COMPANY CODE OF ETHICS AND POLICY

Policy Brief & Purpose

The Alujo Enterprises code of ethics encompasses a broad spectrum of business practices and procedures. While it may not address every possible issue, it establishes fundamental principles to guide all employees and officers. Everyone associated with Alujo Enterprises is expected to conduct themselves appropriately and avoid even the appearance of improper behavior. The Code should also be provided to and followed by Alujo Enterprises representatives. Additionally, our policies apply to various operations, and it is crucial to be familiar with and adhere to the policies relevant to your daily work.

In case of a conflict between a law and a policy in this Code, you must comply with the law. Similarly, if a local custom or policy conflicts with this Code, you must adhere to the Code. If you have any questions about such conflicts, you should consult your manager. Employees and officers are responsible for understanding the legal and policy requirements relevant to their jobs and reporting any suspected violations of the law, this Code, or Alujo Enterprises policy.

Violations of this Code will result in disciplinary action, which may include dismissal. Additionally, breaches of this Code may also constitute violations of the law, potentially leading to civil or criminal penalties for you, your supervisors, and/or Alujo Enterprises.

Scope

This policy applies to everyone we employ or have business relations with, including employees, interns, volunteers, as well as business entities like vendors, enterprise customers, or venture capital companies.

Components of Our Code of Professional Ethics:

We base our business code of ethics on common principles of ethics:

• Conflict of Interest
• Confidentiality
• Discrimination and Harassment
• Health and Safety
• Competition and Fair Dealing
• Compliance Procedures

Detailed Overview of Our Code:

Conflict of Interest

A conflict of interest arises when an individual’s private interests interfere, or appear to interfere, with the interests of Alujo Enterprises. This situation can occur if an employee or officer takes actions or has interests that make it difficult to perform their work objectively and effectively. Conflicts of interest may also occur if an employee, officer, or their family member receives improper personal benefits due to their position in Alujo Enterprises. Loans or guarantees of obligations for employees, officers, or their family members by Alujo Enterprises may create conflicts of interest and, in some cases, are prohibited by law.

Working for a competitor, customer, or supplier is a conflict of interest. Avoid any direct or indirect business connections with our customers, suppliers, or competitors unless required on our behalf.

Any employee or officer aware of a conflict or potential conflict should report it to a supervisor, manager, or other appropriate personnel.

Confidentiality

Employees and officers must maintain the confidentiality of proprietary information entrusted to them by Alujo Enterprises, its customers, or suppliers, unless disclosure is authorized in writing by management or required by law. Proprietary information includes non-public information that could be useful to competitors or harmful to Alujo Enterprises, its customers, or suppliers if disclosed. This obligation continues even after employment ends.

Discrimination and Harassment

The diversity of Alujo Enterprises employees is a valuable asset. We are committed to providing equal opportunity in all aspects of employment and will not tolerate illegal discrimination or harassment based on race, color, religion, sex, national origin, or any other protected class. For further information, consult the appropriate Alujo Enterprises policy.

Health and Safety

Alujo Enterprises is dedicated to providing a safe and healthy work environment. Employees and officers are responsible for maintaining a safe workplace by following environmental, safety, and health rules and practices and reporting accidents, injuries, and unsafe conditions. Violence and threatening behavior are not permitted. Do not discriminate against people with protected characteristics, as this is prohibited by law. When exercising authority, be fair and transparent, avoiding favoritism and retaliating against employees or applicants. Ensure fair treatment of customers or vendors and address any company errors transparently with your manager.

Competition and Fair Dealing

We aim to outperform our competition fairly and honestly, seeking competitive advantages through superior performance, not unethical or illegal practices. Prohibited actions include stealing proprietary information, possessing trade secrets without consent, or inducing such disclosures from employees of other companies. Employees and officers should respect the rights of and deal fairly with customers, suppliers, competitors, and colleagues. Unethical practices like price fixing, bid rigging, and market allocation are forbidden.

Compliance with quality processes and safety requirements is crucial to maintain Alujo Enterprises’ reputation. All inspection and testing documents must adhere to applicable specifications and requirements.

Business entertainment and gifts should foster goodwill and sound working relationships without gaining unfair advantage. Gifts should be non-cash, consistent with business practices, reasonable in value, not construed as a bribe, and compliant with laws and policies. Consult your manager if unsure about the appropriateness of a gift.

Compliance Procedures

Ensure prompt and consistent action against Code violations. Addressing ethical dilemmas involves gathering all relevant facts, considering if an action seems unethical, and consulting your manager. Managers are responsible for problem-solving, and employees uncomfortable discussing issues with their manager can speak with a Director or HR manager. Report violations confidentially without fear of retaliation. Alujo Enterprises protects anonymity and does not permit retaliation for good faith reports. Always seek guidance when unsure about any situation.

All employees and officers must comply with Alujo Enterprises’ reporting requirements for Code violations. Non-compliance will result in disciplinary action, up to and including termination.