Policies and Procedures

---

 Executive-Level Oversight of Compliance

Sierra Nevada Global Logistics (SNVGL) designates executive-level individuals to oversee compliance. Our Chief Compliance Officer (CCO) ensures that our company adheres to all applicable laws, regulations, and internal policies.

The Chief Compliance Officer's responsibilities include:

1. Leadership and Oversight: Providing strategic leadership and oversight of our compliance and ethics program to ensure it is effective and continuously improving.

2. Policy Development: Developing, implementing, and maintaining comprehensive compliance policies and procedures that align with legal and regulatory requirements.

3. Training and Education: Ensuring that all employees receive regular training on compliance issues and understand their responsibilities under our compliance program.

4. Monitoring and Auditing: Overseeing regular audits and monitoring activities to detect and prevent non-compliance and unethical behavior.

5. Reporting and Communication: Establishing clear channels for reporting compliance concerns and ensuring issues are addressed promptly and effectively.

6. Advisory Role: Acting as an advisor to the executive team and the Board of Directors on compliance-related matters and emerging regulatory trends.

Our commitment to compliance and ethical conduct is integral to our operations, and the Chief Compliance Officer plays a crucial role in maintaining the integrity and transparency of our business practices.

Anti-Bribery and Gift Policies

Sierra Nevada Global Logistics (SNVGL) has stringent policies and procedures that prohibit bribery and regulate giving gifts, entertainment, and travel to government recipients. These measures ensure that our business practices are ethical, transparent, and compliant with all applicable laws and regulations.

Key elements of our policies include:

1. Anti-Bribery Policy: We have a zero-tolerance policy towards bribery. All employees and stakeholders are strictly prohibited from offering, giving, receiving, or soliciting anything of value to improperly influence the actions of government officials or any other individuals.

2. Gifts and Entertainment: Our policy clearly defines acceptable limits on gifts and entertainment. Any gifts or entertainment provided to government recipients must be modest, infrequent, and compliant with all relevant laws and regulations.

3. Travel Expenses: Reimbursement or payment of travel expenses for government officials is highly restricted and must be pre-approved by our compliance team. Such costs must be reasonable, necessary, and directly related to legitimate business purposes.

4. Training and Awareness: We regularly train all employees to ensure they understand and adhere to our anti-bribery and gift policies. This training includes practical guidance on handling situations involving gifts, entertainment, and travel for government recipients.

5. Monitoring and Enforcement: Compliance with these policies is monitored regularly. Any violations are taken seriously and may result in disciplinary action, including termination of employment.

By adhering to these policies, SNVGL ensures that our interactions with government officials are conducted with the highest level of integrity and in full compliance with legal requirements. 

 Accountability for Compliance

Sierra Nevada Global Logistics (SNVGL), our employees, and third-party representatives are held accountable for adhering to the organization’s policies. We have precise mechanisms in place to ensure compliance and to address instances of non-compliance through disciplinary or corrective action.

Critical aspects of our accountability measures include:

1. Clear Expectations: All employees and third-party representatives are informed of our policies and their responsibility to comply with them from the outset of their engagement with SNVGL.

2. Regular Training: We provide ongoing training to ensure everyone understands our policies, the importance of compliance, and the potential consequences of non-compliance.

3. Monitoring and Audits: We conduct regular monitoring and audits to detect deviations from our policies. This helps maintain high standards of ethical conduct and compliance.

4. Reporting Mechanisms: We have established secure and confidential channels for reporting suspected non-compliance or unethical behavior. These channels are accessible to both employees and third-party representatives.

5. Disciplinary Actions: In cases of non-compliance, appropriate disciplinary or corrective actions are taken. This may include retraining, formal warnings, suspension, employment termination, or business relationships with third-party representatives.

6. Consistent Enforcement: We ensure that our policies are enforced consistently and fairly across the organization, regardless of the position or relationship of the individual involved.

By holding everyone accountable for compliance, SNVGL reinforces its commitment to ethical business practices and the integrity of our operations.

Human Rights and Labor Standards Policy

Sierra Nevada Global Logistics (SNVGL) is committed to upholding the highest human rights and labor practices standards. This policy outlines the company's commitment to comply with international laws prohibiting forced labor, slavery, human trafficking, and illegal child labor.

