Code of Conduct

Code of Conduct (the Code) of PCDP LLC (the Company) establishes the values, principles and business practices that guide our business conduct. It does not cover every issue that may arise, but it covers a wide range of business practices and procedures. All of our employees, managers and directors (herein referred to as “Employee”) must conduct themselves in the most ethical manner possible, avoiding even the appearance of improper behavior. The Code is shared with business partners and third parties and we expect them to also honor and represent these principles.

PCDP’s good reputation depends on its integrity in business.

We are committed to a culture of honesty and accountability. Therefore, we must always act with the highest standards of ethics and integrity in all of our actions and business activities, internally and externally.

All employees and all others acting on behalf of PCDP must treat clients and contractors, and subcontractors with fairness and respect and to work jointly with them to fostering trusting, collaborative and constructive working relationships. In return we expect our clients, contractors, and subcontractors to treat our employees in the same manner, and to work with us to build those same relationships.

We adopt and implement the Code to ensure compliance with standards, laws and regulations applicable to all business activities. By fostering a well-organized, respectful, and collaborative environment, we can all work together to achieve our goals and uphold our shared values.

PCDP and all of its Employees must comply fully with the laws, rules and regulations applicable to the Company’s business activities. All employees must protect our company’s legality. Further, each of Employees must have an understanding of the laws, rules, regulations, and company policies, that affect our work.

Our Company is fully committed to protecting human rights in its sphere of influence. We undertake to refrain from any involvement in any violation of human rights, directly or indirectly. Furthermore, we expect our clients and contractors to treat all people with respect and fairness and to protect human rights within their sphere of influence

Equal Opportunity

Employees should conform with our equal opportunity policy in all aspects of the employment relationship, including recruiting, hiring, training, work assignment, promotion, transfer, termination, and wage and salary administration.

Diversity

Our Company is dedicated to fostering a workplace culture that values diversity. We recognize that differences among people, including gender identity, age, cultural heritage, religious beliefs, marital status, ethnicity, physical ability, socioeconomic status, sexual orientation, attitudes and experiences, and treat all employees with equal respect and supports everyone’s efforts and participation.

Discrimination and Harassment

The Company strictly prohibits all forms of discrimination, harassment or intimidation, including bullying, based on age, race, gender, national origin, religion, marital status, national service obligations, family responsibilities, pregnancy, childbirth, breastfeeding, or any other health or disability condition.

Preventing harassment in the workplace is an important aspect of fostering a respectful work environment. Harassment may be verbal, visual or physical. It may be non-sexual or sexual in nature. It may include many types of conduct, such as insults, abusive language, threats, intimidation, slurs, offensive jokes or visual displays, or unwelcome touching. Actions or words that could be taken as abusive, derogatory, discriminatory, hostile, improper, or offensive must be avoided.

No accidents, No harm to people and No damage to the environment.

We strictly adhere to both company and government safety, health and environmental regulations, striving to create a healthy, safe and motivating work environment to prevent injuries and accidents. It is the responsibility of each employee to maintain this healthy and safe workplace by following safety, health and environmental rules and practices and by reporting accidents, injuries and unsafe equipment, practices or conditions.

We are committed to sustainability by minimizing waste, using renewable energy, reducing pollution and creating long-lasting, efficient systems that benefit both people and the planet.

Employees has a continuing duty to maintain professional knowledge and skill at the level required to ensure that the Client and Employer receives competent professional services based on current developments in practice, legislation and techniques. Employees should act diligently and in accordance with applicable technical and professional standards.

PCDP is committed to an environment free from conflicts of interest. Conflicts of interest can arise in a variety of situations, typically involving personal relationships, outside activities, financial interests, business opportunities and family members.

A conflict of interest arises when the personal interests of an individual in any way interfere with the interests of the Company; or may occur when an employee’s actions or personal interests interfere with the employee’s ability to effectively perform his or her work of the Company; or if the employee or members of his family receive improper personal benefits, such as consumer loans, benefits or payments, for services related to the Company’s activities in connection with his or her position; or often occur when people gain personal benefit from accessing sensitive and confidential information without permission.

Employees are strongly encouraged to seek clarification and discuss potential conflicts of interest with a representative from Administration and Human Resources. Any employee who becomes aware of a conflict or potential conflict has a duty to disclose it to the appropriate managers or directors of the Company as soon as possible.

Decisions related to the Company’s business must always be based on the Company’s objectives and made with appropriate authority and without conflicts of interest. We avoid conflicts of interest and never use our position or company assets for personal gain.

Employees must comply with applicable competition laws. We prohibit engaging in unfair or illegal practices for profit, whether in our interactions with business partners and competitors or in any other aspect. We are conduct business on the basis of free and fair competition.

The Company does not support any actions aimed at gaining an unfair competitive advantage. No person is permitted to engage in any activity that violates any applicable agreements entered into with a third party, and no person may directly or indirectly use or disclose any confidential information or trade secrets that individual obtained while employed by or associated with such a third party.

The Company is committed to complying with all applicable laws and regulations relating to government (public procurement) contracts and services and to ensuring that its reports, certifications and declarations to government officials are accurate and complete and that any deviations from contract requirements are properly approved.

We committed to conducting business practices in full compliance with anti-corruption laws and regulations applicable to the Company’s business.

We have zero tolerance for any corruptions in business activities, bribes or other improper or unauthorized payments that directly and indirectly make, offer or promise to make, kickbacks, benefits, or advantages to any person, individual, organizations or entity, are prohibited.

