Code of Business Conduct and Ethics

Organization: Igzibo Engineering Solutions, Inc.
Version: 1.1
Status: Living policy
Effective Date: September 16, 2026
Owner: Igzibo Engineering Solutions, Inc.
Review Cycle: At least annually and after material legal, organizational, or business changes.

1. Purpose

This Code of Business Conduct and Ethics establishes baseline expectations for honest, lawful, professional, and responsible conduct when representing or performing work for Igzibo Engineering Solutions, Inc.

The Code is intended to protect Igzibo, its personnel, candidates, clients, vendors, business partners, intellectual property, information, and reputation.

2. Scope

This Code applies to:

• Employees.
• Contractors.
• Consultants.
• Interns and temporary workers.
• Officers and directors where applicable.
• Recruiters and staffing personnel acting for Igzibo.
• Other representatives acting on behalf of Igzibo.

Igzibo may require vendors and other business partners to agree to separate contractual conduct requirements.

Definitions

Confidential Information: Non-public information requiring controlled access under the Data Classification and Handling Standard.

Conflict of Interest: A situation in which personal, financial, professional, or other interests could improperly influence, or appear to influence, a person's duties for Igzibo.

Igzibo: Igzibo Engineering Solutions, Inc.

Improper Payment: Money, benefit, gift, favor, or other thing of value provided or offered for an unauthorized or improper purpose.

Personal Information: Information relating to an identified or identifiable individual.

Representative: A person authorized to act for or on behalf of Igzibo.

AI (Artificial Intelligence): A machine-based system capable of generating predictions, recommendations, decisions, content, or other outputs based on inputs.

4. Core Principles

Personnel and representatives must:

1. Act honestly.
2. Comply with applicable law and binding requirements.
3. Protect confidential information.
4. Treat people professionally and respectfully.
5. Avoid conflicts of interest.
6. Protect client interests and contractual obligations.
7. Maintain accurate business records.
8. Protect organizational resources.
9. Report suspected misconduct.
10. Cooperate with authorized investigations.

5. Compliance With Law and Contracts

Igzibo personnel must comply with applicable law and binding contractual requirements.

Where a client or contract establishes requirements more restrictive than an Igzibo policy, personnel must follow the applicable requirement unless doing so would violate law.

No business objective authorizes unlawful conduct.

6. Honesty and Accurate Representation

Personnel must not knowingly:

• Make false statements to clients, candidates, vendors, or business partners.
• Falsify qualifications or experience.
• Alter records to misrepresent work performed.
• Misrepresent project status.
• Misrepresent candidate qualifications.
• Conceal material errors.
• Submit false invoices or expense claims.
• Manipulate business records.

Technical, recruiting, project, and financial information should be presented accurately and with appropriate context.

7. Confidentiality

Personnel must protect Igzibo and client information.

Confidentiality requirements apply during and after a person's engagement where applicable.

Confidential information must be handled according to:

• Data Classification and Handling Standard.
• Technology Acceptable Use Policy.
• Applicable client requirements.
• Confidentiality agreements.
• Employment or contractor agreements.

8. Intellectual Property

Personnel must respect:

• Igzibo intellectual property.
• Client intellectual property.
• Third-party intellectual property.
• Open-source licenses.
• Software licenses.
• Copyrights, patents, trademarks, and trade secrets.

Personnel must not use or disclose another party's proprietary material without authorization.

Ownership and assignment of work product are governed by applicable contracts and agreements.

9. Conflicts of Interest

Personnel must disclose actual, potential, or apparent conflicts of interest.

Examples may include:

• Outside employment affecting Igzibo duties.
• Personal financial interests in a vendor.
• Recruiting a close personal relationship without disclosure where the relationship could affect a business decision.
• Accepting benefits from a party seeking business from Igzibo.
• Using Igzibo opportunities for personal gain.
• Directing business to a related party without appropriate disclosure and authorization.

The existence of a potential conflict does not necessarily mean that conduct is prohibited. The conflict must be disclosed and evaluated.

10. Gifts, Hospitality, and Benefits

Personnel must not accept or provide gifts, entertainment, travel, favors, or other benefits when they are intended to improperly influence a business decision or could reasonably create that appearance.