Scope
This policy applies to all contractors, consultants, suppliers, and third parties acting on behalf of SNVGL.

Policy Statement
SNVGL strictly prohibits all forms of forced labor, slavery, human trafficking, and illegal child labor. The company is committed to ensuring that all business operations and supply chains are free from these unethical practices.

Definitions

• Forced Labor: Work or service that people are forced to do against their will under the threat of some form of punishment.
• Slavery: A condition in which individuals are owned by others who control where they live and at what they work.
• Human      Trafficking: The recruitment, transportation, transfer, harboring, or receipt of persons using threat, force, coercion, abduction, fraud, deception,      or abuse of power for exploitation.
• Illegal Child      Labor: Work that is mentally, physically, socially, or morally dangerous and harmful to children and interferes with their schooling.

Responsibilities

• Employees and      Representatives: Must adhere to this policy, report any suspicious activity, and avoid any conduct that could be perceived as supporting forced labor,      slavery, human trafficking, or illegal child labor.
• Management: All employees and representatives must know and comply with this policy, and training and resources must be provided as necessary.
• Suppliers and      Partners Are expected to adhere to the same standards and ensure that their operations and supply chains are free from forced labor, slavery, human trafficking, and illegal child labor.

Reporting Violations
Employees, representatives, and third parties are encouraged to report any violations or suspected violations of this policy to their supervisor or the designated compliance officer. Reports can be made anonymously and without fear of retaliation.

Consequences of Violation
Violations of this policy will be taken seriously and may result in disciplinary action, including termination of employment or contract and potential legal action.

Due Diligence and Risk Assessment
SNVGL will conduct regular due diligence and risk assessments to identify, prevent, and mitigate risks of forced labor, slavery, human trafficking, and illegal child labor in its operations and supply chains.

Review and Amendments
This policy will be reviewed periodically and may be amended to ensure continued compliance with legal and ethical standards.

 Anti-Corruption Risk Assessment Policy

Sierra Nevada Global Logistics (SNVGL) is committed to maintaining the highest standards of integrity and compliance with anti-corruption laws and regulations. This policy outlines the procedures for conducting periodic anti-corruption risk assessments to identify, assess, and prioritize key compliance risks and remediation needs.

Scope
This policy applies to all employees, contractors, consultants, suppliers, and third parties acting on behalf of SNVGL.

Policy Statement
SNVGL will conduct periodic anti-corruption risk assessments to identify, assess, and prioritize risks related to corruption and bribery. The goal is to implement effective risk mitigation and remediation strategies to ensure compliance with legal and ethical standards.

Risk Assessment Procedures

1. Assessment Planning: Develop a risk assessment plan that outlines the scope, objectives,      and methodology for evaluating anti-corruption risks. This includes identifying critical exposure areas, such as high-risk countries, industries, and business practices.
2. Data Collection: Gather relevant information and data from various sources, including internal records, financial transactions, third-party relationships, and external reports on corruption risks.
3. Risk Identification: Based on the collected data, identify potential corruption risks. These may include business practices, regulatory compliance, third-party interactions, and employee conduct risks.
4. Risk Evaluation: Assess the identified risks in terms of their potential impact and likelihood. Evaluate the effectiveness of existing controls and mitigation measures in addressing these risks.
5. Risk      Prioritization: Prioritize risks based on their potential impact and likelihood. Focus on high-priority risks that require immediate attention or remediation.
6. Action Plan: Develop an action plan to address identified risks. This may include implementing new controls, enhancing existing measures, providing additional training, or taking corrective actions.
7. Implementation: Execute the action plan and implement all recommended measures effectively. Monitor progress and make adjustments as necessary.

Responsibilities

• Employees and Representatives: Must be aware of anti-corruption risks and comply with the company’s policies. Report any concerns or potential risks to the compliance officer.
• Compliance Officer: Responsible for overseeing the risk assessment process, conducting it periodically, and implementing and monitoring risk mitigation strategies.

Reporting and Documentation
Maintain comprehensive documentation of the risk assessment process, including the findings, action plans, and implementation status. Report critical risks and remediation efforts to senior management and the Board of Directors.

Review and Amendments
This policy will be reviewed periodically and may be amended to ensure continued effectiveness and compliance with legal and ethical standards.

