Code of Ethics and Anti-Corruption Policy

Simplebooklet Marketing Inc. | Approved March 25, 2025

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1. Purpose

At Simplebooklet Marketing Inc. ("Simplebooklet"), we are committed to conducting business with integrity, transparency, and accountability. This Code of Ethics and Anti-Corruption Policy ("Policy") outlines our standards for ethical conduct and is designed to prevent corruption, bribery, and facilitation payments in all areas of our operations.

2. Scope

This Policy applies to:

All employees, officers, and directors of Simplebooklet
Contractors, consultants, and agents acting on our behalf
Any third parties or partners engaged in business with Simplebooklet

3. Our Ethical Principles

We expect all team members and partners to:

Act with honesty, fairness, and transparency
Avoid conflicts of interest
Comply with applicable laws and regulations
Uphold our company's reputation by avoiding any conduct that could be perceived as unethical

4. Anti-Bribery and Corruption

4.1 Bribery is Strictly Prohibited

You must never offer, give, solicit, or receive any form of bribe or improper payment. This includes cash, gifts, entertainment, or anything of value intended to influence a business decision or secure an unfair advantage.

4.2 Facilitation Payments

Facilitation payments — small, unofficial payments to speed up routine actions — are prohibited, even in jurisdictions where they may be considered legal.

4.3 Third Parties

Simplebooklet is responsible for the conduct of third parties acting on its behalf. We conduct due diligence and expect all representatives to comply with this Policy.

5. Gifts and Hospitality

Gifts, entertainment, or hospitality must:

Be reasonable in value
Be given transparently and in good faith
Not influence — or be perceived to influence — a business decision

Report any gifts valued over $100 to your manager or the Compliance Officer for review.

6. Conflicts of Interest

Employees must avoid situations where personal interests conflict with the interests of the company. Any actual or potential conflicts must be disclosed promptly to management.

7. Reporting and Whistleblowing

Employees and partners are encouraged to report any suspicious activity, breaches of this Policy, or unethical behavior through any of the following means:

Confidential email: ken.kwasnicki@simplebooklet.com
Direct report to a manager or designated compliance officer

Reports will be treated confidentially and without retaliation.

8. Disciplinary Action

Violations of this Policy may result in:

Disciplinary action, including termination of employment
Termination of contract with vendors or partners
Legal action where appropriate

9. Review and Training

This Policy will be reviewed annually and updated as needed. Regular training will be provided to all relevant employees and third parties to ensure understanding and compliance.

10. Commitment

All employees and partners of Simplebooklet must acknowledge that they have read, understood, and agreed to comply with this Code of Ethics and Anti-Corruption Policy.

Approved by:
James Scott Brownlee
CEO, Simplebooklet Marketing Inc.
March 25, 2025

Updated on: 08/09/2026

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