Ethical Business Practices Statement 

Effective Date: August 18, 2026   |   Last Updated: August 18, 2026

CleverXEL LLC is committed to conducting business with integrity, professionalism, accountability, and respect. This statement describes the principles that guide how we work with clients, partners, contractors, vendors, employees, and other stakeholders.

1. Integrity and Professional Conduct

We aim to conduct business honestly, fairly, and in good faith. Our business activities, communications, recommendations, and professional relationships should reflect appropriate standards of integrity, accuracy, and professionalism.

2. Client Interests and Responsible Service

We seek to understand client needs, operating environments, objectives, and constraints before recommending or implementing solutions. We strive to provide services that are practical, responsible, and appropriate to the engagement rather than promoting unnecessary complexity.

3. Transparency

We aim to communicate clearly about scope, responsibilities, project expectations, commercial terms, known limitations, material risks, conflicts of interest, and the status of solutions that are still in development or pilot stages.

We do not intentionally present expected results, pilot targets, or future capabilities as completed or validated outcomes.

4. Conflicts of Interest

We seek to identify and appropriately manage actual, potential, or perceived conflicts of interest. Where a material conflict may affect our ability to perform objectively or responsibly, we may disclose the issue, implement safeguards, or decline or discontinue the engagement where appropriate.

5. Anti-Bribery and Improper Influence

CleverXEL does not support bribery, kickbacks, corruption, fraud, or other improper methods of obtaining business or influencing decisions. Business relationships, referrals, gifts, entertainment, and other benefits should be handled responsibly and in accordance with applicable law and professional standards.

6. Confidentiality and Data Responsibility

We respect confidential, proprietary, personal, and sensitive information entrusted to us and seek to handle it only for legitimate business purposes, contractual obligations, and applicable legal requirements.

Additional information is provided in our Client Confidentiality & Data Protection Statement and Privacy Notice.

7. Responsible Use of Technology and AI

We believe technology and artificial intelligence should support legitimate business needs and responsible human decision-making. Where AI-enabled capabilities are used or developed, we consider appropriate human oversight, privacy, security, transparency, governance, accuracy, and professional responsibility.

Additional information is provided in our Responsible AI Use Statement.

8. Compliance With Law

We aim to conduct our business in accordance with applicable laws, regulations, contractual obligations, and professional requirements. Where specialized legal, tax, accounting, medical, regulatory, or other licensed professional advice is required, the appropriate qualified professional should be consulted.

9. Fair and Respectful Treatment

We are committed to professional relationships based on respect, fairness, and dignity. We do not support unlawful discrimination, harassment, retaliation, exploitation, or abusive conduct in our business activities.

10. Honest Marketing and Communications

We seek to ensure that website content, proposals, presentations, portfolio materials, project descriptions, and other business communications are accurate and not intentionally misleading.

Where results or capabilities are presented, we distinguish between:

• documented outcomes;

• estimates or projections;

• pilot targets; and

• capabilities that remain in development.

11. Responsible Partnerships

We expect contractors, vendors, consultants, and other third parties working with or on behalf of CleverXEL to act responsibly and in a manner consistent with applicable contractual requirements and professional standards.

12. Raising Concerns

Concerns about our business practices may be submitted under our Complaints and Feedback Policy. We encourage concerns to be raised in good faith and seek to review credible concerns appropriately.

13. Continuous Improvement

As CleverXEL grows, develops new solutions, and later enters additional markets, we may update our practices and governance standards to reflect changing business, legal, technological, and professional expectations.

14. Contact

Questions about this policy may be directed to:

CleverXEL LLC

Address: 2443 Fair Oaks Blvd, #306, Sacramento, CA 95825, United States

Email: clients@cleverxel.com

Phone: +1 916 999 0904