Business Ethics Policy

Poseidon Diving Logistics LLC is committed to conducting business lawfully, fairly, and with integrity. This policy sets the standards of conduct expected of company personnel and supports customer and supplier compliance expectations, including those commonly required by larger commercial and government-related customers.

1. Purpose

Poseidon Diving Logistics LLC conducts business based on honesty, lawful conduct, fair dealing, and accountability. This Business Ethics Policy establishes the company’s expectations for ethical business conduct and compliance with applicable laws, regulations, contractual obligations, and customer requirements.

This policy is intended to function as Poseidon Diving Logistics LLC’s written ethics and compliance statement for its operations as a wholesale distributor of diving products.

2. Scope

This policy applies to all company personnel and to any person or entity acting on behalf of Poseidon Diving Logistics LLC in connection with company business. It also informs the company’s expectations for suppliers, service providers, and subcontractors where flow-down obligations or customer requirements apply.

3. Core Standards of Conduct

All covered persons are expected to:

• Act honestly, fairly, and in good faith.
• Comply with applicable laws, regulations, contract terms, and customer requirements.
• Avoid conduct that creates actual or apparent impropriety.
• Protect the reputation of the company and its business partners.
• Raise concerns promptly when an issue is identified.

4. Compliance With Laws and Customer Requirements

Poseidon Diving Logistics LLC will comply with applicable laws and regulations in the jurisdictions where it operates. This includes, as applicable, anti-bribery laws, labor laws, workplace safety laws, environmental requirements, trade compliance rules, product conformity obligations, recordkeeping requirements, and customer-specific contractual requirements. Where a customer requirement is more restrictive than this policy, the stricter requirement will govern for that work.

5. Anti-Bribery and Anti-Corruption

Poseidon Diving Logistics LLC prohibits bribery, kickbacks, and improper payments in any form. No covered person may offer, promise, give, request, or accept anything of value to improperly influence a business decision, obtain or retain business, or secure an unfair advantage. This prohibition applies whether dealing with private parties, public entities, military organizations, or government officials, and whether acting directly or through an intermediary.

6. Gifts, Meals, Entertainment, and Business Courtesies

Business courtesies must never be used to influence decision-making improperly. Covered persons may not offer or accept gifts, meals, entertainment, favors, discounts, or other benefits that are excessive, frequent, not transparent, inconsistent with law or contract, or likely to create the appearance of impropriety. Modest and customary courtesies may be acceptable only when lawful, reasonable, infrequent, and not intended to influence a purchasing or business decision.

7. Conflicts of Interest

Covered persons must avoid actual, potential, or apparent conflicts of interest. Examples include:

• Financial interests that could affect independent judgment.
• Personal relationships that influence sourcing, pricing, or contracting decisions.
• Outside employment or consulting that conflicts with company duties.
• Use of company opportunities, information, or property for personal gain.

Any known or potential conflict must be disclosed promptly to company management.

8. Accurate Records and Honest Communications

Poseidon Diving Logistics LLC will maintain accurate, complete, and timely records. Covered persons must not create false, misleading, incomplete, or off-book records. Invoices, shipping records, certifications, quality records, inventory records, and business communications must accurately reflect the facts. The company also expects truthful and accurate representations to customers, suppliers, regulators, auditors, and business partners.

9. Product Integrity, Authenticity, and Conformity

Poseidon Diving Logistics LLC is committed to supplying authentic, conforming products from approved or otherwise validated sources appropriate to the goods and customer requirements involved. The company will take reasonable measures to prevent counterfeit, suspect counterfeit, tampered, substituted, or nonconforming products from entering the supply chain. Nonconforming product must be identified, controlled, and handled appropriately, and known product integrity concerns must not be concealed.

10. Human Rights, Labor Standards, and Anti-Trafficking

Poseidon Diving Logistics LLC prohibits human trafficking, forced labor, debt bondage, involuntary labor, child labor, coercion, deceptive recruiting, and the confiscation of identity documents. The company expects lawful employment practices and respectful treatment of workers. Where applicable, the company will require suppliers and service providers to maintain similar standards.

11. Equal Opportunity, Respect, and Professional Conduct

Poseidon Diving Logistics LLC is committed to a professional business environment free from unlawful discrimination, harassment, retaliation, and abusive conduct. Employment and business decisions must be based on legitimate, lawful, and job-related considerations.

12. Health, Safety, and Environmental Responsibility

The company will conduct operations in a manner that supports workplace safety and compliance with applicable environmental and safety requirements. Covered persons must follow reasonable safety procedures, report unsafe conditions, and handle products in a manner consistent with applicable law and good practice.

13. Trade Compliance

Where applicable, Poseidon Diving Logistics LLC will comply with import, export, sanctions, customs, and trade-control laws. Covered persons must not misclassify goods, misstate country of origin, ship to prohibited parties or destinations, or ignore red flags relating to restricted end uses or diversion risk.

14. Confidential Information and Intellectual Property

Covered persons must protect confidential, proprietary, and non-public information belonging to Poseidon Diving Logistics LLC, its customers, and its suppliers. Such information may be used only for legitimate business purposes and disclosed only to authorized persons with a need to know.

Nothing in this policy is intended to restrict any rights protected by applicable law, including the right to report possible violations of law to government agencies or, where protected by law, to discuss wages, hours, or other terms and conditions of employment.

15. Fair Competition and Procurement Integrity

Poseidon Diving Logistics LLC will compete fairly and lawfully. Covered persons must not engage in price-fixing, bid-rigging, market allocation, misuse of competitor information, or misuse of procurement-sensitive information. The company’s qualifications, certifications, sourcing, and capabilities must be represented accurately.

16. Reporting Concerns and Non-Retaliation

Covered persons are expected to report known or suspected violations of law, this policy, customer requirements, or contractual obligations. Reports may be made to company management using the contact information published on the company’s About page. Poseidon Diving Logistics LLC prohibits retaliation against anyone who raises a concern in good faith, asks a compliance question, participates in an investigation, or refuses to engage in conduct the person reasonably believes is unlawful or unethical.

17. Investigations and Corrective Action

The company will review credible concerns promptly and take appropriate action where needed. This may include internal investigation, corrective action, employee discipline, supplier corrective action requests, customer notification where required, or termination of a business relationship when warranted.

18. Supplier and Subcontractor Expectations

Poseidon Diving Logistics LLC expects suppliers, service providers, and subcontractors to conduct business ethically and in compliance with applicable law. Where appropriate or required, the company expects such parties to support standards relating to:

• Anti-bribery and anti-corruption compliance.
• Conflict-of-interest disclosure.
• Accurate records and truthful representations.
• Human rights, lawful labor practices, and anti-trafficking controls.
• Product authenticity, traceability, and conformity.
• Flow-down of applicable requirements to lower-tier suppliers when required.

19. Training and Awareness

Poseidon Diving Logistics LLC will provide reasonable ethics and compliance awareness to relevant personnel based on role, risk, and customer requirements. This may include written acknowledgments, training, procedural guidance, or contract-specific compliance instructions.

20. Responsibility and Oversight

Company management is responsible for implementing this policy, promoting ethical conduct, responding to concerns, and ensuring that the company’s business practices support lawful and responsible operations.

21. Contact

Questions regarding this policy may be directed to Poseidon Diving Logistics LLC through company management using the contact information published on the company’s About page.