I. Purpose CSS, Inc. is committed to maintaining the highest ethical standards in all business operations. This Compliance and Ethics Policy outlines our commitment to anti-corruption, business ethics, avoidance of conflicts of interest, and strict controls related to the payment of commissions, and provision of gifts or entertainment, particularly in dealings involving government entities.

II. Scope This policy applies to all officers, directors, employees, contractors, agents, consultants, and representatives of CSS, Inc. and its subsidiaries or affiliates, in all locations and jurisdictions where CSS, Inc. operates.

III. Anti-Corruption and Anti-Bribery Compliance CSS, Inc. strictly prohibits any form of bribery or corrupt practices. No employee or representative of CSS, Inc. may offer, give, solicit, or receive anything of value intended to improperly influence a business decision or gain an unfair advantage.

This includes:

• Payments, gifts, or favors to government officials, customers, or business partners.
• Kickbacks or hidden commissions.
• Use of third parties to engage in prohibited conduct on behalf of CSS, Inc.

CSS, Inc. complies fully with the U.S. Foreign Corrupt Practices Act (FCPA), and all other applicable anti-corruption laws.

IV. Business Ethics and Integrity All business dealings shall be conducted transparently, honestly, and fairly. CSS, Inc. does not tolerate:

• Fraud, deception, or misrepresentation.
• Collusive behavior or anticompetitive conduct.
• Undisclosed relationships that could impair impartial judgment.

V. Conflict of Interest Policy The following principles shall apply:

a) No officer, director, employee, agent, or consultant of any government entity, or their immediate family or household member, shall directly or indirectly receive or be promised any form of benefit, payment, or compensation in connection with the award or performance of any agreement with CSS, Inc.

b) CSS, Inc. shall disclose any potential conflicts of interest, including undisclosed partnerships or interests in contract-related activities. Agreements will not be entered into with knowledge of undisclosed competing proposals or collusion.

c) CSS, Inc. personnel shall not engage in outside interests or relationships that conflict with their duties, unless disclosed in writing and approved by senior management and/or the relevant contracting agency.

d) These standards are in addition to all applicable statutory conflict-of-interest provisions. Where there is a conflict between this policy and the law, the stricter provision shall apply.

e) Any actual or apparent conflict that becomes known after entering into a contract must be promptly reported to the client’s project manager, and CSS, Inc. shall fully cooperate in any investigation or resolution process.

VI. Gifts and Entertainment Gifts and entertainment provided by CSS, Inc. must:

• Be infrequent and of nominal value.
• Not be intended to influence business decisions.
• Be permitted under applicable laws and client policies.

No gifts or entertainment shall be offered to government officials without prior written approval from CSS, Inc. Legal or Compliance.

VII. Commissions and Third-Party Payments CSS, Inc. does not permit secret commissions or improper payments through third parties. All commissions or fees paid to agents or intermediaries must:

• Be documented in a written agreement.
• Reflect fair market value for legitimate services rendered.
• Be reviewed and approved by executive leadership.

VIII. Reporting Violations and Compliance Oversight Employees must report any suspected violations of this policy to their supervisor or the Compliance Officer. CSS, Inc. strictly prohibits retaliation against any individual who reports a concern in good faith.

1. Enforcement Violations of this policy may result in disciplinary action, up to and including termination of employment or contract, and potential legal action.

For questions or reporting, please contact:

Elmer Rodriguez

elmerr@cssimpact.com