Code of Conduct

Allonnia’s commitment to integrity and doing the right thing begins with complying with all laws, rules, and regulations where we do business. Further, each of us must understand the company policies, laws, rules, and regulations that apply to our specific roles. We are responsible for preventing violations of the law and for speaking up if we see possible violations. Highlighted below, are areas of our business that we must ensure comply with all laws and regulations where we do business:

Anti-Corruption

The United States Foreign Corrupt Practices Act (“FCPA”) prohibits offering, providing, or promising anything of value (including money, gifts, preferential treatment, and any other sort of advantage), either directly or indirectly, by a United States company, or any of its employees, subsidiaries, affiliates, or agents, to a Foreign Government Official for the purposes of influencing an act or decision in that individual’s official capacity, or inducing the official to use such officials’s influence with the foreign government to assist the United States company, its subsidiaries or affiliates, or anyone else, in obtaining or retaining business or securing an improper advantage.

Employees of Allonnia may not directly or indirectly offer, promise, grant, or authorize the giving of money or anything else of value to a Foreign Government Official to influence official action, obtain or retain business, or secure an improper advantage. These legal restrictions apply fully to all Allonnia employees regarding their activities during or in relation to their employment with Allonnia, regardless of an employee’s physical location.

Child and Forced Labor

Allonnia prohibits the use of both child labor and forced or compulsory labor. We expect that all managers will ensure strict compliance with all relevant local and international laws and standards in respect to child labor. We do not employ any person under the age of eighteen years in the workplace without permission from the CHRO, and , in all cases, the Company will comply with all applicable laws. In addition, we will not tolerate the use of any child or forced labor within our supply chain partners. A system of checking and maintaining records of workers at the time of employment, to determine proof of age, is in place. All managers are responsible to ensure that no employee is made to work against such employee’s will or work as bonded/forced labor or be subject to corporal punishment or coercion of any type related to work.

Competition

We are dedicated to ethical, fair, and vigorous competition. We will sell Allonnia products and services based solely on their merits. We will make independent pricing and marketing decisions and will not improperly cooperate or coordinate our activities with our competitors. We will not offer or solicit improper payments or gratuities in connection with the purchase of goods or services for Allonnia or the sales of its products or services, nor will we engage or assist in unlawful boycotts of customers.

Proprietary Information

It is important that we respect the property rights of others. We will not acquire or seek to acquire through improper means, a competitor’s trade secrets or other proprietary or confidential information. We will not engage in unauthorized use, copying, distribution or alteration of software or other intellectual property.