Ethics & Compliance Homeward · NeotericX Incorporated Version 1 · 2026-10-30 00:00:00 Build with integrity. Compete fairly. Speak up when something is wrong. These are responsibilities we bring to the business we are building. ## Homeward and NeotericX Homeward is owned and operated by NeotericX Incorporated. This NeotericX corporate commitment applies to Homeward as relevant to its activities. Commitments and planned controls are not a claim of completed implementation or independent certification. ## Our code of conduct We expect people acting for NeotericX to act honestly, comply with applicable requirements, respect others, protect entrusted information, and maintain accurate records. A commercial opportunity does not justify bribery, deception, exploitation, or interference with protected rights. Managers are responsible for setting clear expectations, seeking appropriate advice, and responding to concerns. Our internal policy library provides draft operating procedures for formal review and adoption; publication of a policy is not evidence that every control has been implemented or audited. ## Fair business and anti-corruption We prohibit bribes, kickbacks, and improper payments offered directly or through intermediaries. Gifts, hospitality, donations, sponsorships, and business expenses must have a legitimate purpose and must not be used to improperly influence a decision. We will evaluate heightened risks involving public officials, agents, transactions, and business partners before proceeding. Actual or potential conflicts of interest should be disclosed and reviewed. People with a conflict should not approve their own transaction or control its review. Records must describe the real purpose of a transaction; false invoices, concealed payments, and misleading entries are unacceptable. ## Responsible technology and national security We will review applicable licensing, export, sanctions, privacy, AI, and investment requirements before covered activities. We will not knowingly facilitate prohibited transfers or diversion of technology, sensitive information, or resources. Required approvals and authorizations must be obtained at the legally required stage. ## Respect for people and their rights Our standards include nondiscrimination, reasonable accommodation, freedom of association, support for unionization, and protection from retaliation. Confidentiality and conduct rules must not be used to suppress protected workplace discussions, collective action, whistleblowing, or reports to regulators. ## Raise a concern Email info@neotericx.info with the subject “Ethics concern.” Share a concise description, relevant dates, and a safe way to contact you. Do not include passwords, classified information, medical records, or other unnecessary sensitive material. We will seek appropriate review, limit access to those who need it, and take corrective action when warranted. This is a company contact mailbox, not an independently operated or 24-hour hotline. We cannot promise anonymity or absolute confidentiality. You may contact an appropriate agency, union representative, or legal adviser directly without company permission. No internal report is required first. ## Accountability as we grow Our implementation approach calls for named owners, proportionate due diligence, training, documented approvals, records, and periodic review. Formal adoption, independent reporting arrangements, and verified implementation are tracked separately from these public commitments. We will revise procedures when our activities or applicable requirements change.