Integrity and Compliance Without Compromise

Partners are required to maintain a thorough understanding of, and to comply fully with, all applicable laws, regulations, controls, restrictions, and procedures in every jurisdiction in which they conduct business.

These obligations include compliance with:

• Trade controls and trade restraints
• Marketing, advertising, and promotional practices
• Antitrust and fair competition laws
• Insider trading restrictions
• Anti-corruption laws (FCPA, UK Bribery Act)
• Data protection and privacy laws
• Environmental protection requirements

VLC Solutions maintains a strict zero-tolerance approach toward bribery and corruption. Partners must conduct business in a manner that ensures full compliance with all applicable anti-bribery and anti-corruption laws.

Partners must not offer, promise, authorize, provide, solicit, or accept any payment, gift, benefit, or thing of value to or from any individual or official for the purpose of obtaining business or securing improper advantage.

VLC Solutions is committed to conducting business in an ethical, lawful, and principled manner. Any form of corruption, coercion, fraud, extortion, or unethical conduct is strictly prohibited.

Partners must not seek to gain an unfair advantage through the misuse of confidential information, misrepresentation of material facts, omission of critical information, or engagement in deceptive practices.

VLC Solutions complies with all applicable trade laws, economic sanctions programs, and export control regulations. Partners represent, warrant, and agree that they will not sell, export, re-export, transfer, or make available any VLC Solutions products to:

• Parties subject to UN, EU, or UK sanctions
• Denied Parties List or Entity List parties
• OFAC designated entities
• Countries under comprehensive sanctions (Cuba, Iran, North Korea, Syria, Crimea)

Partners are strictly prohibited from participating in, supporting, or facilitating any unsanctioned boycott, including the Arab League Boycott. This prohibition applies whether participation is direct or indirect.

Partners must not include or agree to any contractual language that would restrict VLC Solutions' business relationships based on unsanctioned boycott requirements. Any such provisions shall be deemed null and void.

Partners are evaluated based on objective business criteria only. Charitable activities do not influence business decisions or supplier selection.

VLC Solutions' general policy is not to make political contributions or use company funds to support political candidates, PACs, or lobbying organizations. Partners must not make political contributions on behalf of VLC Solutions.

A conflict of interest arises when personal, financial, or external interests interfere with professional responsibilities. Partners must promptly disclose any actual, potential, or perceived conflict of interest.

Partners agree to avoid activities that could reasonably give rise to a conflict of interest, including relationships where VLC Solutions employees serve as officers or directors of Partner organizations.

Partners agree to take appropriate measures to protect VLC Solutions' Confidential Information. Safeguards must be equivalent to those used to protect their own confidential information, but in no event less than reasonable care.

Partners must immediately notify VLC Solutions of any unauthorized use or disclosure and cooperate fully to mitigate harm and prevent further unauthorized use.

Partners must maintain appropriate controls to ensure that VLC Solutions' intellectual property is not improperly used, disclosed, or infringed upon. NDAs may be required prior to exchanging confidential information.

Partners represent and warrant that any materials provided do not infringe third-party rights. Unauthorized use of VLC Solutions' name, logos, or trademarks is prohibited without prior written approval.

When marketing on behalf of VLC Solutions, Partners must comply with all applicable marketing, advertising, and communications laws including the Lanham Act, CAN-SPAM Act, and TCPA.

Partners must comply with all applicable antitrust laws. Partners must not enter into agreements with competitors regarding pricing, terms of trade, production levels, market allocation, or exchange competitively sensitive information.

Partners with access to material, non-public information about VLC Solutions must not trade securities while in possession of such information, nor disclose it to others who may trade based on that information. Tipping or facilitating insider trading is strictly prohibited.