Squid Ink LLC Anti-Corruption & Ethical Conduct Policy

Effective Date: January 1, 2026
Applies To: All employees, contractors, officers, and third parties acting on behalf of Squid Ink LLC (“Squid Ink”)

1. Purpose

Squid Ink LLC is committed to conducting business with integrity, transparency, and fairness. This policy establishes clear expectations to prevent bribery, corruption, and unethical business practices in all operations, including sales, partnerships, and vendor relationships.

2. Zero-Tolerance Policy

Squid Ink maintains a zero-tolerance approach to bribery and corruption. No employee, contractor, or partner may:

• Offer, give, request, or accept anything beyond a reasonable value to improperly influence a business decision or to gain an unfair advantage

This applies to both private sector and government interactions.

3.  Scope of Risk (Relevant to Squid Ink)

As a data storage and security reseller, Squid Ink operates in environments where corruption risks may arise, including:

• Channel partnerships (VARs, MSPs, distributors)
• Vendor/OEM relationships
• Enterprise procurement processes
• Public sector or regulated industries
• International transactions (current or future)

All such activities are covered by this policy.

4. Gifts, Meals, and Entertainment

Reasonable business courtesies are permitted if they meet all of the following criteria:

• Modest in value (generally <$500 unless approved)
• No cash transactions
• Infrequent and not excessive
• Compliant with the recipient’s company policies

5. Third Parties & Channel Partners

Squid Ink may be held responsible for the actions of third parties acting on its behalf. This includes:

• Resellers
• Agents
• Consultants
• Distributors
• Referral partners

Requirements:

• Partners must operate with integrity and comply with anti-corruption laws
• Commission structures must be transparent and documented

Red flags include:

• Requests for unusual payment structures
• Requests for payments to offshore or unrelated entities

6. Government & Public Sector Interactions

Special care must be taken when dealing with:

• Government agencies
• Public universities
• State/local/federal employees
• Government-owned enterprises

Rules:

• No gifts, payments, or favors to government officials without explicit approval
• Follow stricter standards where required
• Ensure all bids and contracts are handled transparently

7. Accurate Books & Records

All business transactions must be:

• Accurately recorded
• Transparent and justifiable
• Properly approved

Squid Ink prohibits:

• Off-the-books accounts
• Mislabeling expenses (e.g., disguising bribes as “marketing”)
• False invoices or documentation

8. Reporting Concerns

If you see something questionable, speak up.

Examples:

• Suspicious payment requests
• Unusual partner behavior
• Pressure to “do whatever it takes” to close a deal

Reporting Options:

• Directly to leadership (Founder/Management)
• Or via designated internal reporting channel (as established)

No retaliation will be tolerated against anyone who raises concerns in good faith.

9. Accountability & Enforcement

Violations of this policy may result in:

• Termination of employment or contract
• Termination of partner relationships
• Legal action where applicable

10. Compliance with Laws

Squid Ink complies with all applicable anti-corruption laws, including but not limited to:

• U.S. anti-bribery laws
• International anti-corruption regulations where applicable

11. Practical Guidance

When making decisions, ask:

• Would I be comfortable if this were made public?
• Is this influencing a decision unfairly?
• Does this align with our values and long-term reputation?

12. Acknowledgment

All applicable individuals must acknowledge that they:

• Have read and understood this policy
• Agree to comply with its requirements

At Squid Ink, we believe trust is a competitive advantage. We win business through expertise, relationships, and integrity.

Jaslyn Scribner & Aaron Scribner, Co Founders