Effective Date: August 13, 2026
Approved By: Managing Director, C3K Properties LLC
Applies To: Owners, officers, employees, contractors, consultants, agents, representatives, and other persons acting on behalf of C3K Properties LLC
C3K Properties LLC ("C3K") is committed to conducting business with integrity, transparency, accountability, and compliance with applicable laws and regulations.
This Code of Business Conduct and U.S. Public Sector Compliance Policy ("Code") establishes the ethical and compliance standards applicable to C3K's business activities, including its work with U.S. federal, state, and local government customers.
C3K expects all persons acting on its behalf to conduct business honestly, avoid improper conduct, protect public trust, and comply with applicable contractual and legal requirements.
This Code applies to C3K's owners, officers, employees, contractors, consultants, agents, representatives, and other persons acting on behalf of C3K.
The Code applies to C3K's commercial and public sector activities, including:
Government contracting and subcontracting;
Information technology hardware, software, licensing, maintenance, and support;
Manufacturer and distributor relationships;
Real estate and professional services;
Procurement and supply-chain activities;
Sales and business development;
Proposal and quotation preparation; and
Other products and services offered by C3K.
Individuals and organizations representing C3K are expected to understand and follow the portions of this Code applicable to their responsibilities.
C3K conducts business honestly, fairly, and in good faith.
C3K will not knowingly participate in fraud, bribery, corruption, kickbacks, false statements, bid manipulation, conflicts of interest, or other improper business practices.
C3K expects its representatives to:
Act with integrity and professionalism;
Comply with applicable laws, regulations, contractual requirements, and customer requirements;
Maintain accurate business records;
Protect confidential and procurement-sensitive information;
Avoid actual and apparent conflicts of interest;
Compete fairly;
Report suspected violations; and
Cooperate appropriately with lawful government audits, reviews, and investigations.
C3K recognizes that doing business with government entities carries obligations beyond those ordinarily applicable to commercial transactions.
C3K's public sector activities shall be conducted in accordance with applicable federal, state, and local procurement requirements and the terms and conditions incorporated into each solicitation, contract, purchase order, subcontract, or other agreement.
C3K personnel involved in government business are responsible for reviewing applicable requirements before making representations, submitting quotations or proposals, accepting awards, or performing contractual obligations.
Where a contract incorporates provisions of the Federal Acquisition Regulation ("FAR"), Defense Federal Acquisition Regulation Supplement ("DFARS"), agency supplements, or other government requirements, C3K will comply with the provisions applicable to its performance.
C3K prohibits bribery, kickbacks, improper gratuities, and other corrupt practices.
No person acting on behalf of C3K may directly or indirectly offer, promise, authorize, provide, request, or accept money or anything of value for the purpose of improperly:
Influencing an official decision;
Obtaining or retaining business;
Securing preferential treatment;
Influencing a procurement;
Obtaining confidential or procurement-sensitive information; or
Rewarding favorable treatment.
This prohibition applies to dealings with government officials, customers, suppliers, manufacturers, distributors, subcontractors, consultants, and other business partners.
C3K will comply with applicable anti-kickback and anti-corruption requirements associated with government contracts.
Government employees are subject to strict rules concerning gifts, meals, travel, entertainment, discounts, and other things of value.
C3K personnel and representatives shall not offer or provide anything of value to a government official or employee when doing so is prohibited by applicable law, regulation, agency policy, solicitation, contract, or ethical requirement.
No gift, meal, entertainment, travel, payment, discount, favor, or other benefit may be offered for the purpose of influencing a government decision or obtaining an improper business advantage.
When there is uncertainty about whether something may appropriately be provided to a government official, the default C3K policy is not to provide it until the applicable requirements have been reviewed and approval has been obtained from C3K management.
C3K personnel and representatives must avoid situations in which personal, financial, family, employment, or other interests improperly influence, or appear to influence, business decisions.
Potential conflicts involving government customers, contracting officials, suppliers, subcontractors, competitors, or business partners must be disclosed to C3K management.
C3K will take reasonable steps to address identified conflicts before proceeding with the affected activity.
No person acting for C3K may use a government or business relationship for improper personal benefit.
