Code of Business Ethics

Effective Date: August 27, 2025
Last Updated: August 27, 2025
Approved By: Executive Leadership

Article I. Preamble & Foundational Principles

Section 1.01 Executive Statement of Commitment

At Assivo, Inc., an Illinois corporation ("Assivo," "Company," "we," "us," or "our"), ethical business conduct forms the cornerstone of our operations, stakeholder relationships, and corporate reputation. This Code of Business Ethics (this "Code") establishes the fundamental standards and principles that guide decision-making and behavior across all aspects of our global business operations.

This Code applies universally to all Assivo personnel, including employees, officers, directors, contractors, consultants, and business partners, serving as our collective commitment to conducting business with unwavering integrity and ethical excellence.

Section 1.02 Scope of Application and Binding Effect

This Code governs all business activities, relationships, and decisions undertaken on behalf of or in connection with Assivo across our global operations in Chicago, Mexico City, Mumbai, Chennai, and all other locations where we conduct business activities or maintain operational presence.

Section 1.03 Core Values and Ethical Foundation

Our ethical framework is built upon five fundamental values that inform all business decisions and stakeholder interactions:

Integrity: We conduct all business activities with honesty, transparency, and moral courage, honoring our commitments and taking responsibility for our actions and their consequences.
‍Excellence: We strive for superior performance in all endeavors, continuously improving our capabilities, methodologies, and service delivery to create exceptional value for clients and stakeholders.
‍Respect: We treat all individuals with dignity and respect, valuing diverse perspectives, fostering inclusive environments, and ensuring that every person can contribute meaningfully to our collective success.‍
Accountability: We take ownership of our decisions and their consequences, maintaining transparency in our operations, accepting responsibility for individual and collective performance, and learning from both successes and challenges.
‍Innovation: We embrace change and technological advancement, seeking creative solutions that advance our clients' objectives while contributing to sustainable business growth and industry leadership.

Article II. Legal & Regulatory Compliance Framework

Section 2.01 Fundamental Compliance Obligations

All personnel must comply with applicable laws, regulations, industry standards, and regulatory guidance in every jurisdiction where we operate or provide services. Where local laws establish different requirements than this Code, the more restrictive standard shall apply unless compliance would violate applicable law.

Section 2.02 Key Regulatory and Compliance Focus Areas

We maintain particular vigilance and enhanced compliance programs regarding:

Anti-Corruption and Anti-Bribery Laws: Including the U.S. Foreign Corrupt Practices Act, UK Bribery Act 2010, and equivalent international anti-corruption statutes and regulations governing interactions with government officials, commercial counterparties, and business partners.
‍Data Protection and Privacy Regulations: Including the EU General Data Protection Regulation, California Consumer Privacy Act, Health Insurance Portability and Accountability Act, and sector-specific privacy laws governing the collection, processing, use, and disclosure of personal information.
‍Export Control and Trade Sanctions: Including regulations administered by the Office of Foreign Assets Control, Bureau of Industry and Security, and equivalent international trade control regimes governing cross-border transactions, technology transfers, and business relationships.
‍Employment and Labor Laws: Including fair employment practices, workplace safety regulations, compensation requirements, anti-discrimination laws, and labor relations statutes governing our relationships with personnel across all operational jurisdictions.
‍Competition and Antitrust Laws: Including regulations governing market competition, pricing practices, customer relationships, supplier arrangements, and other commercial activities that could affect market dynamics or competitive conditions.

Section 2.03 Regulatory Monitoring and Adaptation

We actively monitor regulatory developments, participate in industry consultations, engage with regulatory authorities, and adapt our practices to maintain compliance with evolving legal requirements and regulatory expectations across our global operations.

Article III. Anti-corruption & Business Integrity

Section 3.01 Zero Tolerance Anti-Corruption Policy

Assivo maintains an uncompromising zero tolerance policy regarding corruption, bribery, and improper payments in all forms and across all business relationships. No personnel may directly or indirectly offer, provide, solicit, or accept anything of value to improperly influence business decisions, gain unfair competitive advantage, or secure improper business benefits.

