Compliance and Ethics Policy

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Effective Date: October 2025
Last Updated: October 7, 2025

1. Commitment to Integrity

At Cedero Global LLC, we are committed to conducting business with honesty, transparency, and respect for all applicable laws and international standards.

Our reputation is built on trust — with clients, suppliers, and regulators — and we maintain zero tolerance for unethical or illegal practices in any form.

2. Legal and Regulatory Compliance

Cedero Global operates in full compliance with:

• U.S. federal and state laws, including trade and export regulations;
• International trade controls, including the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) and the Bureau of Industry and Security (BIS);
• Customs, environmental, and maritime regulations applicable to the import, export, and transportation of goods;
• Anti-corruption and anti-money laundering (AML) laws, including the U.S. Foreign Corrupt Practices Act (FCPA) and equivalent international standards.
   

We maintain up-to-date screening processes and business partner due diligence to prevent involvement with sanctioned entities, prohibited transactions, or restricted goods.

3. Ethical Business Conduct

Our business principles are guided by integrity and accountability:

• No Bribery or Corruption: We do not tolerate offering, requesting, or accepting bribes or improper advantages under any circumstances.
• Fair Competition: We promote open and fair trade practices and comply with applicable antitrust laws.
• Transparency: All contracts, transactions, and representations are handled truthfully and documented accurately.
• Responsible Sourcing: We work only with partners who meet recognized ethical, legal, and environmental standards.
   

4. Trade Compliance Program

Cedero Global maintains a structured compliance program that includes:

• Partner screening through U.S. and international sanction lists (OFAC, BIS, UN, EU);
• Transaction-level due diligence for sensitive materials or regions;
• Verification of export classification (ECCN/HTS codes) and licensing when required;
• Recordkeeping and reporting procedures aligned with federal regulations.
   

We continuously monitor and update our controls to reflect changes in law and industry best practices.

5. Data and Confidentiality

Confidentiality and data integrity are essential to our business relationships.

We protect all proprietary, client, and personal information according to our Privacy Policy and relevant data protection regulations, including GDPR and CCPA frameworks.

6. Environmental and Social Responsibility

Cedero Global recognizes the importance of sustainable business practices and aims to:

• Minimize environmental impact in logistics and operations;
• Promote energy efficiency and responsible material handling;
• Support fair labor and safety standards across its supply chain.
   

We believe ethical trade also means responsible trade — balancing economic opportunity with environmental and social respect.

7. Reporting Concerns

Cedero Global encourages employees, partners, and stakeholders to report any compliance or ethical concerns confidentially.

Reports may be submitted directly to compliance@cederoglobal.com.
All reports are reviewed promptly and without retaliation against the reporting party.

8. Continuous Improvement

Compliance and ethics are not static. Cedero Global reviews its practices regularly, trains its partners and representatives, and collaborates with industry bodies to ensure alignment with evolving global standards.

9. Contact

Cedero Global LLC
273 Palisade Avenue, Apt 1
Cliffside Park, New Jersey 07010
📧 compliance@cederoglobal.com
🌐 www.cederoglobal.com