Ethics & Compliance

Hillstone Corporation (UEI XJB7GHKQMGM7, CAGE 99AJ7) is committed to the highest standards of integrity in its work for U.S. Government customers and their prime contractors. This page publishes our Combating Trafficking in Persons (CTIP) Compliance Plan, posted in accordance with FAR 52.222-50(h)(4), our Code of Business Ethics and Conduct, and our Anti-Corruption, Trade Compliance and Quality Assurance Policy.

Combating Trafficking in Persons (CTIP) Compliance Plan (HC-PLN-002)
Code of Business Ethics and Conduct (HC-POL-001)
Anti-Corruption, Trade Compliance and Quality Assurance Policy (HC-POL-003)

Combating Trafficking in Persons (CTIP) Compliance Plan

Document HC-PLN-002 · Revision 00 · Effective October 20, 2026 · Approved by Suham B. Faqi, Founder & CEO

1. Purpose and Authority

This Plan sets out how Hillstone prevents trafficking in persons in its operations and supply chain. It is prepared in accordance with FAR Subpart 22.17, FAR 52.222-50 (Combating Trafficking in Persons), Executive Order 13627 and 22 U.S.C. § 7104(g), and contains each element required of a compliance plan under FAR 52.222-50(h).

2. Scope

This document applies to Hillstone Corporation (USA) and to all personnel, agents, representatives, recruiters, suppliers and subcontractors at any tier who perform work on Hillstone’s behalf, including work performed through Hillstone’s regional affiliate companies in the State of Qatar, the State of Kuwait, the Kingdom of Bahrain and the Republic of Iraq. It covers in particular third-country national workers recruited for work in the Arabian Gulf region, including drivers, warehouse staff, technicians and laborers employed by Hillstone, its affiliates or its subcontractors.

3. Policy Statement

Hillstone has zero tolerance for trafficking in persons. No employee, agent, recruiter or subcontractor may engage in, support or tolerate any trafficking-related activity, whether or not it occurs on a U.S. Government contract.

The following are prohibited (FAR 52.222-50(b)):

Engaging in severe forms of trafficking in persons, procuring commercial sex acts, or using forced labor.
Destroying, concealing, confiscating or otherwise denying an employee access to his or her identity or immigration documents, such as a passport or residence permit.
Using misleading or fraudulent practices during recruitment, such as failing to disclose, or misrepresenting, key terms of employment including wages, benefits, location, living conditions, housing costs, and the hazardous nature of the work.
Using recruiters that do not comply with the labor laws of the country in which the recruiting takes place.
Charging employees recruitment fees.
Failing to provide return transportation, or to pay its cost, at the end of employment for an employee who is not a national of the country of performance and was brought there to work on a U.S. Government contract or subcontract (subject to the exceptions in FAR 52.222-50).
Providing or arranging housing that fails to meet host-country housing and safety standards.
Failing to provide a written employment contract, recruitment agreement or other required work document, in a language the employee understands, where required by law or contract – and, for an employee relocating to perform the work, at least five days before departure from the country of origin.

4. Awareness Program

Every new employee receives a CTIP briefing at onboarding, before deployment to any work site, and acknowledges it in writing.
Refresher training is provided at least annually to all personnel.
Notices describing employee rights, the prohibited activities above and the reporting channels are posted at each work site, labor camp and office, in English, Arabic and the principal languages of the workforce (for example Hindi, Urdu, Nepali, Bengali, Sinhala and Tagalog).
Subcontractors and recruiters receive a copy of this Plan and must brief their own workers.

5. Reporting Without Fear of Retaliation

Any person may report a suspected violation, openly or anonymously, through the following channels:

Channel	Contact
Ethics & Compliance Officer	Suham B. Faqi, Founder & CEO \| Suham@hillstoneus.com \| +1 (619) 902-9073
Company mailbox	info@hillstoneus.com (mark the subject line “CONFIDENTIAL – ETHICS”)
DoD Hotline	www.dodig.mil/hotline \| 1-800-424-9098
Global Human Trafficking Hotline	1-844-888-FREE (3733) \| help@befree.org

No action will be taken against any person who reports in good faith. Retaliation is itself a serious violation of this Plan. All reports are kept confidential to the greatest extent possible.