Compliance and Anti-Corruption Training Policy

Purpose
Sierra Nevada Global Logistics (SNVGL) ensures that all relevant individuals are educated about compliance and anti-corruption standards. This policy outlines the requirements for periodic compliance training, including anti-corruption training.

Scope
This policy applies to the following individuals and groups:

• Employees
• Contractors and Consultants
• Suppliers and Business Partners
• Board Members
• Third-Party Representatives

Policy Statement
SNVGL requires all specified individuals and groups to participate in periodic compliance training, including anti-corruption training. The training ensures they understand and adhere to the company’s compliance standards and anti-corruption policies.

Training Requirements

1. Employees: All employees must complete initial compliance and anti-corruption training upon hire and participate in refresher courses at least annually.
2. Contractors and Consultants: Must complete compliance and anti-corruption training as part of their onboarding process and periodically as required by their contract terms.
3. Suppliers and Business Partners: Must receive training or provide certification of compliance with anti-corruption standards, as specified in their contracts or agreements with SNVGL.
4. Board Members: Must complete compliance and anti-corruption training upon joining the Board and participate in refresher courses at least annually.
5. Third-Party Representatives: Must receive anti-corruption training or certification, as required by their agreements with SNVGL.

Training Content
Training programs will cover:

• Overview of anti-corruption laws and regulations
• SNVGL’s anti-corruption policies and procedures
• Examples of corrupt practices and how to recognize them
• Reporting mechanisms for concerns and potential violations
• Ethical decision-making and conflict of interest considerations

Tracking and Documentation
SNVGL will maintain records of all training sessions, including participant attendance and completion dates. Training records will be reviewed periodically to ensure compliance with this policy.

Responsibilities

• Human Resources: Responsible for coordinating and scheduling training sessions, tracking completion, and maintaining training records.
• Compliance Officer: Oversees training content development and delivery, ensures training effectiveness, and addresses training-related issues.

Review and Amendments
This policy will be reviewed periodically and updated to ensure its effectiveness and compliance with legal and regulatory standards.

Anti-Bribery and Anti-Corruption Certification Policy

Purpose
Sierra Nevada Global Logistics (SNVGL) is dedicated to maintaining the highest ethical standards and complying with all anti-bribery and anti-corruption laws and regulations. This policy certifies that SNVGL will not engage in any practices that violate these standards.

Policy Statement
SNVGL certifies that it will not, directly or indirectly, offer, pay, promise, or authorize the payment of any money, gift, benefit, or anything of value to a Government official (as defined below) for any of the following purposes:

(i) Government Official Definition:

• Any officer,      employee, or person acting in an official capacity for any government      department, agency, or instrumentality, including state-owned or      -controlled companies, and public international organizations.
• Any political      party or official thereof, or candidate for political office.

(ii) Prohibited Purposes:

• (a) Influencing      an Act or Decision: To influence an act or decision      of a Government official in their official capacity.
• (b) Inducing      Violation of Duty: To induce a Government official      to do or omit to do any act in violation of the lawful duty of such      official.
• (c) Securing an      Improper Advantage: To secure an improper advantage.
• (d) Affecting      Government Decisions: To induce a Government official      to use their influence to affect or influence any act or decision of a      government or instrumentality in obtaining or retaining business.

Certification Requirements
All employees, contractors, consultants, and third parties acting on behalf of SNVGL are required to certify their adherence to this policy and confirm that they will not engage in any prohibited activities as outlined above.

Responsibilities

• Employees and      Representatives: Must understand and comply with this policy and report any concerns      or potential violations to the compliance officer.
• Compliance      Officer: Responsible for overseeing the implementation of this policy,      ensuring adherence, and addressing any compliance issues.

Monitoring and Enforcement
SNVGL will implement appropriate measures to monitor compliance with this policy, including periodic audits and reviews. Any violations will be addressed promptly, with appropriate corrective actions taken.

Review and Amendments
This policy will be reviewed periodically and may be amended as necessary to ensure continued compliance with legal and ethical standards.

Policy Title: Prohibition on the Provision of Covered Telecommunications Equipment or Services to the Government

Policy Number: SNVGL-TEC-001

Effective Date: 14 December 2023

Policy Statement:

Sierra Nevada Global Logistics (SNVGL) is committed to ensuring the security and integrity of its operations and services. According to federal regulations and best practices, SNVGL will not provide the government with any covered telecommunications equipment or services.