C3K will compete for government business fairly and lawfully.
C3K personnel shall not improperly seek, obtain, use, disclose, or distribute:
Contractor bid or proposal information;
Government source-selection information;
Competitors' confidential pricing;
Nonpublic evaluation information;
Proprietary information belonging to another party; or
Other information that C3K is not authorized to possess.
C3K will rely on publicly available information, information lawfully provided by customers and partners, and information C3K is otherwise authorized to use.
Information submitted by C3K to government customers must be accurate and complete to the best of C3K's knowledge.
C3K prohibits knowingly submitting false, misleading, or materially incomplete information.
This standard applies to:
Technical proposals;
Price quotations;
Invoices;
Product descriptions;
Delivery representations;
Country-of-origin information;
Manufacturer authorization;
Small business representations;
Socioeconomic representations;
Certifications;
Past performance information;
Product specifications;
Warranty and support representations; and
Other information submitted in connection with government business.
Employees and representatives must not certify information they know to be inaccurate.
C3K supports fair and open competition.
C3K will independently determine its prices and business terms and will not enter into improper agreements with competitors concerning:
Prices;
Margins;
Bid amounts;
Customers;
Territories;
Whether to submit a bid;
Allocation of government opportunities; or
Other matters that unlawfully restrict competition.
C3K personnel shall not participate in bid rigging, price fixing, market allocation, or other anticompetitive conduct.
C3K is committed to maintaining the integrity of products supplied to government customers.
Where required by the applicable solicitation, contract, manufacturer program, or customer requirement, C3K will obtain products through manufacturers or authorized distributors, resellers, or other approved supply channels.
C3K will not knowingly misrepresent:
Product condition;
Manufacturer;
Part number;
Configuration;
Country of origin;
Warranty;
Licensing;
Support entitlement;
Manufacturer authorization; or
Supply-chain status.
C3K will not knowingly represent used, refurbished, remanufactured, counterfeit, or gray-market products as new OEM-authorized products.
C3K will comply with applicable U.S. export-control, import-control, trade-sanctions, and restricted-party requirements.
Where applicable, C3K will evaluate transactions involving products, software, technology, customers, destinations, and counterparties for applicable restrictions.
C3K will not knowingly participate in a transaction prohibited by applicable U.S. sanctions or export-control laws.
C3K expects manufacturers, distributors, suppliers, and other parties involved in regulated transactions to provide accurate product and trade-compliance information within their responsibility.
When applicable to a government contract, C3K will comply with federal restrictions concerning prohibited or covered technology, equipment, software, applications, and services.
This includes applicable requirements concerning:
Covered telecommunications and video surveillance equipment or services;
Prohibited cybersecurity products or software;
Federal Acquisition Supply Chain Security Act restrictions;
Government restrictions on covered applications; and
Other technology or supply-chain restrictions incorporated into an applicable solicitation or contract.
C3K will review these requirements on a contract-by-contract basis and will not knowingly provide prohibited products or services where an applicable restriction applies.
C3K will take reasonable measures appropriate to its size, business activities, and contractual obligations to protect company, customer, supplier, and government information.
C3K personnel must protect:
Confidential business information;
Proprietary information;
Customer information;
Credentials and account information;
Procurement-sensitive information; and
Government information subject to contractual safeguarding requirements.
Where a government contract imposes specific cybersecurity, safeguarding, incident-reporting, FAR, DFARS, or other information-security requirements, C3K will evaluate and comply with the requirements applicable to its performance.
C3K will not claim cybersecurity certifications, assessments, or compliance levels that it has not obtained or established.
C3K respects confidential and proprietary information belonging to customers, manufacturers, distributors, suppliers, competitors, and other third parties.
Such information may only be obtained, accessed, used, or disclosed for legitimate and authorized business purposes.
C3K personnel shall not improperly disclose confidential pricing, quotations, credentials, technical information, customer data, or other protected information.
C3K expects suppliers, manufacturers, distributors, consultants, subcontractors, agents, and other business partners supporting C3K's government activities to conduct business lawfully and ethically.