Section 3.02 Prohibited Activities and Conduct

The following activities are strictly prohibited under all circumstances:

Government Official Interactions: Direct or indirect payments, gifts, or benefits to government officials, political parties, political candidates, or their family members, regardless of local customs or perceived business necessity.
‍Facilitation Payments: So-called "grease payments" or expediting fees to government officials or others to secure routine services or accelerate normal processes, even where such payments may be legally permitted under local law.
‍Commercial Bribery and Kickbacks: Improper payments, rebates, commissions, or other benefits provided to commercial counterparties, clients, suppliers, or their representatives to influence business decisions or gain competitive advantage.
‍Money Laundering and Financial Crimes: Participation in money laundering activities, structuring financial transactions to avoid reporting requirements, or engaging in suspicious financial activities that could facilitate illegal conduct.

Section 3.03 Third-Party Due Diligence and Management

We conduct comprehensive due diligence on all business partners, including:

Background Verification and Reputation Assessment: Systematic evaluation of business partners' backgrounds, reputations, financial stability, and compliance history through independent research and verification procedures.
‍Anti-Corruption Policy and Practice Evaluation: Assessment of business partners' anti-corruption policies, training programs, compliance systems, and historical adherence to ethical business practices and legal requirements.‍
Ongoing Monitoring and Relationship Management: Continuous oversight of business partner activities, performance monitoring, relationship review procedures, and prompt investigation of any compliance concerns or red flag indicators.

Section 3.04 Business Courtesies and Entertainment Guidelines

Business courtesies, gifts, and entertainment must satisfy all of the following requirements:

‍Reasonable Value and Frequency: Limited to reasonable value appropriate to the business relationship and infrequent enough to avoid creating obligations or expectations of reciprocity.‍
Business Purpose and Relationship: Clearly related to legitimate business purposes and consistent with normal business relationship development and maintenance activities.
‍Local Custom and Cultural Appropriateness: Consistent with local business customs and cultural practices while remaining within acceptable value and frequency parameters.‍
Transparency and Documentation: Properly documented, transparently disclosed, and approved through appropriate organizational channels when exceeding established thresholds or involving sensitive relationships.

Article IV. Conflicts of Interest Management

Section 4.01 Conflict of Interest Definition and Identification

A conflict of interest exists when personal interests, relationships, or activities may compromise or appear to compromise professional judgment, loyalty to Assivo, or the ability to make objective business decisions in the Company's best interests.

Section 4.02 Common Conflict Scenarios and Risk Areas

Personnel must be particularly vigilant regarding the following potential conflict situations:

‍Financial Interests and Investments: Direct or indirect financial interests in competitors, clients, suppliers, or other business partners that could influence professional judgment or create competing loyalties.
‍Outside Employment and Board Positions: External employment, consulting arrangements, board positions, or other professional commitments that could create time conflicts, competing obligations, or access to confidential information.
‍Family and Personal Relationships: Family members, close personal friends, or romantic partners employed by or having business relationships with competitors, clients, suppliers, or other business associates.
‍Corporate Opportunities and Resources: Personal use of corporate resources, information, or business opportunities for individual benefit rather than Company advancement.

Section 4.03 Disclosure and Management Procedures

All actual and potential conflicts of interest must be promptly disclosed and managed through the following process:

‍Immediate Disclosure Obligation: Written disclosure to immediate supervisor, Human Resources, or General Counsel upon identification or development of any potential conflict situation.‍
Formal Review and Assessment: Comprehensive review by appropriate management personnel and compliance officers to assess conflict severity, potential impact, and available management strategies.
‍Mitigation Strategy Development: Implementation of appropriate mitigation measures including recusal from decision-making, assignment modifications, divestiture requirements, or other controls as necessary to manage identified conflicts.
‍Ongoing Monitoring and Reassessment: Regular review of conflict status, effectiveness of implemented controls, and continued appropriateness of management strategies with adjustments as circumstances change.