Purpose:

This policy complies with Section 889 of the John S. McCain National Defense Authorization Act for Fiscal Year 2019 (NDAA FY19), which prohibits the use of certain companies' covered telecommunications equipment or services due to security concerns. This policy ensures that SNVGL does not provide, use, or contract for covered telecommunications equipment or services in federal government contracts.

Scope:

This policy applies to all employees, contractors, and partners of SNVGL involved in the procurement, provision, and management of telecommunications equipment and services.

Definitions:

• Covered Telecommunications Equipment or Services: Includes telecommunications or video surveillance equipment or services produced or provided by Huawei Technologies Company, ZTE Corporation, or any subsidiary or affiliate of such entities, and any other companies identified by the federal Government as posing a national security risk.
• Government: Refers to any federal department, agency, or other entities of the United States Government.

Policy Requirements:

1. Prohibition on Provision: SNVGL will not provide the Government with any covered telecommunications equipment or services. This includes but is not limited to:
   
   • The installation, procurement, or use of covered telecommunications equipment or services in any products or services offered to the Government.
   • The inclusion of covered telecommunications equipment or services in any contract, subcontract, or other contractual instruments with the Government.

1. Supplier Verification: SNVGL will conduct due diligence to verify that suppliers and subcontractors do not provide covered telecommunications equipment or services. This includes:
   
   • Screening suppliers and subcontractors for compliance with Section 889 of the NDAA FY19.
   • Requiring certification from suppliers and subcontractors that they do not use or provide covered telecommunications equipment or services.

1. Employee Training: SNVGL will provide training to relevant employees on the requirements of this policy and the identification of covered telecommunications equipment or services.
2. Compliance Monitoring: SNVGL will implement procedures to monitor compliance with this policy. This includes regular audits and reviews of procurement and contracting processes to ensure no covered telecommunications equipment or services are used or provided.
3. Reporting Non-Compliance: Any employee or contractor who becomes aware of a potential violation of this policy must report it immediately to their supervisor or the Compliance Officer. SNVGL will investigate all reports and take appropriate corrective action.
4. Policy Review and Updates: This policy will be reviewed annually and updated as necessary to ensure continued compliance with applicable laws and regulations.

Responsibility:

The Compliance Officer is responsible for overseeing the implementation and enforcement of this policy. All department heads are responsible for ensuring their teams understand and adhere to this policy.

Non-Compliance:

Non-compliance with this policy may result in disciplinary action, up to and including termination of employment or contracts.

Approval:

This policy has been approved by the CEO and the Board of Directors of SNVGL.

  Sierra Nevada Global Logistics (SNVGL) Anti-Inversion Policy

Policy Title: Affirmation of Domestic Corporate Status

Policy Number: SNVGL-ADC-001

Effective Date: 14 December 2023

Policy Statement:

Sierra Nevada Global Logistics (SNVGL) is committed to maintaining its status as a domestic corporation within the United States. SNVGL affirms it is not an inverted domestic corporation and adheres to all regulations and requirements to sustain this status.

Purpose:

This policy affirms SNVGL's commitment to remaining a domestic corporation as defined by U.S. federal regulations, ensuring compliance with relevant laws, and maintaining transparency with our stakeholders.

Scope:

This policy applies to all SNVGL operations, subsidiaries, and affiliates.

Definitions:

• Inverted Domestic Corporation: A company reincorporated in a foreign country while retaining material operations in the United States, typically for tax benefits.
• Domestic Corporation: A corporation incorporated within the United States and adheres to U.S. tax and regulatory standards.

Policy Requirements:

1. Affirmation of Status:
   
   • SNVGL is incorporated in the United States and maintains its headquarters and principal place of business in Reno, Nevada.
   • SNVGL will not engage in any transaction or corporate restructuring that would classify it as an inverted domestic corporation under U.S. law.

1. Compliance with Regulations:
   
   • SNVGL will comply with all U.S. federal, state, and local laws and regulations concerning corporate structure and tax obligations.
   • SNVGL will provide necessary documentation and disclosures to demonstrate its domestic corporate status as required by regulatory bodies and contractual obligations.

