Ethos CODE OF CONDUCT

Gifts and Entertainment Disclosure Form

Managing Gifts and Entertainment Responsibly At Ethos, we understand that giving and receiving gifts or entertainment can be a common part of doing business. However, it's important to ensure that these exchanges don't create a conflict of interest or suggest anything improper. That's why we expect all employees to follow our guidelines for managing gifts and entertainment, and to avoid any actions that could be perceived as unethical or give us an unfair advantage. We also have guidelines for political contributions and entertaining politicians and government officials. For more information, please review our policies on gifts and entertainment.

Anti-Corruption and Bribery Policy

Refusing to take bribes or pay kickbacks

I am hiring a vendor to work for Ethos, and they want a flat fee for their services. Do I still need an itemized invoice?

Ethos has a zero-tolerance policy towards bribery and corruption.All employees and representatives are responsible for understanding and complying with our policies, the Foreign Corrupt Practices Act, and applicable local anti-bribery and anti-corruption laws. We are committed to conducting our business with integrity and refuse to take or offer bribes or kickbacks.

Yes, even for fixed-rate services, it is essential to obtain an itemized invoice. This helps us understand and account for how our money is being spent, ensuring transparency and proper financial management.

Ethos recognizes the importance of protecting the integrity of the global financial system from money laundering, terrorist financing, and other financial crimes. The company will comply with all applicable governmental requirements that have been designed to prohibit and prevent both actual and potential money laundering, as well as other activities that facilitate money laundering, the funding of terrorist activity, and other financial crime. Ethos will not knowingly deal with proceeds from unlawful activity or that support terrorist activities. Ethos will not deal with individual’s, entities, or restricted countries designated by the U.S Department of Treasury Office of Foreign Assets Control (“OFAC'') and similar applicable sanctions regulations in other countries where the company operates. Preventing Money Laundering

Anti-Money- Laundering and Trade & Economic Sanctions Policy.

12

Made with FlippingBook - professional solution for displaying marketing and sales documents online