Code of Ethics

1. Purpose

BluSky is committed to integrity, professionalism, and full compliance with laws. This Code defines the standards expected from all persons and entities acting with or for the Company.

2. Scope of Application

This Code applies to:

• Shareholders
• Board members and de facto managers
• Employees and temporary workers
• Consultants and advisors
• Suppliers, service providers, and business partners
• Agents and intermediaries
• Anyone acting on behalf of BluSky
• Customers (regarding ethical use of BluSky systems)

3. Core Principles

All parties must uphold:

• Legality
• Integrity
• Respect and professionalism
• Confidentiality
• Accountability
• Zero tolerance for corruption

4. Conduct Requirements

All covered parties must:

• Avoid conflicts of interest
• Protect company assets and IP
• Use data only for authorized purposes
• Follow cybersecurity rules
• Avoid falsification or misuse of information
• Report misconduct immediately (no retaliation)

5. Third-Party Responsibilities

Consultants, suppliers, and partners must:

• Comply with this Code
• Act ethically when representing BluSky
• Protect systems and information

Non-compliance may result in termination of contracts or reporting to authorities.

6. Customer Responsibilities

Customers must:

• Use BluSky systems ethically
• Avoid fraud, misuse, or illegal activity
• Comply with AML/KYC rules

BluSky may suspend or terminate access for violations.

7. Anti-Corruption & Gifts

Prohibited:

• Bribery, kickbacks, or facilitation payments
• Gifts intended to influence decisions

Gifts over $100 require approval.

8. Enforcement

Violations may result in:

• Termination of employment or contracts
• Customer access suspension
• Legal action or reporting to authorities

9. Acknowledgment

All covered parties must acknowledge and follow this Code. Employees reaffirm compliance annually.