Business Ethics & Anti-Corruption Policy

1. Commitment and Scope

Global Roots Services ("GRS" or the "Company") conducts business honestly, ethically, and in full compliance with all applicable anti-corruption and anti-bribery laws, including the United States Foreign Corrupt Practices Act (FCPA), the U.S. Anti-Kickback Act and Anti-Kickback Statute, the UK Bribery Act, and the anti-corruption laws of every country in which we operate. This Policy applies to all GRS owners, employees, contractors, and agents, and to affiliate personnel (including our Philippine affiliate) when acting in connection with GRS business.

2. No Bribery — Anywhere, in Any Form

No person covered by this Policy may offer, give, promise, authorize, or accept anything of value — money, gifts, travel, entertainment, employment, favors, or charitable or political contributions — to or from any government official or private party in order to obtain or retain business, influence a decision, or secure an improper advantage. This prohibition includes facilitation ("grease") payments, which GRS does not pay under any circumstances, even where local custom tolerates them.

3. Gifts and Hospitality

Business gifts and hospitality must be infrequent, of nominal value (under $100 USD), customary, accurately recorded, and never in cash or cash equivalents. No gift or hospitality of any value may be provided to a government official, foreign or domestic, without the prior written approval of the Owner.

4. Third Parties and Affiliates

GRS will not engage a third party to do indirectly what this Policy forbids directly. Agents, consultants, teaming partners, and affiliate personnel acting on GRS's behalf are selected with reasonable care, informed of this Policy, and expected to comply with it as a condition of the relationship.

5. Books, Records, and Internal Controls

All GRS transactions are recorded accurately and completely in the Company's books and records. Off-the-books accounts, false or misleading entries, and undisclosed or unrecorded funds are prohibited.

6. Government Contracting Integrity

In all U.S. federal, state, and local government work, GRS complies with applicable procurement integrity rules, makes only truthful certifications and representations, and strictly prohibits kickbacks in connection with prime contracts and subcontracts.

7. Raising Concerns; No Retaliation

Suspected violations of this Policy or of any law must be reported promptly to the Owner at jesse@globalrootsservices.com. Reports are reviewed and addressed by the Owner directly. GRS prohibits retaliation of any kind against anyone who raises a good-faith concern.

8. Distribution, Training, and Review

This Policy is provided to all GRS personnel and key partners at the start of their engagement, and its requirements are reviewed with them. The Owner reviews this Policy at least annually and updates it as the Company grows.