6. Recruitment and Wage Plan

Licensed recruiters only: Hillstone uses only recruitment agencies that are licensed in the country where recruiting takes place, whose staff are trained in this Plan, and that sign a written agreement prohibiting fees to workers.
No recruitment fees: workers pay no recruitment fees of any kind. Each worker signs a fee declaration on arrival; if a worker is found to have paid a fee, Hillstone or the responsible recruiter reimburses it in full.
Honest terms: wages, benefits, hours, location, housing and the nature of the work are stated in writing before recruitment and are not changed to the worker’s disadvantage on arrival.
Wages: wages meet or exceed host-country legal requirements. Any variance is explained in writing. Wages are paid on time by bank transfer, with a pay slip in a language the worker understands, and without unlawful deductions.

7. Housing Plan

Where Hillstone or a subcontractor provides or arranges housing, the housing will meet host-country housing and safety standards and any housing requirements in the applicable contract. Housing is inspected before occupancy and periodically thereafter, and deficiencies are corrected promptly.

8. Identity Documents

Workers keep their own passports, residence permits and identity documents. Where a worker asks in writing for secure storage, documents are kept in a locked location the worker can access at any time, and are returned immediately on request.

9. Subcontractors and Agents: Prevention, Monitoring and Termination

Due diligence: before engagement, subcontractors and recruiters are screened (including SAM.gov exclusions) and must confirm in writing that they comply with this Plan.
Flow-down: FAR 52.222-50 is included in every subcontract and recruitment agreement, together with the compliance-plan and certification requirements where they apply.
Monitoring: Hillstone may conduct site and housing visits, confidential worker interviews and reviews of pay and recruitment records.
Detection and termination: any subcontractor or agent found to be engaged in a prohibited activity will be required to remedy it, and Hillstone may suspend or terminate the relationship.

10. Notification, Investigation and Remedy

On receiving any credible information that an employee, subcontractor, subcontractor employee or agent has engaged in conduct that violates this Plan or FAR 52.222-50, Hillstone will immediately inform the Contracting Officer (and the prime contractor, where Hillstone is a subcontractor) and the agency Inspector General.
Hillstone will cooperate fully with any Government audit or investigation and provide reasonable access to facilities and staff.
Victims will be protected, and Hillstone will take remedial action such as reimbursing fees, providing return transportation and taking action against the responsible persons.

11. Annual Certification

Where required by FAR 52.222-50(h)(5), before receiving an award and annually thereafter, Hillstone will certify that it has implemented this Plan and that, after due diligence, either no abuses relating to any of the prohibited activities have been found, or appropriate remedial and referral actions have been taken. Subcontractors subject to the same requirement must provide the same certification to Hillstone.

12. Posting, Responsibility and Review

The relevant contents of this Plan are posted at each workplace and on Hillstone’s website (www.hillstoneus.com).
The Ethics & Compliance Officer is responsible for implementing this Plan, keeping training and inspection records, and reviewing the Plan at least annually.

Code of Business Ethics and Conduct

Document HC-POL-001 · Revision 00 · Effective October 20, 2026 · Approved by Suham B. Faqi, Founder & CEO

1. Purpose

Hillstone Corporation supplies equipment, materials, logistics and support services to U.S. Government customers and their prime contractors in the Middle East. Our customers trust us with work that supports service members and diplomatic missions, often in demanding environments. This Code sets out the standards of conduct we hold ourselves to and that we expect from everyone who works with us.

This Code is consistent with FAR 52.203-13 (Contractor Code of Business Ethics and Conduct) and the principles of the Defense Industry Initiative (DII) Model Supplier Code of Conduct adopted by our prime contractor customers. Where a law, a contract term and this Code differ, we follow the law first, then the contract, then this Code.

2. Scope

3. Compliance with Laws

We comply with all laws and regulations that apply to our business, and with every flow-down clause in our subcontracts and purchase orders. These include, among others:

The Federal Acquisition Regulation (FAR) and the Defense Federal Acquisition Regulation Supplement (DFARS).
The U.S. Foreign Corrupt Practices Act, the Anti-Kickback Act (41 U.S.C. §§ 8701–8707), the Procurement Integrity Act and the False Claims Act.
U.S. export control, sanctions and anti-boycott laws (EAR, ITAR, OFAC regulations).
The laws of each host nation in which we operate, including labor, customs, tax and anti-bribery laws of Qatar, Kuwait, Bahrain and Iraq.