Sponsorships or donations to non-political organizations should be transparent and should not be made for the purpose of influence pending decisions.

We do not associate with entities, whether organizations, companies, or private individuals, which make use of corrupt methods and refuse to enter into any contractual agreements with such entities.

We respect the privacy and dignity of all individuals and safeguard the confidentiality of employee records and information.

Integral to our business success is our protection of confidential company information, as well as non-public information entrusted to us by employees, customers and other business partners. Confidential and proprietary information includes such things as pricing and financial data, customer names/addresses or non-public information about other companies, including current or potential suppliers and vendors. We will not disclose confidential and non-public information without a valid business or legal purpose and proper authorization.

We ensure that when handling financial and personal information of our clients or other parties, only the necessary information required for our business is collected, used and stored. We will obtain any relevant information directly from the person or entity concerned and will only use reputable and reliable sources to supplement this information.

We will retain information only for as long as required or required by law and will maintain the physical security of such information.

Company resources are provided for company business use. The Company resource include physical property, such as facilities, supplies, equipment, inventory, vehicles and the Company funds, as well as include intangible assets, such as confidential and proprietary information, intellectual property and information systems.

Employees must respect and protect our company’s resources, both physical and intangible. Although personal use is permitted, they should use them responsibly and not disrupt the workplace or affect work productivity. The Company equipment such as computers, copiers and fax machines should not be used for outside business or activities such as religion or politics.

In order to protect the interests of the Company network and our employees, we reserve the right to monitor or review all data and information contained on an employee’s company-issued computer or electronic device, the use of the Internet or local intranet.

We will not tolerate the use of Company resources (including email, instant messaging, the Internet or Company portal) to create, access, store, print, request or send any material that is abusive, threatening, offensive, sexually explicit, online gambling, betting services or otherwise offensive or inappropriate.

All Company property in the employee’s possession, as well as records of any kind, confidential or not, must be returned to/remain with the Company.

Intellectual Property

To protect the Company’s intellectual property, never disclose them to anyone outside the Company unless the Employee has express permission and is subject to a non-disclosure agreement, if applicable. Do not disclose such information, even within the Company, unless the individual has a business need to know it. Confidentiality is maintained even after the Employee has left the Company.

To the extent permissible by law, the rights to all intellectual property created with the Company materials, on the Company time, at the Company expense or within the scope of our duties belong to the Company. Just as we expect others to honor our intellectual property rights, we must respect the rights of others, including compliance with licensing and other similar agreements.

Data Security and Cybersecurity

Employees must comply with applicable privacy and data security laws, as well as applicable contractual requirements when handling personal information and business data collected in the course of conducting business. Failure to do so is not only a breach of this Code, but also, potentially a breach of civil and/or criminal laws related to data protection.

Our priority is to prevent information security breaches when working with both clients and company information. We recognize how important it is to keep our data and our clients’ data secure. We may take measures such as encryption, access controls, training programs and procedures to ensure the protection of information security and prevent future information breaches.

Classified or Proprietary Information

In the course of employment, Employee may have access to intellectual property, trade secrets, proprietary information and confidential information, which is the exclusive property of the Company. Employee must not copy, reproduce, extract, translate, disclose, publish, or deal with confidential information in a manner that is not authorized.

Employee is not allowed to disclose any classified or proprietary information without authorization. In addition, we must avoid discussing confidential information in places where we can be overheard, including restaurants, restrooms, taxis, airplanes, elevators or the Company common areas.

Employees who have access to or are in control of such information should at all times provide adequate safeguards to prevent its abuse or misuse such as disclosing information in exchange for monetary compensation or using information for personal interest. It should be noted that unauthorized disclosure of any personal data may result in a breach of the applicable legislation on privacy.

Any Employee leaving the employment of the Company are to surrender all confidential information in their possession to their manager and if the same cannot be surrendered, to destroy such confidential information. They may not retain any copy of any confidential information in whatever form for themselves. Former employees are absolutely and strictly prohibited from disclosing or using any confidential information for any reason whatsoever.

All employees and third parties working with PCDP are required to know and abide by the values and standards set out in this Code. If there is any uncertainty about a company’s policy, questions should be asked. Any person who suspects that standards are not being met or is aware of violations of the Code should contact company management. We take the standards set out in the Code seriously and any violations will result in disciplinary action.

We will not retaliate against any individual for filing a good-faith concern regarding non-compliance with this Code or any other Company policy. We will not retaliate against any individual participating in the investigation of any such complaint either. Finally, we will not tolerate any such retaliation by any manager or executive officer, or by any company with which we contract.

PCDP has zero tolerance when it comes to bribery and corruption, fraud and other non-compliance with our Code of Conduct.

If non-compliance with the Code of Conduct is reported or suspected, we will take action to investigate and, where necessary, correct the situation. Individuals who violate our Code of Conduct, other policies and guidelines, or any laws will be subject to appropriate disciplinary action, which may include termination. If any of our business partners violates our Code of Conduct, we consider this to be reason for terminating our business relationship.

Following this Code is important for all of us at PCDP and to our business partners. It helps to build our business and it helps to protect us.

Employees must report any violations of the Code to the Management team or the Administration Office for appropriate action. Also, Employee should speak to them when they have a question about the application of the Code or when in doubt about how to properly act in a particular situation.

Employees have the option to report violations of the Code or raise a concern, anonymously, confidentially, and without fear of retaliation by contacting the Administration Office.