01Purpose

LDA Digital Solutions is committed to conducting business with integrity, transparency, professionalism, and respect for applicable laws.

This Code of Conduct and Anti-Corruption Policy sets out the standards expected from everyone acting for or on behalf of LDA Digital Solutions. It applies especially to personnel involved in Salesforce-related business, CRM consulting, implementation work, client advisory, public-sector-adjacent engagements, nonprofit projects, technology partnerships, and business development activities.

This policy is designed to support lawful and ethical business conduct, prevent bribery and corruption, protect client trust, and ensure that our work is carried out responsibly.

02Scope

This policy applies to:

• Employees, contractors, consultants, officers, managers, and owners of LDA Digital Solutions.
• Subcontractors, delivery partners, referral partners, advisors, agents, vendors, and other third parties acting on behalf of LDA Digital Solutions.
• Any person or organization representing LDA Digital Solutions in connection with client work, Salesforce-related business, public-sector opportunities, nonprofit engagements, commercial partnerships, or business development.

All covered persons are expected to read, understand, and follow this policy.

03Our Core Standards

LDA Digital Solutions expects all personnel and business partners to:

• Act honestly, fairly, and professionally.
• Comply with applicable laws, regulations, contractual obligations, and partner program requirements.
• Avoid bribery, corruption, fraud, kickbacks, misrepresentation, and improper influence.
• Protect confidential information, client data, intellectual property, and business records.
• Avoid conflicts of interest, or disclose them promptly.
• Compete fairly and respect fair competition rules.
• Maintain accurate records, invoices, expense reports, contracts, and communications.
• Report suspected misconduct in good faith.

No business opportunity, client relationship, or partner benefit is worth violating the law or compromising our integrity.

04Anti-Bribery and Anti-Corruption

LDA Digital Solutions prohibits bribery and corruption in any form.

Covered persons must not offer, promise, authorize, give, request, accept, or receive anything of value for the purpose of improperly influencing a decision, securing business, retaining business, obtaining a benefit, or gaining an unfair advantage.

“Anything of value” may include, but is not limited to:

• Cash or cash equivalents.
• Gifts, meals, travel, entertainment, or hospitality.
• Discounts, commissions, rebates, or referral fees.
• Charitable donations or sponsorships.
• Job offers, internships, consulting roles, or personal favors.
• Political contributions.
• Business opportunities or preferential treatment.

This prohibition applies whether the improper benefit is provided directly or indirectly through another person, company, consultant, subcontractor, referral partner, or intermediary.

05Compliance with Anti-Corruption Laws

LDA Digital Solutions requires compliance with applicable anti-corruption laws and standards, including where relevant:

• The U.S. Foreign Corrupt Practices Act (FCPA).
• The U.K. Bribery Act.
• Applicable anti-bribery, anti-corruption, procurement, sanctions, tax, and business integrity laws in the countries where LDA Digital Solutions operates or provides services.
• Salesforce partner compliance obligations and ethical business expectations.

Because LDA Digital Solutions works internationally, personnel must be careful not only to follow local law, but also to avoid conduct that could violate international anti-corruption standards.

06Government Officials and Public-Sector Interactions

Extra care is required when interacting with:

• Government officials or employees.
• Public agencies, ministries, municipalities, regulators, courts, or state institutions.
• State-owned or state-controlled companies.
• Public universities, public hospitals, public utilities, or public international organizations.
• Political parties, political candidates, elected officials, appointed officials, or royal family representatives.
• Close relatives or associates of government personnel.

LDA Digital Solutions personnel must not offer, promise, give, request, or accept anything of value to improperly influence a public-sector decision, procurement process, license, permit, grant, contract, inspection, certification, or regulatory outcome.

Any Salesforce-related government, public-sector, or state-owned entity opportunity must be reviewed by management before proposal submission, subcontractor engagement, or any offer of gifts, hospitality, sponsorship, donation, or referral arrangement.

07Facilitation Payments

LDA Digital Solutions prohibits facilitation payments.

A facilitation payment is a small payment or benefit intended to speed up or secure a routine government action, such as issuing a permit, processing paperwork, scheduling an inspection, or providing a public service.

Even when such payments are viewed as common in a local market, they are not allowed under this policy.

08Gifts, Meals, Travel, Hospitality, and Events

Reasonable business courtesies may be allowed only when they are:

• Lawful.
• Modest in value.
• Infrequent.
• Transparent.
• Properly documented.
• Consistent with the recipient organization’s rules.
• Not intended to influence a decision improperly.

Personnel must not offer or accept gifts, meals, travel, entertainment, or hospitality that could create a conflict of interest, appear improper, or influence a business or government decision.

The following are prohibited:

• Cash or cash equivalents, including gift cards.
• Luxury or excessive hospitality.
• Gifts or hospitality during active procurement or contract negotiations, unless approved by management and permitted by the recipient’s rules.
• Benefits offered to government personnel without prior management review.
• Anything intended to influence a decision or reward improper conduct.

When in doubt, personnel must ask management before offering or accepting any gift, meal, travel, hospitality, or event invitation.

09Charitable Donations, Sponsorships, and Community Activities

LDA Digital Solutions may support nonprofit, educational, community, technology, and civic initiatives when they align with our mission and are handled transparently.

Donations, sponsorships, grants, event support, or community contributions must not be used to improperly influence a client, government official, partner, procurement process, or business decision.

All charitable or sponsorship activity connected to a client, prospect, partner, public institution, or government-related organization must be documented and reviewed by management before approval.

10Political Contributions

LDA Digital Solutions does not make political contributions on behalf of the company unless permitted by law and approved in writing by management.

