact, it will raise the matter, seek corrective action within a reasonable timeframe, and, if the partner is unwilling to remedy a severe violation, suspend or terminate the relationship.
7. Risk Analysis and Due Diligence
The company carries out a human rights risk analysis of its own operations and its direct suppliers at least annually, and on an ad hoc basis when it enters a new market, engages a new category of supplier, takes on a materially different type of work, or receives substantiated information suggesting a risk in its extended supply chain. The analysis considers the nature of the activity, the country in which it is performed, and the sector of the counterparty. Identified risks are prioritised by severity, likelihood and the company’s ability to influence the outcome, and preventive measures are assigned and tracked.
8. Reporting Concerns
Anyone, whether or not connected to Foxtrot LLC, may report a suspected human rights or labour standards violation relating to the company or its supply chain by writing to compliance@foxtrotllc.com. Reports may be made in any language and may be submitted anonymously.
Reports are received and reviewed by the Founder and Managing Member. The company acknowledges receipt, discusses the facts with the person who raised the concern where contact is possible, investigates proportionately, and communicates the outcome. The identity of anyone raising a concern is protected, and retaliation of any kind against a person who reports in good faith or who participates in an investigation is prohibited and is itself a violation of this policy.
9. Remediation
Where Foxtrot LLC has caused or contributed to an adverse human rights impact, it will provide for or cooperate in remediation. Remedial action is proportionate to the severity of the impact and may include correcting the practice, compensating those affected, changing a process or contract term, ending an engagement, or reporting the matter to the relevant authority. Any violation within the company’s own operations is ended immediately.
10. Training and Communication
This policy is provided to every employee and contractor at the start of their engagement and is available to customers, suppliers and the public on request. Personnel receive guidance appropriate to their role on recognising and reporting human rights and labour standards concerns.
11. Documentation and Review
The company documents its risk analyses, preventive measures, reports received and remedial actions taken, and retains that documentation for at least seven years. This policy is reviewed at least annually by the Founder and Managing Member, and revised where the review, a substantiated report, or a change in the company’s operations or in applicable law makes revision necessary.
12. Approval
This policy is adopted on behalf of Foxtrot LLC and takes effect on the date shown above.
Farshad Mohammadi
Founder and Managing Member
Foxtrot LLC
Date: 10 September 2026