Article V. Confidentiality & Information Protection

Section 5.01 Information Stewardship and Protection Obligations

We serve as stewards of confidential information belonging to Assivo, our clients, business partners, and other stakeholders. All personnel have fundamental obligations to protect confidential information from unauthorized disclosure, misuse, or compromise.

Section 5.02 Confidential Information Categories and Examples

Confidential information includes, but is not limited to:

‍Proprietary Business Information: Strategic plans, business models, financial information, operational procedures, competitive intelligence, and other non-public business information that provides competitive advantage or market position.
‍Client and Customer Information: Client data, project information, commercial terms, performance metrics, business requirements, and any other information provided by or relating to client relationships and service delivery.‍
Technical and Intellectual Property: Software code, algorithms, methodologies, technical specifications, research and development information, and other intellectual property assets and innovations.
‍Personnel and Human Resources Information: Employee personal information, compensation data, performance evaluations, disciplinary records, and other human resources information requiring confidentiality protection.

Section 5.03 Data Protection Principles and Practices

Our information protection practices encompass the following core principles:

‍Data Minimization and Purpose Limitation: Collecting, accessing, and retaining only information necessary for legitimate business purposes and authorized processing activities.
‍Access Control and Need-to-Know: Restricting information access to authorized personnel with legitimate business needs and implementing appropriate technical and administrative controls.
‍Encryption and Technical Safeguards: Implementing industry-standard encryption and security technologies for information protection during storage, transmission, and processing activities.
‍Retention Management and Secure Disposal: Maintaining information only for required business and legal periods followed by secure destruction using appropriate methods and documentation.

Article VI. Fair Competition & Market Practices

Section 6.01 Commitment to Fair Competition

We compete fairly and ethically in all markets, building competitive advantage through superior service quality, innovation, operational excellence, and value creation rather than through anti-competitive practices or market manipulation.

Section 6.02 Prohibited Anti-Competitive Activities

We strictly prohibit the following anti-competitive activities:

Price Fixing and Market Allocation: Agreements or coordination with competitors regarding pricing, market territories, customer allocation, or other commercial terms that restrict competition or harm market dynamics.
‍Monopolistic Practices and Market Abuse: Abuse of market position, predatory pricing, exclusive dealing arrangements designed to restrict competition, or other practices that harm competitive market conditions.
‍Bid Rigging and Procurement Manipulation: Coordination with competitors in bidding processes, submission of complementary bids, or other practices designed to manipulate competitive procurement processes.

Section 6.03 Competitive Intelligence and Information Gathering

We gather competitive information exclusively through legitimate means:

Public Information Sources: Industry publications, public filings, conference presentations, website information, and other publicly available materials and resources.
‍Legitimate Market Research: Authorized market research activities, industry surveys, customer feedback, and other ethical information gathering methods and sources.
‍Professional Networking: Industry associations, professional conferences, educational events, and other legitimate networking opportunities for information exchange and relationship development.

Article VII. Employment Practices & Human Rights

Section 7.01 Equal Opportunity and Non-Discrimination Commitment

We provide equal employment opportunities and maintain workplaces free from discrimination based on race, color, religion, gender, sexual orientation, gender identity, national origin, age, disability, veteran status, or other protected characteristics under applicable law.

Section 7.02 Workplace Harassment Prevention and Response

We maintain workplace environments free from harassment, intimidation, or inappropriate conduct through:

Zero Tolerance Policy: Uncompromising prohibition of harassment, bullying, intimidation, or other inappropriate workplace conduct affecting any personnel or stakeholder.
‍Prevention and Training Programs: Regular training, awareness campaigns, and education programs designed to prevent harassment and promote respectful workplace cultures.
‍Reporting and Investigation Procedures: Multiple reporting channels, prompt investigation procedures, appropriate corrective action, and protection against retaliation for good faith reporting.

Section 7.03 Health, Safety, and Workplace Protection

We prioritize workplace health and safety through:

Regulatory Compliance and Standards: Compliance with occupational safety regulations, health standards, and workplace protection requirements across all operational locations.
‍Safety Training and Awareness: Regular safety training programs, hazard awareness education, emergency response procedures, and continuous safety culture development.
‍Incident Reporting and Investigation: Comprehensive incident reporting systems, investigation procedures, corrective action implementation, and continuous improvement of safety practices and protocols.