1. Corporate Governance:
   
   • The Board of Directors and executive management of SNVGL are responsible for ensuring that the company complies with this policy.
   • Any proposed changes to the corporate structure must be reviewed and approved by the Board of Directors to ensure they do not affect SNVGL's status as a domestic corporation.

1. Employee and Stakeholder Communication:
   
   • SNVGL will communicate its commitment to maintaining its domestic status to all employees and stakeholders.
   • Training and informational sessions will be provided to relevant employees to ensure understanding and compliance with this policy.

1. Monitoring and Reporting:
   
   • SNVGL will implement internal controls and monitoring mechanisms to ensure ongoing compliance with this policy.
   • Any employee who becomes aware of potential non-compliance or any action that could classify SNVGL as an inverted domestic corporation must report it immediately to their supervisor or the Compliance Officer.
   • SNVGL will investigate all reports and take appropriate corrective action as necessary.

1. Policy Review and Updates:
   
   • This policy will be reviewed annually and updated as necessary to reflect any changes in laws, regulations, or corporate structure.
   • Any updates to this policy will be communicated to all relevant stakeholders.

Responsibility:

The Compliance Officer is responsible for overseeing the implementation and enforcement of this policy. The Board of Directors is responsible for reviewing and approving any changes to the corporate structure to ensure compliance with this policy.

Non-Compliance:

Non-compliance with this policy may result in disciplinary action, up to and including termination of employment or contracts.

Approval:

This policy has been approved by the CEO and the Board of Directors of SNVGL.

Policy Title: Equal Opportunity Compliance Reports

Policy Number: SNVGL-EOCR-001

Effective Date: 14 December 2024

Policy Statement:

Sierra Nevada Global Logistics (SNVGL) is committed to maintaining an inclusive, diverse, and equitable workplace. To support this commitment, SNVGL will regularly produce Equal Opportunity Compliance Reports that monitor and ensure adherence to all relevant Equal Opportunity laws and regulations.

Purpose:

This policy outlines the procedures for preparing, reviewing, and disseminating Equal Opportunity Compliance Reports. These reports will help SNVGL monitor compliance, identify areas for improvement, and demonstrate our commitment to equal opportunity in employment.

Scope:

This policy applies to all departments and employees within SNVGL.

Definitions:

• Equal Opportunity: Ensuring all employees and job applicants receive fair treatment without discrimination based on race, color, religion, sex, national origin, age, disability, genetic information, or any other protected characteristic.
• Compliance Reports: Documents that provide data and analysis on SNVGL's adherence to equal opportunity laws and internal policies.

Policy Requirements:

1. Data Collection and Analysis:
   
   • SNVGL will collect data on hiring, promotions, terminations, training, and compensation to ensure compliance with equal opportunity laws.
   • Data will be analyzed to identify trends, disparities, or potential areas of concern.

1. Reporting Schedule:
   
   • Equal Opportunity Compliance Reports will be prepared on a quarterly and annual basis.
   • Reports will be reviewed by the Human Resources (HR) Department and the Compliance Officer before dissemination.

1. Content of Reports:
   
   • Reports will include statistical data on workforce composition, hiring practices, promotions, terminations, and compensation.
   • Analysis of the data to identify any discrepancies or areas needing improvement.
   • Action plans to address identified issues and improve equal opportunity practices.

1. Internal Review and Approval:
   
   • Draft reports will be reviewed by the HR Department and the Compliance Officer.
   • Final reports will be approved by the CEO and the Board of Directors.

1. Dissemination:
   
   • Approved reports will be distributed to senior management and relevant department heads.
   • A summary of findings and action plans will be communicated to all employees to promote transparency and accountability.

1. Continuous Improvement:
   
   • SNVGL will use the findings from the reports to inform and improve equal opportunity policies and practices.
   • Action plans will be implemented to address any identified issues and monitored for effectiveness.

1. Training and Awareness:
   
   • Regular training will be provided to employees and management on equal opportunity policies and practices.
   • Employees will be informed of the importance of compliance and their role in maintaining an inclusive workplace.

1. Record Keeping:
   
   • All data collected and reports produced will be securely stored in accordance with SNVGL’s data retention policies.
   • Records will be maintained for a minimum of five years or as required by law.

