Vendor Code of Conduct

Akzis Inc. (“Akzis”) strives to achieve the highest standard of business and professional integrity, and seeks to avoid even the appearance of improper behavior. We expect our vendors, suppliers, distributors, partners, business associates, and third party representatives (“Vendors”) to uphold these standards of conduct and professional integrity and communicate them to their organization

This Vendor Code of Conduct (“Code”) sets forth Akzis’ expectation that its Vendors uphold the highest standards of ethics and comply with all applicable laws and regulations. These expectations should complement each Vendor’s own company policies, applicable legal requirements, and the terms of any agreements that a Vendor may have with Akzis. Failure to comply with this Code could result in termination of the business relationship.

Akzis encourages Vendors to raise questions or concerns about this Code to their Akzis point of contact.

I. COMPLIANCE WITH APPLICABLE GOVERNMENTAL LAWS, RULES, AND REGULATIONS

A. Akzis expects its Vendors to comply with both the letter and the spirit of all laws, rules and regulations that apply to the Vendor’s business, particularly those related to Vendor’s performance of duties for Akzis.

II. ANTI-CORRUPTION COMPLIANCE & BUSINESS EXPENSES

A. Akzis prohibits bribes, kickbacks, or other improper or illegal payments of anything of value from being directly or indirectly offered, given, authorized, promised, solicited, or accepted in any way related to Akzis, whether it involves public officials (including officers or employees of governments or state-owned entities) or private parties.

B. Akzis prohibits bribery to influence a public official, to obtain or retain business from any party, or to secure an unfair business advantage.

C. Akzis also prohibits Vendors from making facilitation payments, or small, unofficial payments to public officials to expedite routine, non-discretionary government decisions (even if permissible under local law).

D. All business expenses provided by Vendors related to Akzis’s business – including gifts (whether money or any other thing of value), hospitality, entertainment, events, travel, or accommodation – must comply with any agreements with Akzis; have a legitimate business purpose; be reasonable and modest in value and frequency; comply with local law; and be accurately recorded. Akzis prohibits the provision of cash gifts.

III. EXPORT, CUSTOMS, TRADE CONTROL, AND ANTI-MONEY LAUNDERING

A. Akzis expects its Vendors to comply with all applicable export, customs, and trade control laws and regulations, including economic and trade sanctions laws, antiboycott laws, and any related licensing requirements.

B. Akzis also expects its Vendors to comply with all applicable anti-money laundering laws and regulations.

IV. CONFLICTS OF INTEREST & CORPORATE OPPORTUNITIES

A. Vendors must avoid actual or potential business or financial conflicts of interest involving Akzis – i.e., instances where the Vendor’s personal interests (including interests of the Vendor itself or the Vendor’s employees, officers, or directors) interfere or appear to interfere with Akzis’s interests.

B. Vendors are prohibited from directly or indirectly (a) taking personally for themselves opportunities that are discovered through the use of Akzis property, information or positions; (b) using Akzis property, information or positions for personal gain; or (c) competing with Akzis for business opportunities.

C. Any actual or potential conflicts of interest must be promptly reported to Akzis.

V. INSIDER TRADING

A. Vendors may not trade or advise others to trade relational securities while in possession of “material nonpublic information” about Akzis. Information is material if it could reasonably be expected to affect the judgment of investors regarding whether to buy, sell, or hold the securities in question of an Akzis provider, supplier, partner, user, or competitor.

B. Akzis also prohibits Vendors from “tipping” others (e.g., family or friends) regarding material nonpublic information about Akzis which may be used to influence investments made in an Akzis partner or competitor.

VI. ANTITRUST, COMPETITION, AND FAIR DEALING

A. Akzis expects its Vendors to comply with applicable antitrust and competition laws designed to promote fair and open competition, particularly as it relates to Akzis.

B. Vendors must not directly or indirectly enter into any formal or informal agreement with competitors that fixes or controls prices, divides or allocates markets, limits the production or sale of products, boycotts certain suppliers or customers, eliminates competition or otherwise unreasonably restrains trade.



C. Vendors must deal fairly with the Company’s customers, service providers, suppliers, competitors and employees.

D. Vendors may not take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any other unfair dealing practice.

VII. RECORD MANAGEMENT AND RECORDING TRANSACTIONS

A. Vendors are expected to ensure that all financial books, records and accounts related to their relationship with Akzis accurately reflect transactions and events.

B. Vendors must not falsify documents, transactions, or accounting records related to Akzis.

VIII. CONFIDENTIAL INFORMATION

A. We expect our Vendors to safeguard and protect Akzis’s confidential information, as well as the confidential information of Akzis’s customers, suppliers, shareholders, Akzis employees, or other third parties. Confidential information should be interpreted broadly to include all non-public information relating to Akzis or other companies that would be harmful to the relevant company (or useful to competitors) if disclosed.

B. Akzis prohibits Vendors from misusing proprietary information or trade secret information that was obtained without the owner’s consent; or from using confidential information for personal gain.

IX. DATA PRIVACY

A. Vendors must comply with all applicable laws and regulations regarding the protection of personal information or other sensitive or protected information, and assist Akzis in complying with its own obligations in this regard.

X. HUMAN RIGHTS, EMPLOYEE RELATIONS AND NON-DISCRIMINATION

A. We expect our Vendors to comply with all applicable human rights laws prohibiting child, forced, indentured, or involuntary labor.

B. Akzis expects its Vendors to conduct themselves in a professional manner with courtesy and respect for others. We do not tolerate harassment by our Vendors in any form, including verbal, physical, or sexual harassment.

C. Akzis is committed to providing equal opportunities in employment, development, and advancement for all qualified persons – and we expect our Vendors to share that commitment. Akzis does not tolerate illegal discrimination by its Vendors.

XI. ENVIRONMENT, SAFETY, AND HEALTH

A. Akzis expects its Vendors to operate in a manner protective of human health, safety, and the environment, especially as it relates to Vendors work with Akzis.

B. Akzis expects its Vendors to comply with both the letter and the spirit of applicable health, safety and environmental laws and regulations.

XII. USE AND PROTECTION OF Akzis CORPORATE ASSETS

A. If provided with Akzis assets (including technology, software, proprietary information, or other physical assets), Vendors are expected to protect these assets and ensure their efficient use for legitimate business purposes.