Integrity and Compliance Program

1. Introduction and Purpose

At Cytric Partners LLC, we are committed to operating with integrity, transparency, and full compliance with applicable laws and ethical standards. This Integrity and Compliance Program sets forth our company’s principles and internal controls to prevent, detect, and address any unlawful or unethical conduct. It reflects our responsibility as a U.S.-based business and vendor, especially in engagements with public entities.

Our policies are tailored to our size, operational risks, and structure as a small business, while aligning with best practices in corporate compliance.

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2. Core Principles

Our Program is based on the following foundational principles:

• Ethical Business Practices: All business must be conducted honestly and fairly.

• Legal Compliance: We comply with all applicable federal, state, and local laws.

• Anti-Corruption and Anti-Bribery: We strictly prohibit bribery, kickbacks, and improper payments.

• Transparency: All interactions—especially with government officials—must be documented and traceable.

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3. Code of Ethics and Conduct

We maintain a formal Code of Ethics and Conduct that outlines:

• Compliance obligations for all personnel.

• Expectations regarding integrity, conflicts of interest, and confidentiality.

• Prohibition of gifts, bribes, or facilitation payments.

• Reporting obligations for suspected violations.

The Code is distributed to all new hires and is reviewed annually by management. It serves as a practical guide for ethical decision-making.

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4. Public Sector Compliance Measures

Given our involvement in government-related projects, we have adopted internal procedures to mitigate risks related to public procurement, including:

• Pre-bid Risk Review: Management reviews every solicitation and tender response for compliance and ethical risks.

• Contract Execution Controls: All contracts are signed only by authorized personnel and stored in a secure and auditable manner.

• Government Interaction Guidelines: Only designated representatives may engage with public officials; such interactions are logged when appropriate.

These controls are designed to prevent misconduct in accordance with the Foreign Corrupt Practices Act (FCPA), the Federal Acquisition Regulation (FAR), and relevant state/local rules.

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5. Training and Awareness

We provide periodic internal training to employees, including:

• Introduction to the Code of Ethics.

• Recognition and prevention of ethical and legal risks.

• Guidance on handling interactions with public sector clients.

• Reinforcement of our reporting and escalation mechanisms.

Training is adjusted to reflect evolving laws, risks, and the specific duties of each team member.

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6. Reporting

We encourage a speak-up culture. Any employee, contractor, or third party can report suspected violations through the following channel: compliance@cytricpartners.com
All reports are confidential and may be made anonymously. Retaliation against whistleblowers is strictly prohibited and subject to disciplinary action.

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7. Oversight and Continuous Improvement

The company’s leadership is responsible for enforcing and updating this Program. We conduct annual reviews of our compliance practices and adapt as necessary to meet legal and operational developments.

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8. Document Retention and Record-Keeping

We maintain records of:

• Training sessions conducted.

• Acknowledgment forms of the Code of Ethics.

• Communication logs with public agencies, when applicable.

• All compliance reports and resolutions.

These documents are stored securely and retained according to applicable regulations and internal policy.

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This Integrity and Compliance Program demonstrates our ongoing commitment to responsible business conduct. We view integrity not only as a legal obligation but as a core value essential to our long-term success and reputation.

For more information, please contact our compliance team at: compliance@cytricpartners.com.

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