Responsibility:

The HR Department and the Compliance Officer are responsible for the preparation, review, and dissemination of the Equal Opportunity Compliance Reports. Senior management and department heads are responsible for implementing action plans and ensuring compliance within their teams.

Non-Compliance:

Non-compliance with this policy may result in disciplinary action, up to and including termination of employment or contracts.

Approval:

This policy has been approved by the CEO and the Board of Directors of SNVGL.

Policy Title: Affirmative Action Compliance

Policy Number: SNVGL-AAC-001

Effective Date: 14 December 2024

Policy Statement:

Sierra Nevada Global Logistics (SNVGL) is dedicated to promoting diversity and inclusion in the workplace. As part of this commitment, SNVGL will implement and maintain an Affirmative Action Program (AAP) to ensure compliance with all applicable affirmative action laws and regulations, and to foster equal employment opportunities for all individuals.

Purpose:

The purpose of this policy is to outline SNVGL's commitment to affirmative action and to establish procedures for developing, implementing, and maintaining an effective Affirmative Action Program.

Scope:

This policy applies to all employees, applicants for employment, and all departments within SNVGL.

Definitions:

• Affirmative Action: A set of proactive measures to recruit, hire, promote, and retain individuals from underrepresented groups, ensuring equal opportunity in the workplace.
• Affirmative Action Program (AAP): A written plan that outlines specific actions and procedures to achieve affirmative action goals and compliance with applicable laws.

Policy Requirements:

1. Affirmative Action Plan Development:
   
   • SNVGL will develop and maintain a written Affirmative Action Plan (AAP) in compliance with Executive Order 11246, the Rehabilitation Act of 1973, the Vietnam Era Veterans’ Readjustment Assistance Act of 1974, and other applicable laws.
   • The AAP will include specific goals, timetables, and action steps to address underrepresentation and ensure equal opportunity in employment.

1. Data Collection and Analysis:
   
   • SNVGL will collect and analyze data on workforce composition, applicant flow, hires, promotions, terminations, and other employment actions to identify areas of underrepresentation and potential barriers to equal opportunity.
   • The data will be used to develop and adjust affirmative action goals and strategies.

1. Outreach and Recruitment:
   
   • SNVGL will engage in proactive outreach and recruitment efforts to attract a diverse pool of qualified candidates.
   • Partnerships with community organizations, educational institutions, and minority-focused groups will be established to support these efforts.

1. Training and Development:
   
   • Regular training on affirmative action and equal employment opportunity (EEO) principles will be provided to all employees, with a focus on managers and supervisors.
   • Development programs and career advancement opportunities will be made available to underrepresented groups to support their growth within the organization.

1. Monitoring and Reporting:
   
   • The effectiveness of the AAP will be monitored regularly through internal audits and compliance reviews.
   • SNVGL will prepare and submit required affirmative action reports to the Office of Federal Contract Compliance Programs (OFCCP) and other relevant agencies as needed.
   • Periodic progress reports will be shared with senior management and the Board of Directors.

1. Employee Involvement:
   
   • All employees are encouraged to support and participate in SNVGL's affirmative action efforts.
   • An open-door policy will be maintained to allow employees to voice concerns or suggestions related to affirmative action and equal employment opportunity.

1. Non-Discrimination and Anti-Retaliation:
   
   • SNVGL will not tolerate discrimination or retaliation against any individual for participating in affirmative action activities or for filing a complaint related to discrimination or non-compliance with affirmative action policies.
   • All complaints will be investigated promptly and thoroughly, with appropriate corrective actions taken as necessary.

Responsibility:

The Compliance Officer and the Human Resources (HR) Department are responsible for the development, implementation, and maintenance of the AAP. Managers and supervisors are responsible for supporting affirmative action efforts within their teams.

Non-Compliance:

Non-compliance with this policy may result in disciplinary action, up to and including termination of employment or contracts.

Approval:

This policy has been approved by the CEO and the Board of Directors of SNVGL.

Policy Title: Buy American Certificate Compliance

Policy Number: SNVGL-BAC-001

Effective Date: [Insert Effective Date]

Policy Statement:

Sierra Nevada Global Logistics (SNVGL) is committed to supporting American manufacturing and ensuring compliance with the Buy American Act (BAA) and other related regulations. As part of this commitment, SNVGL will provide Buy American Certificates for applicable products and services to affirm our compliance with federal procurement requirements.

