Code of Conduct

Anti-bribery and anti-corruption policy

(1) Introduction

NutriBlends, LLC., (the Company) has a zero-tolerance policy towards bribery and corruption. We prohibit bribery, kickbacks, or illegal payments to individuals or entities for any purpose. We require all employees, contractors, and business partners to comply with all relevant anti-bribery and anti-corruption laws and regulations. Any violation of this policy will result in disciplinary action up to and including termination of employment or contract.

We are committed to maintaining the highest standards of ethical conduct in all our business dealings and relationships. As part of this commitment, we have implemented an anti-bribery and anti-corruption policy that prohibits any form of bribery, corruption, or improper inducement in connection with our business activities.

(2) Applicability and Purpose

This policy applies to all employees, (hereinafter referred as to the “employees”) of the Company (including employees temporarily transferred to affiliates and vendors), agents, representatives, joint venture, partners, or anyone else doing business in the name of or with the Company, including the suppliers, contractors, or subcontractors (collectively referred to herein as "Covered Parties")., or accepting any bribe or other improper inducement, whether in cash or in kind, directly or indirectly, to or from any person or organization in order to gain an improper business advantage.

We will not tolerate any form of bribery or corruption, and any employee or contractor found to have violated this policy will be subject to disciplinary action, up to and including termination of employment or contract.

We will also cooperate fully with any government authorities or law enforcement agencies investigating allegations of bribery or corruption, and we will take appropriate measures to prevent future occurrences.

(3) Policy

By following this policy and upholding the highest standards of ethical conduct, we can help to ensure that our business activities are conducted with integrity and in compliance with all applicable laws and regulations.

  1. Bribery, fraud, money laundering, conflicts of interest, and improper interactions with government officials or entities are strictly prohibited.
  2. No employee, contractor, or representative of our company shall offer, pay, seek, or accept cash, gifts, sponsorships, or anything else of value, directly or indirectly, to improperly influence a business decision or gain a business advantage.
  3. Any employee, contractor, or representative of our company who becomes aware of any violation of this code of conduct or any related law or regulation must immediately report it to the appropriate authority within the company.
  4. We will cooperate fully with any government investigation or legal proceedings related to these issues.
  5. Employees, contractors, and representatives of our company must avoid any situation where their personal interests may conflict with the interests of the company.
  6. Any potential conflicts of interest must be promptly disclosed to the appropriate authority within the company, and steps must be taken to manage or eliminate the conflict.
  7. Our company will not tolerate retaliation against any employee, contractor, or representative who reports a violation of this code of conduct or participates in any related investigation.
  8. We will periodically review and update this code of conduct as necessary to make sure it stays current and effective.

It is important that we follow these guidelines to ensure that our company conducts its operations ethically and responsibly.

(4) Prohibited Activities

(a) The Company Staff/covered parties should not offer and/or provide any pecuniary or other benefits to Public Officials either directly or indirectly (i.e. through a third party). Furthermore, if there is a possibility that any Business Entertainment could give rise to a misunderstanding that the Company has conducted the Business Entertainment with the intention of gaining an improper business advantage (irrespective of its genuine intention), the Company Staff should not offer the Business Entertainment in such a situation. Company has conducted the Business Entertainment with the intention of gaining an improper business advantage (irrespective of its genuine intention), the Company Staff should not offer the Business Entertainment in such a situation. (b) Offering any cash (including, but not limited to, bills/notes, Cheques, every kind of cash voucher, stock certificates, and securities;

(c) Any entertainment at the hostess, strip, or similar adult entertainment clubs; and

(d) Any business meal or gift if the expense is not properly recorded in the appropriate accounting books and not as per the Code of Conduct Policy of the Company.

(5) Policy on Invitations

All of the following conditions must be satisfied in the case of any invitations made to Public Officials:

(a) There must be a legitimate purpose for the invitation of the Public Official, and there must be no circumstances giving rise to any misunderstanding that such invitation has been made with the intention of gaining any improper business advantage;

(b) Any expense for the invitation borne by the Company should be limited to a reasonable amount or actual expenditure;

(c) Any money to be paid by the Company shall not (in any way) provide any personal benefit to a Public Official;

(d) Such invitation must not violate the Anti-bribery Laws of the relevant country which the Public Official works for;

(e) The expenses for the invitation should be accurately and properly recorded in the relevant accounting books.

(6) Consultation Service

If it is difficult to judge whether the planned Business Entertainment is permissible from a review of this Policy, such cases may be referred to the Managing Director, who will with the help of the legal department decide whether such expense is within the permitted or not under this policy.

(7) Reporting incidents of Bribery and Corruption

If any member of the Company Staff discovers any intentional or accidental violation of this Policy, such member should report such discovery to his/her superior or to the Managing Director or email us.

Last updated 3/18/2023