Anti-Corruption & Business Ethics Policy

This Anti-Corruption and Business Ethics Policy sets out the standards VitaSignal LLC expects from its directors, officers, employees, contractors, advisors, and anyone else acting on the company's behalf ("Covered Persons"). It applies to all business activities, including research partnerships, pilot engagements, licensing discussions, vendor selection, investor relations, and government or institutional interactions, regardless of location.

VitaSignal LLC conducts business honestly, fairly, and in compliance with applicable anti-corruption and anti-bribery laws, including the U.S. Foreign Corrupt Practices Act and similar laws in jurisdictions where we operate. Covered Persons must not offer, promise, authorize, or provide anything of value to any person, including a government official or commercial counterparty, to improperly influence an act or decision, secure an improper advantage, or obtain or retain business.

Gifts and hospitality may be offered or accepted only when they are modest, infrequent, transparent, and not intended to influence a business decision. Gifts, meals, entertainment, or hospitality exceeding $250 in aggregate value per recipient in any rolling 12-month period require prior written approval from the Compliance Officer. Gifts of cash or cash equivalents are prohibited. All gifts and hospitality must be accurately recorded.

Interactions with government officials, public health authorities, academic institutions receiving public funds, and employees of state-affiliated entities require heightened care. Covered Persons may not provide anything of value to a government official unless pre-approved in writing by the Compliance Officer and permitted under applicable law and the recipient's own ethics rules. Political contributions made on behalf of VitaSignal LLC require prior Board approval.

VitaSignal LLC does not pay commissions or success fees to government officials or their representatives. Commercial intermediaries, consultants, brokers, or referral partners must be engaged under written agreements that include anti-corruption representations, are compensated at fair market value for legitimate services, and are approved by the Compliance Officer. Facilitation payments, however small, are prohibited.

All transactions and expenses must be recorded accurately, completely, and in a timely manner. No undisclosed or unrecorded accounts may be established, and no payment may be approved with the understanding that any portion will be used for an improper purpose. Expense reports, invoices, and contracts must reflect the true nature and recipient of each payment.

Covered Persons are required to report any actual, potential, or suspected violation of this policy promptly to the Compliance Officer. Reports may also be submitted through the contact channel listed below. VitaSignal LLC prohibits retaliation against any person who reports a concern in good faith, participates in an investigation, or refuses to participate in conduct that would violate this policy.

Violations of this policy may result in disciplinary action, up to and including termination of employment or engagement, recovery of improper payments, and referral to legal counsel or law enforcement as appropriate. The Compliance Officer reviews this policy at least annually and updates it to reflect changes in law, regulation, and business operations.