Code of Conduct

1. Purpose and scope

Duskbridge, Inc. is the parent holding company of the group. This code applies to the directors, officers, employees, and contractors of Duskbridge and of each Duskbridge operating company, and it states the conduct Duskbridge expects of the vendors, subcontractors, and partners who work with the group. An operating company may maintain its own more specific policies, including the contractor business ethics standards that attach to federal work; this group code sets the floor, not the ceiling.

2. Standards of conduct

• Deal honestly. No false statement, misrepresentation, or deceptive practice toward a customer, a government agency, an investor, a partner, or a colleague.
• Follow the law wherever the group operates, including anti-corruption and anti-bribery law, procurement integrity rules on government work, competition law, export and sanctions rules where they apply, and employment and workplace law.
• Avoid conflicts of interest, and disclose a potential conflict promptly rather than managing it privately.
• Protect confidential information and personal information, handle data only for the purposes it was provided, and follow the group's published privacy commitments.
• Keep accurate books and records. No off-record accounts, no falsified entries, and no records destroyed outside a retention schedule or in the face of a legal hold.
• Offer and accept only reasonable, lawful business courtesies. Nothing of value may be offered to a government official to influence an official act.
• Maintain a professional workplace free of harassment, discrimination, and retaliation.
• Build and operate technology responsibly, consistent with the group's doctrine that governance is architecture, including auditability and human oversight of consequential automated systems.

3. Vendors, subcontractors, and partners

Duskbridge expects the parties it works with to meet the same standards: honest dealing, lawful conduct, protection of information entrusted to them, and prompt disclosure of a problem that affects the group or its customers. A vendor or subcontractor who observes conduct inconsistent with this code in connection with group business is asked to report it through the route below.

4. How to report a concern

To report suspected misconduct, a conflict of interest, an ethics concern, or a violation of this code, email contact@duskbridge.com with the subject line Conduct report. The mailbox is monitored, and a message marked Conduct report is handled confidentially at the group level rather than as an ordinary business inquiry. A report may also be sent by mail to Duskbridge, Inc., 8100 Wyoming Blvd STE M4-301, Albuquerque, NM 87113, United States. This email and mail route does not depend on the website contact form and remains available if the form is unavailable.

A report may be made anonymously, including from an email address that does not identify you. Providing contact information is encouraged because it allows follow-up questions, but it is not required for a report to be reviewed.

5. Non-retaliation

Duskbridge does not tolerate retaliation against anyone who raises a concern in good faith or participates in a review. Retaliation is itself a violation of this code and should be reported through the same route.

6. How reports are handled

Conduct reports are treated as confidential and shared only with the people needed to review the matter. Where a reply address is provided, Duskbridge targets an acknowledgement within 5 business days. Review findings and any corrective action are recorded at the group level, and matters that require it are escalated to counsel or to the appropriate authority.

7. Governance and review

This code is owned at the Duskbridge group level and reviewed at least annually. Duskbridge will update the date above when this page changes. Questions about the code that are not reports can be sent through the contact form.