Purpose:

The purpose of this policy is to outline the procedures for issuing Buy American Certificates, ensuring that SNVGL meets the requirements of the Buy American Act and other relevant laws and regulations.

Scope:

This policy applies to all products and services offered by SNVGL that are subject to the Buy American Act.

Definitions:

• Buy American Act (BAA): A federal law that requires the U.S. government to prefer U.S.-made products in its purchases.
• Buy American Certificate: A document that certifies a product or service complies with the requirements of the Buy American Act.

Policy Requirements:

1. Product Evaluation:
   
   • SNVGL will evaluate all products and services to determine whether they are subject to the Buy American Act.
   • Products and services that fall under the scope of the BAA will be assessed to ensure they meet the necessary criteria.

1. Criteria for Compliance:
   
   • To comply with the Buy American Act, products must be manufactured in the United States and consist of more than 50% U.S.-sourced components.
   • SNVGL will ensure that suppliers and subcontractors provide necessary documentation to verify compliance with these criteria.

1. Issuance of Certificates:
   
   • Buy American Certificates will be issued for products and services that meet the compliance criteria.
   • The certificate will include information such as the product name, description, and a statement confirming its compliance with the Buy American Act.

1. Supplier and Subcontractor Compliance:
   
   • SNVGL will require suppliers and subcontractors to certify that their products and services comply with the Buy American Act.
   • Regular audits and reviews will be conducted to verify the accuracy of these certifications.

1. Record Keeping:
   
   • SNVGL will maintain records of all Buy American Certificates issued, including supporting documentation from suppliers and subcontractors.
   • Records will be retained for a minimum of five years or as required by law.

1. Employee Training:
   
   • Relevant employees will receive training on the requirements of the Buy American Act and the procedures for issuing Buy American Certificates.
   • Training will include information on identifying eligible products, evaluating compliance, and maintaining accurate records.

1. Compliance Monitoring:
   
   • SNVGL will implement procedures to monitor compliance with this policy, including periodic audits and reviews.
   • Any non-compliance or discrepancies identified will be addressed promptly, with corrective actions taken as necessary.

1. Reporting Non-Compliance:
   
   • Employees who become aware of potential non-compliance with the Buy American Act or this policy must report it immediately to their supervisor or the Compliance Officer.
   • SNVGL will investigate all reports and take appropriate corrective action.

Responsibility:

The Compliance Officer and the Procurement Department are responsible for overseeing the implementation and enforcement of this policy. They are also responsible for issuing Buy American Certificates and ensuring that all products and services comply with the Buy American Act.

Non-Compliance:

Non-compliance with this policy may result in disciplinary action, up to and including termination of employment or contracts.

Approval:

This policy has been approved by the CEO and the Board of Directors of SNVGL.

Policy Title: Certification Regarding Responsibility Matters

Policy Number: SNVGL-CRM-001

Effective Date: 14 December 2024

Policy Statement:

Sierra Nevada Global Logistics (SNVGL) is dedicated to maintaining the highest standards of integrity, responsibility, and compliance in all business dealings. In alignment with Executive Order 12689, SNVGL requires certification regarding responsibility matters to ensure that all individuals and entities associated with the company adhere to ethical and legal standards.

Purpose:

The purpose of this policy is to outline the requirements for certification regarding responsibility matters, ensuring compliance with Executive Order 12689 and promoting responsible business practices within SNVGL.

Scope:

This policy applies to all employees, contractors, subcontractors, and suppliers associated with SNVGL.

Definitions:

• Executive Order 12689: An order issued by the President of the United States that mandates the debarment of contractors from federal procurement and non-procurement programs if they are found not to be responsible.
• Certification Regarding Responsibility Matters: A declaration made by individuals or entities to affirm their compliance with ethical, legal, and regulatory standards, and their eligibility to participate in federal procurement and non-procurement programs.

Policy Requirements:

1. Certification Requirement:
   
   • All employees, contractors, subcontractors, and suppliers must complete and submit a Certification Regarding Responsibility Matters as a condition of their association with SNVGL.
   • The certification must affirm that the individual or entity is not debarred, suspended, proposed for debarment, or otherwise declared ineligible for participation in federal procurement or non-procurement programs.

