Counterfeit Goods Policy

Crossroad Distributor Source
Effective: May 2025

1.0 Commitment to Ethical Conduct

1.1 Crossroad Distributor Source maintains a zero-tolerance policy toward all forms of bribery and corruption. We are committed to conducting business with honesty, integrity, and transparency in every area of our operations, both domestically and internationally.

1.2 This policy aligns with applicable anti-bribery and corruption laws, including the U.S. Foreign Corrupt Practices Act (FCPA) and other relevant international standards.

2.0 Bribery

Employees of Crossroad Distributor Source and any third parties acting on behalf of the company are strictly prohibited from:

• Offering, promising, or giving anything of value to improperly influence the actions of another person or organization.
• Requesting, agreeing to receive, or accepting anything of value that could improperly influence a business decision.
• Engaging in or condoning any form of bribery involving foreign officials, customers, vendors, or other business partners.

2.2 Bribery includes any attempt to gain or reward improper performance of a business function, whether the advantage is offered directly or through an intermediary.

3.0 Facilitation Payments

3.1 “Facilitation payments” — small payments made to secure or speed up routine government actions — are considered a form of bribery and are strictly prohibited by Crossroad Distributor Source.

3.2 All employees and agents must decline any request for such payments and promptly report the request to management.

4.0 Gifts and Hospitality

The exchange of reasonable gifts, meals, or hospitality is permitted only when it is appropriate, transparent, and not intended to influence a business decision.

• Gifts must never be cash or cash equivalents.
• Gifts or hospitality must not involve public officials.
• The value and frequency must be modest and proportionate.
• Any gift or hospitality that could appear improper must be declined and reported.

Employees must notify their manager or the Compliance Officer of any offered or received gift or hospitality that could create a potential conflict of interest.

5.0 Charitable Contributions

5.1 Crossroad Distributor Source may make charitable donations or contributions that support legitimate causes, provided they are transparent and properly approved.

5.2 Charitable giving must never be used as a means to improperly influence business decisions or secure an advantage.

6.0 Political Contributions

6.1 Crossroad Distributor Source does not make political donations or contributions, monetary or otherwise, to any candidate, party, or campaign.

6.2 Employees are free to participate personally in political activities, but such involvement must not be associated with or represented as company support.

7.0 Due Diligence and Prevention

7.1 Crossroad Distributor Source implements controls to identify, prevent, and address potential bribery and corruption risks. These include:

• Conducting periodic risk assessments in industries, countries, and partnerships where the company operates.
• Requiring all suppliers, agents, and distributors to adhere to equivalent anti-bribery standards.
• Providing regular employee training on this policy.
• Operating a confidential whistleblowing process that allows employees to report concerns without fear of retaliation.

7.2 This policy will be reviewed regularly and updated as necessary to ensure continued compliance with all applicable laws and ethical standards.

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Crossroad Distributor Source
317.723.5050
Sales@Crossroad.bz
CrossroadDistributorSource.com