Code of Business Ethics

1. Purpose and Scope

Oxenade Industries LLC ("Oxenade") is committed to conducting all business activities with the highest standards of integrity, honesty, and ethical conduct. This Code of Business Ethics ("Code") applies to all employees, officers, directors, consultants, and agents of Oxenade, as well as to subcontractors and business partners acting on our behalf. As a Veteran-Owned Small Business (VOSB) operating in the federal contracting marketplace, we recognize that our reputation for ethical conduct is foundational to our mission and our relationships with government customers and partners.

2. Integrity and Honest Dealing

All personnel are expected to act with integrity in every business interaction. This means:

• Being truthful and transparent in all communications with government customers, contracting officers, and business partners
• Never making false statements, misrepresentations, or omissions in proposals, invoices, certifications, or any other documents submitted to the government
• Avoiding deceptive practices in marketing, advertising, or capability statements
• Disclosing conflicts of interest promptly and fully to appropriate management
• Competing fairly and in accordance with applicable procurement laws and regulations

3. Anti-Bribery and Anti-Corruption

Oxenade strictly prohibits bribery and corruption in all forms. No employee or agent may offer, give, solicit, or accept anything of value — including gifts, entertainment, payments, or other benefits — to or from any government official, customer, supplier, or other third party for the purpose of improperly influencing a business decision or obtaining an unfair advantage.

This prohibition applies to direct and indirect payments and extends to family members and associates of covered individuals. Oxenade complies with the Foreign Corrupt Practices Act (FCPA), the Anti-Kickback Act, and all other applicable anti-corruption laws. Reasonable, modest business courtesies (such as meals or promotional items of nominal value) may be permissible where consistent with applicable law and company policy, but must never be offered or accepted with any expectation of reciprocal benefit.

4. Conflicts of Interest

Employees and agents must avoid situations in which personal interests conflict — or appear to conflict — with the interests of Oxenade or its government customers. Potential conflicts of interest include:

• Holding a financial interest in a competitor, supplier, or customer without disclosure
• Using company resources, information, or relationships for personal gain
• Participating in procurement decisions where a family member or close associate has a financial interest
• Accepting outside employment or board positions that may impair objectivity or performance

Any actual or potential conflict of interest must be disclosed promptly to management. Oxenade will evaluate disclosed conflicts and determine appropriate mitigation measures, which may include recusal from affected decisions.

5. Accurate Recordkeeping and Financial Integrity

Oxenade is committed to maintaining accurate, complete, and timely records in all business activities. All personnel must:

• Record all transactions honestly and in accordance with generally accepted accounting principles (GAAP) and applicable cost accounting standards
• Never falsify, alter, or destroy records, including timesheets, expense reports, invoices, or contract deliverables
• Ensure that all costs charged to government contracts are allowable, allocable, and reasonable under FAR Part 31
• Maintain adequate documentation to support all billings and contract performance claims
• Cooperate fully with internal and external audits, including audits conducted by the Defense Contract Audit Agency (DCAA) or other government oversight bodies

6. Compliance with FAR, DFARS, and Applicable Law

As a federal contractor, Oxenade is subject to the Federal Acquisition Regulation (FAR), the Defense Federal Acquisition Regulation Supplement (DFARS), and other applicable statutes and regulations. All personnel involved in government contracting activities must:

• Understand and comply with the terms and conditions of all applicable contracts and task orders
• Adhere to required certifications and representations made in proposals and contract documents
• Comply with mandatory disclosure requirements under FAR 52.203-13, including timely reporting of credible evidence of violations of federal criminal law or the civil False Claims Act
• Observe all applicable export control laws, including the Export Administration Regulations (EAR) and International Traffic in Arms Regulations (ITAR)
• Comply with all applicable employment, labor, environmental, and safety laws

7. Protection of Sensitive and Classified Information

Employees and agents who have access to government-furnished information, controlled unclassified information (CUI), or classified national security information must handle such information strictly in accordance with applicable laws, regulations, and contract requirements. Unauthorized disclosure of sensitive government information is strictly prohibited and may result in criminal liability, contract termination, and debarment.

8. Whistleblower Protections

Oxenade is committed to protecting employees who report suspected violations of law, regulation, or this Code in good faith. Retaliation against any employee for reporting a concern, participating in an investigation, or refusing to engage in conduct that violates this Code is strictly prohibited and will result in disciplinary action up to and including termination.

Employees are also protected under applicable federal whistleblower statutes, including the National Defense Authorization Act (NDAA) provisions protecting contractor employees who report fraud, waste, or abuse related to federal contracts.

9. Reporting Concerns

Employees, subcontractors, and other stakeholders who become aware of potential violations of this Code, applicable law, or government contract requirements are encouraged to report their concerns promptly. Reports may be made to direct supervisors, senior management, or directly to our ethics contact. All reports will be treated with appropriate confidentiality to the extent practicable.

10. Enforcement and Consequences

Violations of this Code may result in disciplinary action, up to and including termination of employment or contract, referral to law enforcement authorities, and notification to government contracting officers as required by applicable regulations. Oxenade takes all reported concerns seriously and will investigate allegations promptly and impartially.