C3K may perform reasonable due diligence appropriate to the transaction, including verification of:
Business identity;
Manufacturer or distributor authorization;
Product sourcing;
Sanctions or restricted-party concerns;
Country of origin;
Representations required by the customer; and
Other material compliance requirements.
C3K will not knowingly use a third party to perform an activity that C3K itself is prohibited from performing.
C3K will respond appropriately to lawful government inquiries, audits, reviews, and investigations.
C3K personnel shall not:
Destroy or alter relevant records;
Knowingly provide false information;
Conceal material facts;
Interfere improperly with an investigation; or
Retaliate against an individual for cooperating with a lawful inquiry.
Government requests involving legal, contractual, investigative, or disclosure obligations should be promptly brought to the attention of C3K management.
Anyone acting on behalf of C3K who becomes aware of suspected fraud, bribery, corruption, kickbacks, conflicts of interest, false statements, procurement-integrity violations, sanctions violations, cybersecurity incidents, or other material misconduct involving C3K business should promptly report the concern to C3K management.
Reports may be made to:
C3K Properties LLC
Attention: Managing Director
Email: compliance@c3kproperties.com
If a dedicated compliance email address is not maintained, concerns may be submitted through C3K's published business contact information.
C3K will review reported concerns and take reasonable corrective action when appropriate.
Nothing in this Code prohibits or restricts any person's lawful right to communicate with, cooperate with, or report possible violations directly to an appropriate government agency or law-enforcement authority.
C3K prohibits retaliation against any employee, contractor, representative, or other person for making a good-faith report of suspected misconduct or participating appropriately in an investigation.
Knowingly making a false accusation or intentionally providing false information is not protected by this policy.
Violations of this Code may result in corrective action appropriate to the circumstances.
Depending on the nature and severity of the conduct, actions may include:
Additional guidance or training;
Removal from an assignment;
Termination of an employee or contractor relationship;
Termination of a supplier or business-partner relationship;
Corrective disclosure to a customer or government agency when required; and
Referral to appropriate authorities when legally required or otherwise appropriate.
C3K management is responsible for implementing and enforcing this Code.
Management responsibilities include:
Communicating the Code to persons whose responsibilities are affected by it;
Reviewing compliance questions associated with government opportunities;
Addressing reported concerns;
Maintaining appropriate records;
Taking corrective action when necessary; and
Periodically reviewing this Code as C3K's business and government-contracting activities evolve.
All C3K personnel and representatives are individually responsible for complying with the standards applicable to their activities.
C3K will provide compliance information or training appropriate to an individual's role and responsibilities.
Personnel substantially involved in government contracting should understand, as applicable to their responsibilities:
Government procurement integrity;
Anti-bribery and anti-kickback requirements;
Gifts involving government personnel;
Conflicts of interest;
Accurate representations and certifications;
Supply-chain requirements;
Trade controls and sanctions;
Information protection; and
Reporting obligations.
Training and compliance measures will be proportionate to C3K's size, risk profile, contractual requirements, and level of government-contracting activity.
This Code establishes C3K's general standards. It does not replace requirements contained in a specific government solicitation, contract, subcontract, purchase order, law, or regulation.
Where a contractual or legal requirement imposes a higher or more specific standard than this Code, C3K will follow the applicable requirement.
Questions concerning a contract-specific requirement should be raised with C3K management before the relevant representation, certification, commitment, or action is made.
C3K will periodically review this Code and update it as appropriate to reflect:
Changes in C3K's operations;
Changes in government-contracting activities;
Material changes in applicable laws or regulations;
Customer or manufacturer requirements;
Identified compliance risks; and
Lessons learned from C3K's business activities.
C3K Properties LLC is committed to conducting business with integrity and maintaining the trust of its customers, manufacturers, distributors, business partners, and government agencies.
Compliance is a condition of conducting business on behalf of C3K.
C3K expects every person representing the company to exercise sound judgment, act ethically, raise concerns when appropriate, and comply with applicable laws and contractual requirements.
C3K Properties LLC
Approved by: Managing Director
Effective Date: August 13, 2026
Version: 1.0
© 2026 C3K Properties LLC. All rights reserved.