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Code Of Conduct For Business Associates

Management Summary

The Code of Conduct for Business Associates (“BA Code”) defines the fundamental values and standards of integrity that OneMind Services LLC (“OneMind”) expects its Business Associates to uphold in all interactions and transactions. This Code encompasses ethical, professional, financial, and behavioral aspects of business conduct and the repercussions of non-compliance. All Business Associates must adhere to this Code in full.

Introduction

"Business Associates" include all entities, Partners, individuals, or representatives providing products, services, equipment, or support to OneMind under any formal agreement, contract, or arrangement. Business Associates are an extension of OneMind’s values and reputation and are expected to maintain the highest standards of ethics and professionalism.

Non-compliance with this Code that impacts OneMind's reputation may result in contract termination or further legal action. Members of regulated professions may face consequences from their governing body and may be suspended from acting on OneMind’s behalf until cleared.

Perspective & Scope

This Code applies to all Business Associate activities. OneMind acknowledges these partners' essential role in preserving trust among clients, investors, and the public. As industries evolve rapidly, Business Associates must observe the highest ethical standards and comply with all legal and policy obligations while working with OneMind.

Purpose

This Code sets standards for conduct, ensuring ethical practices in all Business Associate dealings with OneMind. Where this Code is stricter than local laws, it shall prevail. If local laws are stricter, they must be fully observed.

Principles Of Conduct

Business Associates must:

  • Act with fairness, honesty, and good faith
  • Uphold the goals of OneMind
  • Respect the confidentiality and intellectual property of OneMind
  • Ensure employees understand and follow this Code
  • Provide a safe and respectful workplace
  • Avoid any appearance of impropriety
  • Follow all relevant laws and regulations
  • Compete fairly and never misrepresent their relationship with OneMind

Business Associates must not:

  • Bring disrepute to OneMind.
  • Misuse their position for personal gain
  • Disclose or misuse information gained from their engagement

Violation Reporting & Enforcement

Violations must be reported in good faith to the appropriate OneMind Manager or the designated contact. Repeated or serious breaches may lead to suspension or contract termination. Investigations will be conducted with fairness and confidentiality.

Key Policy Areas

  1. Financial, ESG & Accounting Practices : Business Associates must maintain complete, accurate, and timely financial records and assist in audits when requested. Compliance with ESG (Environment, Social, Governance) guidelines is mandatory.
  2. Gifts & Inappropriate Payments : Bribery, kickbacks, or undue influence are prohibited. Modest business courtesies must comply with applicable laws.
  3. Competition Laws : Collusion, market division, or price-fixing are strictly forbidden.
  4. Business Dealings : All representations to OneMind must be truthful and authorized. Misrepresentation or defamation of OneMind or its associates is prohibited.
  5. Government Dealings : Adherence to all public procurement and government compliance requirements is essential when acting on OneMind’s behalf.
  6. Insider Trading : Use of confidential information for personal or third-party financial gain is strictly prohibited.
  7. Intellectual Property : All IP belonging to OneMind must be respected. No Business Associate may claim rights to OneMind’s IP or use it without explicit permission.
  8. Confidentiality : Business Associates must protect sensitive information and disclose it only with authorization or if legally required.
  9. Conflict of Interest : Any potential conflicts must be declared. Situations involving relatives working with OneMind must be disclosed.
  10. No Representation on OneMind’s Behalf : Business Associates cannot make commitments or statements on behalf of OneMind without written authorization.

Documentation & Audits

Business Associates must maintain records proving adherence to this Code. OneMind may audit Business Associate operations to ensure compliance.

Reporting Violations

Violations can be reported by contacting:

Email: compliance@onemindservices.com

Phone: 1-408-540-6771

Confidentiality will be maintained, and retaliation is prohibited.

Administration of the Code

The Corporate Compliance Office of OneMind Services LLC administers the Code. Following formal investigative procedures, all concerns will be addressed confidentially and fairly.

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