1. Purpose

This Ethics & Compliance Policy establishes the principles and expectations that guide business conduct throughout Sunol Tech LLC. The policy supports compliance with applicable laws, regulations, contractual obligations, and ethical business standards.

2. Scope

This policy applies to:

• Employees
• Officers and managers
• Contractors and consultants
• Temporary workers
• Suppliers and vendors
• Business partners and representatives

3. Our Core Values

4. Compliance with Laws

Sunol Tech LLC expects all personnel to comply with all applicable local, state, federal, and international laws governing our business activities.

• Export controls and trade regulations
• Privacy and data protection laws
• Labor and employment regulations
• Competition and antitrust laws
• Anti-corruption laws
• Cybersecurity and information security requirements

5. Conflicts of Interest

Employees and representatives must avoid situations where personal interests could improperly influence business decisions.

Any actual, potential, or perceived conflict of interest should be disclosed promptly to management.

6. Anti-Bribery and Anti-Corruption

Sunol Tech LLC prohibits bribery, kickbacks, improper payments, and corrupt business practices in any form.

Business decisions must be based on merit, quality, value, and legitimate commercial considerations.

7. Fair Competition

We compete fairly and ethically in the marketplace.

• No price fixing
• No bid rigging
• No anti-competitive agreements
• No deceptive business practices

8. Human Rights and Workplace Conduct

We support human rights and maintain a workplace free from discrimination, harassment, retaliation, violence, and exploitation.

• Equal opportunity employment
• Respectful workplace behavior
• No forced labor
• No child labor
• Safe working conditions

9. Confidential Information

Employees and business partners must protect confidential, proprietary, and sensitive information belonging to Sunol Tech LLC, customers, suppliers, and other stakeholders.

Information should only be accessed and disclosed when authorized and necessary for legitimate business purposes.

10. Information Security

Sunol Tech LLC is committed to protecting information assets through appropriate cybersecurity, access controls, security monitoring, and risk management practices.

Employees are expected to follow established security policies and promptly report security concerns.

11. Accurate Records and Reporting

Business records, financial information, contracts, reports, invoices, and communications must be accurate, complete, and truthful.

Falsification of records or misleading reporting is strictly prohibited.

12. Environmental Responsibility

We support environmentally responsible business practices and encourage sustainable operations, resource conservation, and regulatory compliance.

13. Supplier and Partner Expectations

We expect suppliers and business partners to operate ethically and comply with applicable laws and standards, including those related to labor practices, human rights, anti-corruption, and environmental responsibility.

14. Reporting Concerns

Employees, suppliers, customers, and stakeholders are encouraged to report suspected violations of laws, regulations, company policies, or ethical standards.

Reports may include concerns involving:

• Fraud
• Corruption
• Harassment
• Discrimination
• Security incidents
• Human rights concerns
• Regulatory violations

15. Non-Retaliation Policy

Sunol Tech LLC prohibits retaliation against anyone who raises concerns, reports misconduct, or participates in investigations in good faith.

16. Investigations

Reported concerns may be reviewed and investigated appropriately. Violations may result in disciplinary action, termination of employment or contracts, legal action, or referral to regulatory authorities.

17. Training and Awareness

Sunol Tech LLC may provide compliance training, awareness programs, and educational resources to support ethical conduct and legal compliance.

18. Governance and Oversight

Management is responsible for supporting compliance efforts, promoting ethical behavior, and maintaining a culture of integrity throughout the organization.

19. Policy Review

This Ethics & Compliance Policy may be reviewed periodically and updated to reflect changes in laws, regulations, business practices, and organizational requirements.

20. Contact Information