1. Content of Certification:
   
   • The certification must include the following statements:
     • The individual or entity has not been convicted of or had a civil judgment rendered against them for fraud, antitrust violations, embezzlement, theft, forgery, bribery, falsification or destruction of records, making false statements, tax evasion, or receiving stolen property.
     • The individual or entity is not presently indicted for or otherwise criminally or civilly charged by a governmental entity with any of the offenses listed above.
     • The individual or entity has not, within the past three years, been terminated for cause or default by any federal agency.
     • The individual or entity has not, within the past three years, been notified of any delinquent federal taxes in an amount that exceeds $3,000.

1. Submission and Review:
   
   • Certifications must be submitted to the Compliance Officer for review and approval before any contract or business association is finalized.
   • The Compliance Officer will verify the accuracy of the certifications and maintain records of all submissions.

1. Periodic Updates:
   
   • Certifications must be updated and resubmitted annually or whenever there is a change in the status of the individual or entity.
   • The Compliance Officer will monitor compliance and request updates as necessary.

1. Training and Awareness:
   
   • Relevant employees will receive training on the requirements and importance of the Certification Regarding Responsibility Matters.
   • Training will include information on identifying responsible business partners and maintaining compliance with Executive Order 12689.

1. Non-Compliance and Reporting:
   
   • Any individual or entity found to be non-compliant with this policy or to have submitted false certifications will be subject to disciplinary action, up to and including termination of employment or contracts.
   • Employees who become aware of potential non-compliance or false certifications must report it immediately to their supervisor or the Compliance Officer.
   • SNVGL will investigate all reports and take appropriate corrective action.

Responsibility:

The Compliance Officer is responsible for overseeing the implementation and enforcement of this policy. All department heads and managers are responsible for ensuring compliance within their teams.

Approval:

This policy has been approved by the CEO and the Board of Directors of SNVGL.

Effective Date: [Insert Date]

The purpose of this policy is to affirm Sierra Nevada Global Logistics' (SNVGL) commitment to environmental transparency and responsibility by publicly disclosing our greenhouse gas (GHG) emissions. This policy outlines the standards and procedures for conducting, reporting, and publicly sharing our GHG emissions inventory.

This policy applies to all operations of SNVGL and covers all GHG emissions generated by the company.

• Accounting Standard: SNVGL will perform its GHG emissions inventory in accordance with the Greenhouse Gas Protocol Corporate Standard or another equivalent accounting standard that has publicly available and consistently applied criteria.
• Data Collection: The inventory will include comprehensive data on all relevant GHG emissions sources, including direct emissions from owned or controlled sources and indirect emissions from the generation of purchased electricity, heat, or steam.

• Transparency: SNVGL is committed to transparency and will publicly disclose the results of our GHG emissions inventory.
• Website Publication: The results of the GHG emissions inventory will be made available on a publicly accessible section of the SNVGL website. This will include a detailed report of the emissions data and the methodologies used.
• Annual Updates: The GHG emissions inventory and the corresponding public disclosure will be updated annually to reflect the most current data and any changes in our operations or accounting standards.

• Consistency: SNVGL will ensure that the criteria and methodologies used in the GHG emissions inventory are consistently applied from year to year to allow for comparability and trend analysis.
• Verification: Where possible, the GHG emissions inventory will be verified by an independent third party to ensure accuracy and reliability of the reported data.

• Environmental Team: The Environmental Team at SNVGL is responsible for conducting the GHG emissions inventory, ensuring compliance with the chosen accounting standard, and preparing the public disclosure report.
• Management Review: The GHG emissions inventory and public disclosure report will be reviewed and approved by senior management before publication.
• Stakeholder Engagement: SNVGL will engage with stakeholders, including employees, partners, and the community, to communicate our GHG emissions data and solicit feedback on our environmental performance.

This policy will be reviewed annually and updated as necessary to reflect changes in regulations, best practices, and organizational values. Any amendments to this policy will be communicated to all employees, partners, and stakeholders.

Authorized by:

Evan Kirkwood
CEO
Sierra Nevada Global Logistics (SNVGL)