Compliance and Ethics Policy

I. Introduction

Methodic LLC is committed to conducting business with the highest standards of integrity, ethics, and compliance. We recognize that maintaining a strong compliance and ethics program is vital to protecting the reputation of our company, our employees, and our customers. This Compliance and Ethics Policy (the "Policy") sets forth the principles and guidelines that govern the conduct of all employees, officers, and directors of Methodic LLC (collectively, "Employees"). We expect all Employees to be familiar with this Policy and to act in accordance with its principles.

This policy is intended to provide guidance on legal and ethical issues that Employees may encounter in the course of their work. It is not intended to be an exhaustive list of all laws and regulations that apply to Methodic LLC or its Employees. Employees are expected to seek guidance if they have any questions about the Policy or its application to their work.

All Employees are responsible for reporting any known or suspected violations of this Policy, and any other applicable laws, regulations, or company policies, to their supervisor, the Human Resources Department, or the Legal Department.

We will not tolerate any retaliation against any Employee for reporting a suspected violation in good faith.

By adhering to this Policy, we will maintain a culture of integrity and ethics, and promote compliance with all applicable laws and regulations.

II. Compliance with Laws and Regulations

Methodic is committed to conducting business in an ethical and lawful manner. We comply with all federal, state, and local laws and regulations applicable to our business. This includes, but is not limited to, laws related to data protection, anti-bribery and anti-corruption, anti-money laundering, and antitrust.

Methodic is subject to a variety of laws and regulations depending on the jurisdiction in which we operate. Some of the laws and regulations that may apply to our business include:

• The General Data Protection Regulation (GDPR)
• The California Consumer Privacy Act (CCPA)
• The Federal Trade Commission Act (FTC)
• The Foreign Corrupt Practices Act (FCPA)
• The Sarbanes-Oxley Act (SOX)

It is our policy to comply with these and all other relevant laws and regulations that govern our business operations.

III. Code of Conduct

The company is committed to maintaining the highest ethical standards in all of its business practices. Our code of conduct sets out the company's expectations for ethical behavior and provides guidance to employees, contractors and partners on how to conduct themselves in compliance with the law and the company's values.

Expectations for ethical behavior include, but are not limited to:

• Honesty and integrity in all interactions and transactions
• Compliance with all applicable laws and regulations
• Respect for the rights and dignity of all individuals
• Fairness and transparency in all business practices
• Responsible use of company assets and resources

The company has a strict policy on conflicts of interest and prohibits employees, contractors and partners from engaging in activities that may compromise their ability to act in the best interests of the company. Any actual or potential conflicts of interest must be disclosed to the company immediately.

IV. Reporting Violations

At Methodic, we take compliance and ethics very seriously. We have a strict compliance and ethics policy in place to ensure that all of our employees and contractors conduct themselves in an ethical and lawful manner. If any employee or contractor becomes aware of any violations of this policy, it is their responsibility to report it immediately.

Violations of this policy should be reported to the Compliance Officer, who can be reached by email at compliance@themethodic.com, or by phone at 703-884-1330. Reports can also be made anonymously through the company's compliance hotline, which is available 24/7.

Methodic prohibits retaliation against any employee or contractor who, in good faith, reports a violation of this policy. Retaliation of any kind will not be tolerated, and any employee or contractor who retaliates against a whistleblower will be subject to disciplinary action. Employees or contractors who believe they have been subjected to retaliation should report it immediately to the Compliance Officer.

V: Training and Education

Methodic is committed to ensuring that our employees have the knowledge and resources necessary to understand and comply with our compliance and ethics policy. To that end, we have developed training and education programs that are designed to provide our employees with the information they need to make ethical and compliant decisions.

Training and education programs for employees

• Our training and education programs cover a wide range of topics, including legal and regulatory compliance, business ethics, and risk management.
• These programs are designed to provide employees with the knowledge and skills they need to identify and address potential compliance and ethical issues.
• We conduct regular trainings and workshops for our employees to keep them updated with the latest laws and regulations.

VI. Auditing and Compliance Monitoring 

At Methodic, we take compliance and ethics very seriously. To ensure that we are always operating in compliance with all relevant laws and regulations, we have established regular auditing and monitoring processes to identify and address any areas of non-compliance. Our internal audit team conducts regular reviews of our business operations, and we also engage external auditors to conduct independent assessments of our compliance.

In the event that any non-compliance is identified, our team takes prompt action to address and correct the issue. This may include implementing new policies or procedures, providing additional training to employees, or taking other appropriate measures to ensure that we are operating in compliance with all relevant laws and regulations. We are committed to taking any steps necessary to maintain our compliance and ethical standards.

Expectations for employees

• We expect all employees to complete the necessary training and education programs as part of their employment with Methodic.
• Failure to complete the required training and education may result in disciplinary action, up to and including termination of employment.
• We also expect our employees to refresh their knowledge with regular trainings and workshops.

VII. Conclusion

In conclusion, Methodic is committed to complying with all applicable laws and regulations, and maintaining the highest standards of ethical behavior. Our Code of Conduct sets clear expectations for honesty and integrity in all of our business practices, and we have strict policies in place for reporting violations and conflicts of interest. Our compliance and ethics policy is regularly audited and monitored to ensure that we are in compliance with all laws and regulations, and our employees receive regular training and education to ensure that they understand and adhere to our compliance and ethics policies. 

This policy is available in its entirety on our website for all employees, clients, and interested parties to review.