Section 7.04 Human Rights and Labor Standards

We respect fundamental human rights throughout our operations and supply chain:

Prohibition of Forced Labor: Absolute prohibition of forced labor, human trafficking, debt bondage, and other forms of involuntary servitude in our operations and business relationships.
‍Freedom of Association: Respect for employee rights to freedom of association, collective bargaining, and other fundamental labor rights recognized under international standards.‍
Fair Compensation and Working Conditions: Commitment to fair wages, reasonable working hours, appropriate benefits, and working conditions that respect human dignity and promote employee well-being.

Article VIII. Environmental Responsibility & Sustainability

Section 8.01 Environmental Stewardship Commitment

We recognize our responsibility to minimize environmental impact and contribute to environmental sustainability through responsible business practices, resource conservation, and continuous improvement in environmental performance.

Section 8.02 Environmental Management and Compliance

Our environmental efforts include:

‍Regulatory Compliance: Full compliance with applicable environmental regulations, permitting requirements, reporting obligations, and environmental protection standards across all operational jurisdictions.
‍Resource Conservation: Energy efficiency initiatives, water conservation programs, sustainable material usage, and waste reduction strategies designed to minimize environmental footprint and resource consumption.
‍Pollution Prevention: Implementation of pollution prevention measures, emission reduction initiatives, and environmental impact mitigation strategies throughout our operations and service delivery activities.

Section 8.03 Sustainability Initiatives and Climate Action

We support environmental sustainability through:

‍Energy Efficiency and Renewable Energy: Energy-efficient technologies, renewable energy adoption where feasible, and continuous improvement in energy management and consumption optimization.
‍Sustainable Transportation and Travel: Promotion of sustainable transportation options, reduced travel through technology utilization, and carbon footprint minimization strategies for business travel and commuting.
‍Green Technology and Paperless Operations: Implementation of environmentally friendly technologies, digitalization initiatives, and paperless operation strategies to reduce environmental impact and improve operational efficiency.

Article IX. Financial Integrity & Accurate Records

Section 9.01 Financial Reporting Standards and Accuracy

We maintain accurate, complete, and transparent financial records in accordance with applicable accounting standards, regulatory requirements, and internal control frameworks. All financial transactions must be properly authorized, accurately documented, and recorded in appropriate accounting systems.

Section 9.02 Internal Control Framework and Governance

Our internal control framework includes:

‍Segregation of Duties and Authorization Hierarchies: Appropriate separation of financial functions, authorization requirements, and approval hierarchies to prevent fraud, errors, and unauthorized transactions.
‍Regular Internal Audits and Compliance Reviews: Systematic internal audit programs, compliance assessments, and control testing procedures to validate internal control effectiveness and identify improvement opportunities.
‍Fraud Detection and Prevention: Comprehensive fraud risk assessment, detection procedures, prevention controls, and response protocols to identify and address potential fraudulent activities.

Section 9.03 Document Retention and Records Management

We maintain comprehensive document retention policies covering:

(a) Financial and Accounting Records: Systematic retention of financial statements, accounting records, tax documents, and supporting financial documentation in accordance with legal requirements and business needs.

(b) Business Correspondence and Communications: Appropriate retention of client communications, business correspondence, contract documentation, and other business records supporting operational activities and legal obligations.

(c) Electronic Communications and Data: Managed retention of electronic communications, system data, and digital records with appropriate backup, archival, and disposal procedures aligned with legal and business requirements.

Article X. Technology Governance & Cybersecurity

Section 10.01 Information Systems Security and Protection

We protect our technology infrastructure and information systems through comprehensive cybersecurity programs designed to meet or exceed industry standards and regulatory requirements.

Section 10.02 Cybersecurity Framework and Controls

Our cybersecurity approach incorporates:

(a) Multi-Layered Security Controls: Defense-in-depth security architecture including network security, endpoint protection, access controls, and monitoring systems designed to prevent, detect, and respond to cybersecurity threats.