Particular care is required when dealing with:

• Government personnel.
• Clients.
• Candidates.
• Vendors.
• Recruiting partners.
• Procurement personnel.
• Parties involved in contract negotiations.

Anti-bribery requirements apply regardless of whether a payment is described as a gift, commission, referral fee, consulting fee, expense, or another business expense.

11. Anti-Bribery and Improper Payments

Igzibo prohibits bribery, kickbacks, and other improper payments.

Personnel must not offer, promise, authorize, provide, request, or accept anything of value for an improper business purpose.

Third-party intermediaries must not be used to accomplish conduct that Igzibo personnel could not lawfully or ethically perform directly.

Additional requirements are established in the Anti-Bribery and Anti-Corruption Policy.

12. Recruiting and Candidate Conduct

Recruiting personnel must:

• Represent opportunities accurately.
• Protect candidate information.
• Obtain appropriate authorization before sharing candidate information.
• Avoid discriminatory or prohibited recruiting practices.
• Avoid manipulating candidate qualifications.
• Avoid submitting candidates without appropriate authorization.
• Respect client recruiting requirements.
• Disclose material conflicts.
• Protect confidential information belonging to candidates, clients, and other employers.

13. Client Relationships

Personnel must:

• Act within authorized scope.
• Protect client information.
• Communicate material risks and issues appropriately.
• Avoid unauthorized commitments.
• Avoid representing that Igzibo has authority it does not have.
• Follow client-specific requirements.
• Escalate material disputes or risks.

14. Financial Integrity and Records

Business records must be accurate and maintained appropriately.

Personnel must not:

• Falsify invoices.
• Create false expense records.
• Conceal liabilities.
• Misstate revenue or costs.
• Circumvent approval controls.
• Use company funds for unauthorized purposes.

Records must be retained according to applicable requirements.

15. Security and Technology

Personnel must comply with applicable Igzibo technology and security requirements, including:

• Technology Acceptable Use Policy.
• Identity and Access Management Standard.
• Data Classification and Handling Standard.
• AI and Generative AI Usage Standard.
• Technology and Third-Party Service Security Standard.
• Security Incident Response Procedure.

Security incidents and suspected misconduct must be reported promptly.

16. Respectful Workplace

Igzibo expects professional conduct.

Harassment, threats, intimidation, discrimination, retaliation, and abusive conduct are not permitted.

The Equal Employment Opportunity and Anti-Discrimination Policy establishes additional requirements.

17. Use of Organizational Resources

Organizational resources must be used for authorized purposes.

Personnel must not use Igzibo resources for:

• Fraud.
• Unauthorized commercial activity.
• Unauthorized access.
• Malicious activity.
• Concealment of misconduct.
• Activities that materially interfere with business operations.

18. Reporting Concerns

Personnel should promptly report suspected:

• Fraud.
• Bribery.
• Conflicts of interest.
• Security incidents.
• Privacy incidents.
• Harassment or discrimination.
• Misuse of organizational resources.
• Falsification of records.
• Unauthorized disclosure.
• Other serious misconduct.

Reports should be made through the reporting channel designated by Igzibo.

19. Non-Retaliation

Igzibo prohibits retaliation for making a good-faith report of suspected misconduct or participating in an authorized investigation, subject to applicable law.

A knowingly false report made for a malicious purpose may itself violate this Code.

20. Investigations

Personnel must cooperate with authorized investigations.

Information related to an investigation must be protected from unauthorized disclosure.

Personnel must not destroy, alter, conceal, or improperly remove records relevant to an investigation or legal hold.

21. Enforcement

Violations may result in:

• Additional training.
• Corrective action.
• Access restrictions.
• Contractual remedies.
• Removal from an engagement.
• Employment action where applicable.
• Termination of a business relationship.
• Legal action where appropriate.

Enforcement will be subject to applicable law and contractual requirements.

22. Exceptions

Exceptions require documented approval from an authorized Igzibo representative where an exception is legally and operationally permissible.

No exception may authorize unlawful conduct.

23. References and Research Basis

This Code was informed by:

• U.S. Department of Justice and U.S. Securities and Exchange Commission, FCPA Resource Guide
• Federal Trade Commission, Protecting Personal Information: A Guide for Business

These sources provide general guidance and do not replace applicable law or legal advice.

Version History