Anti-Bribery and Anti-Corruption Policy

1. PURPOSE & SCOPE

VORDR International LLC (“VORDR” or the “Company”) is committed to conducting all intelligence, cybersecurity, and risk mitigation operations with the highest standards of integrity, professionalism, honesty, and legal compliance.

The Company maintains a strict zero-tolerance policy toward bribery, corruption, fraud, and unethical financial conduct in any form.

This Anti-Bribery & Anti-Corruption Policy (“Policy”) is established to ensure compliance with:

• The U.S. Foreign Corrupt Practices Act (FCPA)

• The UK Bribery Act

• Applicable anti-corruption and anti-money laundering laws

• International procurement and ethical business standards

across all jurisdictions in which VORDR operates, participates in tenders, or conducts security and intelligence activities.

This Policy applies to all:

• Directors

• Officers

• Employees

• Independent Sales Representatives (1099 Contractors)

• Consultants

• Advisors

• Vendors

• Subcontractors

• Third-Party Representatives

(collectively referred to as “Associated Persons”).

2. PROHIBITED CONDUCT

All Associated Persons are strictly prohibited from engaging in bribery, corruption, facilitating payments, or unethical influence practices.

Prohibited conduct includes, but is not limited to:

Offering or Giving Bribes

You may not directly or indirectly:

• Offer

• Promise

• Authorize

• Provide

any financial or non-financial advantage — including cash, gifts, services, favors, travel, entertainment, or hospitality — to any individual, public official, government entity, or private organization for the purpose of:

• Improperly influencing a decision;

• Securing a contract;

• Obtaining confidential information; or

• Gaining an unfair business advantage.

Soliciting or Accepting Bribes

Associated Persons may not:

• Request

• Agree to receive

• Accept

any payment, gift, favor, or benefit intended to compromise VORDR’s impartiality, ethics, operational integrity, or professional judgment.

Facilitating Payments (“Grease Payments”)

VORDR strictly prohibits facilitating or unofficial payments intended to expedite routine governmental actions, including but not limited to:

• Customs clearances

• Permits

• Licensing approvals

• Administrative processing

regardless of local customs or practices.

Corruption in Procurement & Tendering

Associated Persons shall not engage in:

• Bid-rigging

• Collusive tendering

• Procurement manipulation

• Improper incentive arrangements

• Undisclosed kickbacks

during any public or private contracting process, including government, military, institutional, or commercial tenders worldwide.

3. GIFTS, HOSPITALITY & ENTERTAINMENT

VORDR recognizes that reasonable and lawful business hospitality may occur in professional environments. However, such hospitality must never create the appearance of improper influence or conflict of interest.

Transparency Requirements

Any gift, hospitality, or entertainment offered or received on behalf of VORDR must be:

• Reasonable

• Proportionate

• Business-related

• Legally permissible

• Properly documented

and must never compromise professional objectivity.

Strict Prohibitions

Under no circumstances may gifts, hospitality, entertainment, or financial incentives be offered to or accepted from:

• Public officials

• Procurement personnel

• Military representatives

• Government contracting authorities

during active:

• Tender processes

• Contract negotiations

• Procurement evaluations

• Regulatory reviews

4. THIRD-PARTY DUE DILIGENCE & 1099 REPRESENTATIVES

Because VORDR operates under internationally recognized compliance and quality standards, all third-party relationships are subject to rigorous integrity assessments.

Vetting & Background Screening

All third-party representatives, consultants, subcontractors, and 1099 contractors must undergo appropriate due diligence and vetting prior to onboarding.

This process may include:

• Background investigations

• Compliance reviews

• Conflict-of-interest assessments

• Credential verification

• Risk evaluations

Contractual Compliance Obligations

All agreements with third parties must contain explicit clauses requiring compliance with:

• This Policy

• Anti-corruption laws

• FCPA requirements

• Applicable international compliance regulations

Red Flags & Immediate Termination

The following may constitute immediate grounds for suspension or termination of a business relationship:

• Requests for cash payments

• Offshore payment routing without justification

• Lack of transparency

• Refusal to provide documentation

• Suspicious financial structures

• Evidence of unethical conduct

VORDR may also report unlawful activity to appropriate regulatory or law enforcement authorities.

5. INTEGRATION WITH CYBERSECURITY & DATA PROTECTION

(NIST SP 800-171 & CMMC)

VORDR recognizes that cybersecurity failures and corruption risks are often interconnected.

In alignment with:

• NIST SP 800-171

• Cybersecurity Maturity Model Certification (CMMC)

• ISO 9001:2015

the Company maintains strict cybersecurity and information protection controls designed to prevent:

• Corporate espionage

• Financial manipulation

• Unauthorized access

• Procurement fraud

• Data compromise

• Insider threats

All personnel are required to comply with established security protocols relating to:

• Controlled Unclassified Information (CUI)

• Client intelligence

• Internal operational systems

• Secure communications

• Access control procedures

6. REPORTING VIOLATIONS

Any individual who becomes aware of suspected bribery, corruption, fraud, or unethical conduct must immediately report the concern through authorized Company reporting channels.

Reports may be submitted confidentially to:

Support@vordrinternational.net

VORDR strictly prohibits retaliation against any person who reports concerns in good faith.

7. DISCIPLINARY ACTION & ENFORCEMENT

Violations of this Policy may result in severe disciplinary action, including:

• Employment termination

• Immediate cancellation of contractor agreements

• Civil liability

• Criminal prosecution

• Referral to regulatory or law enforcement authorities

VORDR reserves the right to cooperate fully with federal, state, and international investigative agencies.

8. CONTINUOUS COMPLIANCE & REVIEW

This Policy shall be reviewed periodically to ensure ongoing compliance with evolving:

• Anti-corruption regulations

• International business standards

• Cybersecurity requirements

• Quality management obligations

All personnel may be required to complete periodic compliance certifications and anti-corruption awareness training.