(b) Employee Training and Awareness: Regular cybersecurity training, phishing awareness programs, and security best practice education to develop organizational security culture and threat awareness.

(c) Incident Response and Business Continuity: Comprehensive incident response procedures, disaster recovery capabilities, and business continuity planning to maintain operations during cybersecurity incidents or system disruptions.

Section 10.03 Acceptable Use and Technology Governance

Technology resources must be used in accordance with:

(a) Approved Software and System Usage: Utilization of authorized software applications, system access procedures, and technology resources consistent with business purposes and security requirements.

(b) Internet and Communication Standards: Professional use of internet resources, email systems, and communication technologies consistent with business purposes and organizational reputation protection.

(c) Personal Use Limitations: Reasonable personal use of technology resources permitted within established guidelines while maintaining productivity, security, and professional standards.

Section 10.04 Intellectual Property Protection and Compliance

We respect and protect intellectual property rights through:

(a) Third-Party Software Licensing: Proper licensing of commercial software, open source compliance, and respect for intellectual property rights of technology providers and software vendors.

(b) Proprietary Technology Protection: Protection of Assivo's proprietary technologies, methodologies, intellectual property assets, and competitive advantages through appropriate security measures and confidentiality controls.

(c) Patent, Trademark, and Copyright Compliance: Respect for intellectual property rights of others, compliance with patent and trademark requirements, and appropriate use of copyrighted materials and content.

Article XI. Supply Chain Responsibility & Vendor Ethics

Section 11.01 Ethical Supply Chain Management

We select and manage vendors and business partners based on their capabilities, ethical business practices, financial stability, and alignment with our values and ethical standards.

Section 11.02 Vendor Selection and Assessment Criteria

Our vendor selection process includes evaluation of:

(a) Technical Capabilities and Service Quality: Assessment of vendor technical competencies, service delivery capabilities, performance history, and ability to meet our requirements and client expectations.

(b) Ethical Business Practices and Compliance: Evaluation of vendor compliance with anti-corruption laws, labor standards, environmental requirements, and other ethical business practice standards.

(c) Financial Stability and Business Continuity: Assessment of vendor financial health, business stability, continuity planning, and ability to maintain long-term business relationships and service delivery.

Section 11.03 Supplier Code of Conduct and Contractual Requirements

Our suppliers and business partners must:

(a) Adhere to Equivalent Ethical Standards: Maintain ethical business practices equivalent to our own standards through their own codes of conduct, compliance programs, and ethical business culture.

(b) Comply with Contractual Security and Privacy Requirements: Implement appropriate data security, privacy protection, and confidentiality measures consistent with our requirements and regulatory obligations.

(c) Participate in Ongoing Monitoring and Assessment: Submit to regular performance reviews, compliance assessments, and relationship management processes to ensure continued alignment with our standards and requirements.

Article XII. Community Engagement & Corporate Citizenship

Section 12.01 Community Investment and Social Responsibility

We contribute positively to communities where we operate through local economic development, employment opportunities, educational partnerships, and community investment activities that create shared value for stakeholders and society.

Section 12.02 Corporate Citizenship Initiatives

Our corporate citizenship focuses on:

(a) Education and Technology Access: Support for educational institutions, professional development programs, technology access initiatives, and skills development opportunities that advance educational outcomes and economic opportunity.

(b) Diversity and Inclusion Advancement: Promotion of diversity and inclusion in business and technology sectors through mentorship programs, professional development support, and inclusive business practice advocacy.

(c) Charitable Giving and Community Support: Charitable contributions, volunteer activities, disaster relief support, and community development initiatives that address local needs and contribute to social welfare.

Section 12.03 Stakeholder Engagement and Transparency

We engage with stakeholders through:

(a) Client and Customer Engagement: Regular communication, feedback collection, service improvement collaboration, and transparent reporting on performance and service delivery.

(b) Employee Engagement and Development: Professional development opportunities, career advancement support, workplace culture development, and employee feedback and suggestion programs.

(c) Community and Industry Participation: Industry association membership, professional organization participation, thought leadership contribution, and community advisory and stakeholder engagement activities.