Company funds, resources, staff time, systems, branding, or events must not be used to support a political party, candidate, campaign, or political organization without prior written approval and legal review where required.

Personnel may engage in personal political activity on their own time and with their own resources, but they must not suggest that they represent LDA Digital Solutions unless authorized.

11Conflicts of Interest

Personnel must avoid situations where personal interests conflict, or appear to conflict, with the interests of LDA Digital Solutions, its clients, or its partners.

Examples of potential conflicts include:

• A personal financial interest in a client, supplier, subcontractor, or competitor.
• Hiring or supervising a close relative without disclosure.
• Receiving personal benefits from a vendor or client.
• Using company information or relationships for personal gain.
• Working on outside business that competes with LDA Digital Solutions.

Any actual, potential, or perceived conflict of interest must be disclosed to management as soon as possible.

12Third Parties and Business Partners

LDA Digital Solutions expects third parties acting on its behalf to follow the same ethical standards.

This includes subcontractors, consultants, agents, referral partners, implementation partners, advisors, vendors, resellers, and other intermediaries.

Third parties must not be used to make improper payments, hide misconduct, bypass client or partner requirements, or improperly influence business decisions.

Before engaging a third party for Salesforce-related business, public-sector work, government-related opportunities, or sensitive client engagements, LDA Digital Solutions may conduct appropriate risk-based due diligence. This may include reviewing:

• Business reputation.
• Ownership and management.
• Relevant experience.
• Government connections or conflicts of interest.
• Compensation structure.
• Role and necessity of the third party.
• Compliance history.

Red flags must be escalated to management before proceeding.

13Accurate Books, Records, and Expenses

LDA Digital Solutions requires accurate and complete business records.

Personnel must ensure that invoices, contracts, statements of work, expense reports, timesheets, client communications, payment records, and accounting entries fairly and accurately reflect the underlying transaction.

The following are prohibited:

• False or misleading invoices.
• Hidden payments or off-book accounts.
• Misclassified expenses.
• Unrecorded discounts, rebates, or commissions.
• Backdated documents.
• Misleading descriptions of gifts, meals, travel, sponsorships, or consulting fees.

Accurate records are essential to client trust, financial integrity, tax compliance, and partner compliance.

14Fair Competition

LDA Digital Solutions competes fairly and professionally.

Personnel must not enter into agreements or understandings with competitors to fix prices, divide markets, rig bids, restrict services, boycott customers or suppliers, or exchange competitively sensitive information.

Pricing, staffing, proposals, bids, and market decisions must be made independently and honestly.

15Data Protection, Confidentiality, and Responsible Technology Use

LDA Digital Solutions handles client information, business data, personal data, and confidential information with care.

Personnel must:

• Protect confidential information and client data.
• Use systems and data only for authorized business purposes.
• Follow applicable privacy, data protection, cybersecurity, and contractual requirements.
• Avoid unauthorized disclosure of client, partner, employee, or business information.
• Review AI-generated work for accuracy, confidentiality, and appropriateness before use.

Personnel must not upload confidential client data, personal data, credentials, contracts, or sensitive business materials into unauthorized tools or systems.

16Sanctions, Export Controls, and Restricted Parties

LDA Digital Solutions complies with applicable sanctions, export control, and restricted-party requirements.

Personnel must not conduct business in violation of applicable sanctions, export laws, trade restrictions, or partner compliance obligations.

Where a transaction involves restricted countries, high-risk jurisdictions, unusual payment structures, government entities, or unclear ownership, personnel must escalate the matter to management before proceeding.

17Training Requirements

All LDA Digital Solutions personnel touching Salesforce-related business are required to complete anti-corruption and ethics training during onboarding and at least every two years thereafter.

Training may include:

• The Salesforce Trailhead module, Ethics and Integrity for Salesforce Partners.
• Internal anti-corruption and ethics training.
• Online compliance modules.
• Live webinars or webinar recordings.
• Training provided by outside consultants, counsel, or qualified compliance resources.

LDA Digital Solutions will maintain reasonable records of anti-corruption training completion for personnel required to complete training.

18Reporting Concerns

Employees, contractors, partners, clients, and other stakeholders may report suspected bribery, corruption, fraud, conflicts of interest, abuse, data misuse, sanctions concerns, or other misconduct.

Reports should include as much detail as possible, including the persons involved, dates, documents, communications, and any relevant background. Reports will be reviewed by company management and escalated as appropriate.

19Non-Retaliation

LDA Digital Solutions prohibits retaliation against anyone who reports a concern in good faith or participates in a review or investigation.

Retaliation may include termination, demotion, reduced work opportunities, threats, harassment, intimidation, exclusion, or other negative treatment because someone raised a concern.

Anyone who believes they have experienced retaliation should report it immediately.

20Investigation and Corrective Action

LDA Digital Solutions will review reported concerns appropriately and take corrective action where needed. Corrective action may include:

• Additional training.
• Changes to procedures.
• Termination of a third-party relationship.
• Disciplinary action.
• Contract termination.
• Reporting to a client, partner, regulator, or legal authority where required.

Personnel are expected to cooperate honestly with any internal review.

21Monitoring, Review, and Updates

LDA Digital Solutions will review this policy periodically and update it as needed based on changes in law, business operations, partner requirements, client requirements, risk profile, or internal procedures.

This policy is maintained by management and should be reviewed at least every two years, or earlier if needed.

22Questions

Questions about this policy should be directed to:

23Acknowledgment

All covered personnel are expected to comply with this policy.

Failure to follow this policy may result in disciplinary action, termination of contract, termination of employment, removal from client work, or other appropriate action.