Our ethos: GSD will conduct all our activities via shared values and the highest level of integrity.

CORE ETHICS PRINCIPLES:

Culture of values: We view integrity as an imperative to treat one another with respect, honesty, transparency, and genuine care. GSD employees, partners, and clients know we operate from these values. We strive to demonstrate these through our actions and words.

Culture of knowledge: We all have a responsibility to make sure our ethics and business practices are understood. To fulfill this responsibility, GSD communicates our Code to employees, partners, and clients. GSD employees receive ethics training and participate in ethics exercises periodically. GSD’s Code of Business Ethics (the “Code”) is available upon request.

Culture of compliance: It is the responsibility of each person or group of persons acting in any capacity of GSD to adhere to the standards and expectations, whether imposed by law or our Code. Each employee and partner must comply with the spirit and the letter of the Code. For employees, this is a condition of continued employment. Failure to comply will result in disciplinary action, which may include immediate termination for cause.

Culture of openness: It is the responsibility of each person and or group of persons acting in any capacity of GSD to report any conduct that may be a violation of our Code or any law in effect. Each report is handled with the utmost privacy and urgency. While most issues can and should be handled by speaking with either your immediate supervisor or account manager, suspected violations of the Code can be reported outside of the staff structure. No member of GSD and or its agents are above the law or free from compliance as articulated in our Code. Reports may be made anonymously if so desired by:

• written letter addressed to CoBE Reporting c/o COMPLIANCE, GSD LLC, 5388 Discovery Park Blvd, Suite 230, Williamsburg, Va USA 23188;

• via an externally managed website: www.gsdgov.com; or

• via confidential email: [email protected]

For all reports, regardless of method, please identify the company name (i.e. GSD LLC) as well as any detailed information you have with each report.

Culture of action: It is the personal responsibility of each person and or group of persons acting in any capacity of GSD to provide accurate information and to fully cooperate as required. No one should interfere with or obstruct an investigation by providing false information, concealing, or destroying information, or disclosing information about an investigation unless permission is granted in writing by an Officer of GSD or their designee.

Regardless of how a report is made, no person will suffer any retaliation of any kind for reporting in good faith a violation or suspected violation of this Code, policy, or the law. In addition, no person will suffer any retaliation for filing any complaint with any government agency or for exercising any legal right. Again, all employees are protected from any retaliation for reporting a violation.

Culture of ethics: we have an individual responsibility to conduct all our activities with shared company values and demonstrating the highest level of integrity. You are the face and spirit of GSD.