Article XIII. Political Activities & Government Relations

Section 13.01 Political Neutrality and Non-Partisanship

Assivo maintains political neutrality and does not make corporate political contributions, endorse political candidates, or engage in partisan political activities. The Company respects the individual political rights of employees while maintaining organizational political neutrality.

Section 13.02 Employee Political Activity Guidelines

Employees may engage in personal political activities provided they:

(a) Personal Capacity Clarification: Clearly indicate that political views and activities are personal and do not represent Assivo's positions, policies, or endorsements.

(b) Personal Time and Resources: Use personal time and financial resources for political activities rather than Company time, resources, or facilities.

(c) Legal and Regulatory Compliance: Comply with applicable election laws, campaign finance regulations, and lobbying registration requirements in their personal political activities.

Section 13.03 Government Relations and Regulatory Engagement

Professional government relations activities are conducted through:

(a) Registered Representatives and Professional Services: Engagement of registered lobbyists, government relations professionals, and legal counsel for regulatory and legislative matters affecting our business interests.

(b) Transparent Disclosure and Compliance: Full compliance with lobbying registration requirements, disclosure obligations, and reporting standards for government relations activities and expenditures.

(c) Ethical Standards for Official Interactions: Maintenance of highest ethical standards in all interactions with government officials, regulatory authorities, and public sector representatives.

Article XIV. Implementation, Training, & Compliance Monitoring

Section 14.01 Code Implementation and Communication

Code awareness and implementation are ensured through:

(a) Mandatory Ethics Training Programs: Comprehensive ethics training for all personnel covering Code requirements, ethical decision-making, and compliance obligations with regular updates and reinforcement.

(b) Integration with Professional Development: Incorporation of ethics training into onboarding programs, professional development activities, and career advancement processes.

(c) Regular Communication and Reinforcement: Ongoing communication about Code requirements, ethical expectations, and compliance updates through multiple organizational channels and communication methods.

Section 14.02 Compliance Monitoring and Assessment

Code compliance is monitored through:

(a) Regular Compliance Assessments and Reviews: Systematic evaluation of Code compliance, ethical culture assessment, and identification of compliance gaps or improvement opportunities.

(b) Key Performance Indicators and Metrics: Development and monitoring of ethics and compliance metrics, performance indicators, and trend analysis to assess program effectiveness and organizational ethical performance.

(c) Management Oversight and Accountability: Clear management accountability for Code compliance, ethical leadership demonstration, and integration of ethical considerations into business decision-making processes.

Section 14.03 Violation Consequences and Corrective Action

Code violations may result in:

(a) Disciplinary Action: Progressive disciplinary measures up to and including termination of employment based on violation severity, intent, and impact on the organization and stakeholders.

(b) Legal Action and Recovery: Pursuit of legal remedies, recovery of damages, and cooperation with law enforcement authorities for violations involving illegal conduct or significant harm.

(c) Business Relationship Consequences: Suspension or termination of business relationships with third parties for Code violations or failure to meet ethical standards and compliance requirements.

Article XV. Reporting Obligations & Whistleblower Protection

Section 15.01 Reporting Obligations and Expectations

All personnel have fundamental obligations to report:

‍(a) Known or Suspected Code Violations: Any actual or suspected violations of this Code, regardless of the individuals involved or potential consequences of reporting.

(b) Legal and Regulatory Compliance Concerns: Potential violations of applicable laws, regulations, or industry standards that could affect the Company or stakeholders.

(c) Unethical Behavior and Misconduct: Any unethical behavior, misconduct, or activities that could harm the Company's reputation, stakeholders, or business relationships.

(d) Safety and Environmental Concerns: Workplace safety issues, environmental incidents, or other health and safety concerns that could affect personnel or community welfare.

Section 15.02 Reporting Channels and Communication Methods

Multiple reporting options are available to ensure accessible and appropriate reporting mechanisms:

(a) Direct Management Reporting: Communication with immediate supervisors, department managers, or other management personnel for routine concerns, questions, and violation reports.

