Anti-Bribery & Anti-Corruption Policy

1. Purpose and Scope

Storefront Labs, LLC (“Storefront”) is committed to conducting business honestly, transparently, and in compliance with applicable anti-bribery and anti-corruption laws.

This Policy applies to Storefront personnel and to partners, resellers, distributors, consultants, contractors, vendors, agents, intermediaries, and other third parties acting for or on behalf of Storefront or participating in Storefront-related business.

2. Relationship to Other Documents

If an executed agreement imposes stricter anti-corruption requirements, those stricter requirements control.

3. Zero-Tolerance Standard

Storefront prohibits bribery, kickbacks, corruption, secret commissions, improper influence, and falsification of records.

No person may offer, promise, authorize, give, request, agree to receive, or accept anything of value to improperly influence a decision, obtain or retain business, secure an improper advantage, reward improper conduct, or induce a person to misuse a position of trust.

4. Bribery and Improper Payments

“Anything of value” may include:

• cash or cash equivalents;
• gifts, meals, travel, lodging, or entertainment;
• discounts, rebates, commissions, or credits;
• employment, internships, contracts, or business opportunities;
• charitable or political contributions;
• loans, favors, services, or personal benefits;
• confidential information or preferential treatment; and
• benefits provided to relatives, friends, associates, or organizations connected to the recipient.

A payment or benefit may be improper even if it is small, customary, indirectly provided, unsuccessful, or never ultimately delivered.

5. Government Officials

Special caution is required in dealings with government officials, employees of state-owned or state-controlled enterprises, political parties, candidates, public international organizations, judges, regulators, inspectors, customs officials, and persons acting in an official capacity.

No payment, gift, hospitality, travel, contribution, or other benefit may be provided to a government official to influence an official act or obtain an improper advantage.

6. Commercial Bribery

Improper payments are prohibited in private-sector transactions as well as government dealings.

No person may give or receive a secret commission, personal rebate, kickback, side payment, undisclosed referral fee, or other benefit intended to influence a customer, vendor, employee, partner, or business decision.

7. Facilitation Payments

Storefront prohibits facilitation or “grease” payments made to expedite routine governmental action, even where such payments may be customary or locally tolerated.

This prohibition does not prevent payment of a lawful, published government fee for an expedited service where an official receipt is provided and the payment is accurately recorded.

8. Gifts, Meals, Travel, and Hospitality

Business courtesies must be:

• lawful;
• reasonable and proportionate;
• infrequent;
• transparent;
• connected to a legitimate business purpose;
• not cash or a cash equivalent;
• not intended to influence a pending decision; and
• accurately documented.

Business courtesies must never create an appearance of impropriety, obligation, favoritism, or hidden compensation.

Storefront may require advance approval for gifts, travel, entertainment, or hospitality involving government officials, procurement personnel, customers, vendors, or high-value items.

9. Political and Charitable Contributions

No political or charitable contribution may be made on Storefront's behalf without prior written authorization.

Contributions may not be used to conceal a bribe, influence a business decision, benefit a connected official or customer, or bypass approval requirements.

Personal political activity must be clearly separated from Storefront and conducted without Storefront funds, resources, branding, or implied endorsement.

10. Third Parties and Intermediaries

Storefront may be responsible for improper conduct by agents, consultants, distributors, resellers, referral partners, subcontractors, and other intermediaries.

Third parties may not be used to do anything Storefront could not lawfully do directly.

Third-party compensation must be commercially reasonable, proportionate to legitimate services, supported by written documentation, and paid through transparent channels to the contracting party.

11. Due Diligence

Storefront may conduct risk-based due diligence before engaging or paying a third party.

Due diligence may include review of:

• ownership, control, and beneficial owners;
• government affiliations;
• sanctions and restricted-party status;
• qualifications, experience, reputation, and references;
• scope of services and commercial justification;
• proposed compensation and payment arrangements;
• use of subcontractors or intermediaries;
• conflicts of interest; and
• anti-corruption policies and compliance history.

Storefront may decline, suspend, or terminate a relationship where diligence is incomplete or raises unresolved concerns.

12. Books, Records, and Internal Controls

All transactions must be accurately, completely, and timely recorded in appropriate books and records.

Prohibited practices include:

• off-the-books accounts or funds;
• false, incomplete, misleading, or vague descriptions;
• mischaracterized expenses or invoices;
• split payments intended to avoid approval thresholds;
• payments to unrelated persons, personal accounts, or unexplained jurisdictions;
• backdated or fabricated documents;
• undisclosed commissions or rebates; and
• destruction or concealment of relevant records.

Supporting documentation must reflect the actual business purpose, recipient, amount, date, and approval.

13. Conflicts of Interest

Actual or potential conflicts of interest must be disclosed promptly.

Examples include personal, family, financial, or business relationships with customers, vendors, officials, partners, or decision-makers that could influence or appear to influence Storefront-related decisions.

14. Duress and Safety Payments

A payment made under an immediate and credible threat to life, health, or physical safety may be permissible where necessary to prevent serious harm.

Any such payment must be reported to Storefront as soon as safely possible and accurately recorded.

15. Reporting Concerns

Suspected bribery, corruption, kickbacks, improper gifts, falsified records, retaliation, or attempted violations should be reported promptly to hello@storefrontworks.com.

Reports should include relevant facts, dates, persons, transactions, documents, and concerns where available.

A person should not conduct an independent investigation that could destroy evidence, interfere with legal obligations, or create safety risk.

16. Non-Retaliation

Storefront prohibits retaliation against a person who, in good faith:

• reports a suspected violation;
• asks a compliance question;
• declines to participate in suspected misconduct;
• cooperates with an investigation; or
• raises an accounting, controls, or records concern.

Knowingly false or malicious reports are not protected.

17. Investigations and Cooperation

Storefront may investigate suspected violations, preserve records, interview relevant persons, engage advisors, suspend transactions, and cooperate with authorities where permitted or required.

Covered persons must cooperate honestly and preserve relevant documents, communications, and data.

18. Enforcement

Violations may result in:

• rejection or cancellation of a transaction;
• withholding or clawback of commissions or payments;
• suspension or termination of access, employment, engagement, or partner status;
• contractual indemnification or recovery of losses;
• reporting to regulators or law enforcement; and
• civil or criminal consequences under applicable law.

Storefront may take interim action while a concern is being reviewed.

19. Changes to This Policy

Storefront may update this Policy prospectively as laws, risks, products, and business relationships evolve.

Covered persons remain responsible for compliance with applicable law even if this Policy has not yet been updated to reflect a recent legal change.

20. Contact Information

Storefront Labs, LLC
1642 Burgos Dr
Sarasota, FL 34238
United States

Email: hello@storefrontworks.com
Website: www.storefrontworks.com

This Policy provides general compliance standards and is not legal advice concerning a particular transaction, country, payment, official, or business relationship.