(b) Human Resources Department: Specialized reporting channel for employment-related issues, workplace concerns, harassment complaints, and personnel matters requiring confidential handling.

(c) General Counsel and Legal Department: Direct reporting to legal counsel for legal and regulatory matters, compliance concerns, and issues requiring legal analysis or attorney-client privilege protection.

(d) Ethics Hotline and Confidential Reporting: Confidential reporting through designated ethics hotline at (312) 416-8649 and email communication to ethics@assivo.com for sensitive matters requiring confidential handling.

Section 15.03 Anti-Retaliation Protection and Whistleblower Rights

We strictly prohibit retaliation against individuals who:

(a) Good Faith Violation Reporting: Report suspected violations, compliance concerns, or ethical issues in good faith, regardless of whether subsequent investigation confirms the reported concerns.

(b) Investigation Participation and Cooperation: Participate in compliance investigations, provide information or testimony, or otherwise cooperate with internal or external investigation processes.

(c) Refusal to Engage in Unethical Conduct: Decline to participate in activities that violate this Code, applicable law, or ethical standards, even when directed or encouraged to do so by supervisors or colleagues.

(d) Ethics Guidance Seeking: Seek guidance on ethical issues, Code interpretation, or appropriate conduct in challenging or ambiguous situations.

Article XVI. Investigation & Resolution Procedures

Section 16.01 Investigation Process and Standards

Reported concerns are addressed through systematic investigation procedures:

(a) Prompt Acknowledgment and Initial Assessment: Immediate acknowledgment of reported concerns, initial assessment of allegations, and determination of appropriate investigation scope and methodology.

(b) Thorough and Impartial Investigation: Comprehensive investigation by qualified personnel with appropriate expertise, independence, and authority to conduct thorough and impartial fact-finding activities.

(c) Fair Process and Due Consideration: Fair treatment of all parties involved in investigations, appropriate consideration of evidence and circumstances, and respect for the rights and dignity of all personnel.

(d) Appropriate Corrective Action and Follow-up: Implementation of appropriate corrective measures based on investigation findings, monitoring of corrective action effectiveness, and follow-up to ensure resolution and prevention of recurrence.

Section 16.02 Confidentiality and Documentation Standards

Investigation processes maintain:

(a) Appropriate Confidentiality Protections: Reasonable confidentiality measures for all parties involved in investigations while balancing the need for thorough fact-finding and appropriate corrective action.

(b) Comprehensive Documentation and Record-Keeping: Complete documentation of investigation processes, findings, and corrective actions taken, with appropriate retention and access controls for investigation records.

(c) Legal Privilege and Professional Standards: Protection of attorney-client privilege, work product doctrine, and other legal protections where applicable to investigation activities and documentation.

(d) Regulatory Reporting and Cooperation: Compliance with regulatory reporting requirements and cooperation with external authorities when investigation findings indicate potential legal violations or regulatory concerns.

Article XVII. Global Application & Local Adaptation

Section 17.01 Universal Standards and Local Requirements

This Code establishes minimum global standards applicable across all Assivo operations while recognizing that local legal and regulatory requirements may impose higher standards or additional obligations that must be satisfied.

Section 17.02 Cultural Sensitivity and Regional Implementation

Code implementation incorporates:

(a) Cultural Sensitivity and Local Context: Recognition of local cultural practices, business customs, and stakeholder expectations while maintaining universal ethical standards and compliance requirements.

(b) Local Language Translation and Accessibility: Translation of Code requirements into local languages and formats to ensure accessibility and understanding by all personnel across diverse cultural and linguistic backgrounds.

(c) Regional Training and Communication Adaptation: Culturally appropriate training programs, communication methods, and stakeholder engagement approaches that respect local customs while reinforcing universal ethical standards.

Section 17.03 Regional Compliance and Coordination

Regional leadership ensures:

(a) Local Law Compliance and Regulatory Alignment: Full compliance with applicable local laws, regulations, and regulatory requirements while maintaining consistency with global ethical standards and Company policies.

(b) Regional Reporting and Escalation Procedures: Appropriate regional reporting mechanisms, escalation procedures, and coordination with global compliance and ethics programs for consistent implementation and oversight.

(c) Local Stakeholder Engagement and Community Relations: Effective engagement with local stakeholders, community groups, regulatory authorities, and other relevant parties to maintain positive relationships and community standing.

Article XVIII. Code Governance & Continuous Improvement

Section 18.01 Code Administration and Oversight

Code governance includes comprehensive administration and oversight structures:

(a) Ethics Committee: Executive oversight body responsible for Code development, policy updates, compliance monitoring, and strategic direction for ethics and compliance programs.

(b) Compliance Officer: Designated individual responsible for day-to-day Code administration, training coordination, investigation oversight, and compliance program implementation.

(c) Regional Coordinators: Local personnel responsible for regional Code implementation, cultural adaptation, training delivery, and coordination with global compliance programs.

(d) Executive Oversight: Ultimate accountability by executive leadership for Code effectiveness, organizational ethical culture, and integration of ethical considerations into strategic business decisions.

Section 18.02 Regular Review and Update Procedures

This Code undergoes systematic review and update processes:

(a) Annual Review by Ethics Committee: Comprehensive annual review by the Ethics Committee and senior leadership to assess Code effectiveness, identify improvement opportunities, and incorporate lessons learned.

(b) Regulatory and Industry Development Integration: Regular updates to reflect significant regulatory changes, industry developments, emerging best practices, and evolving stakeholder expectations.

(c) Compliance Assessment and Feedback Integration: Incorporation of compliance assessment findings, investigation lessons learned, and stakeholder feedback into Code improvements and program enhancements.

(d) Stakeholder Input and External Perspective: Integration of input from clients, employees, business partners, and other stakeholders to ensure Code remains relevant, effective, and aligned with stakeholder expectations.

Article XIX. Acknowledgment & Commitment

Section 19.01 Personnel Acknowledgment Requirements

All Assivo personnel must provide written acknowledgment that they:

(a) Code Receipt and Review: Have received, read, and understood this Code of Business Ethics and commit to upholding its standards and requirements in all professional activities and business relationships.

(b) Compliance Commitment: Commit to full compliance with Code requirements, applicable laws and regulations, and Company policies and procedures governing ethical business conduct and professional behavior.

(c) Reporting Obligation Acceptance: Accept the obligation to report suspected violations, seek guidance on ethical issues, and participate in compliance programs and investigation activities as required.

(d) Training and Development Participation: Agree to participate in required ethics training programs, professional development activities, and compliance education initiatives to maintain awareness and competence.

Section 19.02 Annual Certification and Disclosure

Personnel participate in annual certification processes including:

(a) Annual Code Compliance Certification: Formal certification of compliance with Code requirements, confirmation of understanding of ethical obligations, and acknowledgment of any changes in circumstances affecting compliance.

(b) Conflict of Interest Disclosure: Annual disclosure of potential conflicts of interest, financial relationships, outside activities, and other circumstances that could affect professional judgment or create competing obligations.

(c) Training Completion Verification: Confirmation of completion of required ethics training, professional development activities, and compliance education programs.

Article XX. Contact Information & Ethics Resources

Section 20.01 Ethics and Compliance Office

Ethics and Compliance Office
Assivo, Inc.
444 West Lake Street, Suite 1700
Chicago, Illinois 60606
Telephone: (312) 416-8649
Email: ethics@assivo.com

Section 20.02 Regional Ethics Coordinators

Regional Coordination and Support:

Americas: americas@assivo.com
Mexico: mexico@assivo.com
India: india@assivo.com

Section 20.03 Additional Resources and Support

For additional ethics resources, training materials, and guidance on ethical decision-making, personnel may access internal ethics resources, professional development materials, and consultation with compliance personnel through established organizational channels and communication systems.

This Code of Business Ethics represents our unwavering commitment to conducting business with integrity, maintaining stakeholder trust, and upholding the highest standards of ethical conduct across all aspects of our global operations. It should be implemented alongside applicable laws, regulations, industry standards, and Company policies to ensure comprehensive ethical governance and compliance excellence.