4. Accurate Records, Billing and Certifications

Every record, invoice, timesheet, quotation and certification we create must be complete, accurate and truthful.
We never alter, back-date or conceal a record, and we never charge a cost to the wrong contract.
Records are retained as required by FAR 4.703 and by the contract, and longer where a dispute, audit or investigation is pending.
Representations and certifications in SAM.gov, proposals and supplier portals are kept current and accurate.

5. Anti-Corruption, Gifts and Kickbacks

We do not offer, pay, solicit or accept bribes, kickbacks or anything of value intended to improperly influence a decision. This includes facilitation payments to speed up routine government actions such as customs clearance, visas, permits or base access, even where local practice tolerates them. The detailed rules, including our customs-clearance procedure, are set out in Policy HC-POL-003.

We do not offer gifts, meals or entertainment to U.S. Government personnel, and we offer customer and prime contractor procurement staff nothing beyond small promotional items of very low value.

6. Fair Competition

We compete on the merits of our price, quality and performance.
We never fix prices, rig bids, allocate customers or exchange current or future pricing information with competitors.
We never seek or use contractor bid or proposal information or source selection information that we are not authorized to have.

7. Conflicts of Interest

Personnel must avoid any situation in which personal, family or financial interests conflict, or appear to conflict, with the interests of Hillstone or its customers. Any actual or potential conflict must be disclosed in writing to the Ethics & Compliance Officer before the person takes part in the matter. Before discussing employment with a current or former U.S. Government official, we confirm compliance with post-employment restrictions (18 U.S.C. § 207 and FAR 3.104).

8. Human Rights and Fair Labor

Hillstone has zero tolerance for trafficking in persons. We do not use forced, bonded or child labor; we do not hold workers’ passports or identity documents; we do not charge workers recruitment fees; and we provide written employment terms in a language each worker understands. Our full program is set out in the Combating Trafficking in Persons (CTIP) Compliance Plan, HC-PLN-002.

Respect and non-discrimination: we treat everyone with dignity and provide equal opportunity without regard to race, ethnicity, religion, color, sex, national origin, age, veteran status, disability or other protected characteristic.
Harassment: physical, verbal and psychological harassment and abusive conduct are prohibited.
Substance abuse: the illegal use, possession, sale or distribution of controlled substances at work is prohibited.

9. Health, Safety and Environment

We protect the health and safety of our people, customers, visitors and the public, and we comply with all applicable environmental, health and safety laws and contract requirements, in line with the Hillstone HSE Policy (HS-IMS-HSE-P-01).

10. Information Protection

Confidential and proprietary information of customers and partners is used only for the purpose for which it was provided.
Controlled Unclassified Information and covered defense information are safeguarded as required by the contract, including DFARS 252.204-7012 where it applies.
We respect intellectual property rights and comply with applicable data privacy laws.
Any loss or unauthorized release of customer information is reported to the customer immediately.

11. Global Trade Compliance

We comply with all import, export, customs and sanctions laws. We screen suppliers, consignees and end users against U.S. Government restricted-party lists; we do not participate in unsanctioned foreign boycotts; and we do not supply prohibited telecommunications equipment (FAR 52.204-25). Details are in Policy HC-POL-003.

12. Quality and Counterfeit Prevention

We deliver products and services that meet or exceed contract requirements. We source from original manufacturers and authorized distributors wherever possible, keep traceability records, and quarantine and report any suspected counterfeit item. Details are in Policy HC-POL-003.

13. Suppliers, Subcontractors and Agents

We expect our own suppliers, subcontractors, recruiters, customs brokers and agents to meet the standards in this Code. Before engaging them we check SAM.gov exclusions and restricted-party lists, we flow down the required contract clauses, and we may end the relationship with any party that violates this Code.

14. Reporting Concerns and Non-Retaliation

Anyone who suspects a violation of law, of a contract or of this Code must report it. Reports may be made openly or anonymously through any of the channels below:

Channel	Contact
Ethics & Compliance Officer	Suham B. Faqi, Founder & CEO \| Suham@hillstoneus.com \| +1 (619) 902-9073
Company mailbox	info@hillstoneus.com (mark the subject line “CONFIDENTIAL – ETHICS”)
DoD Hotline	www.dodig.mil/hotline \| 1-800-424-9098
Global Human Trafficking Hotline	1-844-888-FREE (3733) \| help@befree.org

Hillstone does not retaliate against anyone who raises a concern in good faith. Employees of contractors and subcontractors are also protected from reprisal under 10 U.S.C. § 4701 and 41 U.S.C. § 4712.

Where Hillstone has credible evidence that a principal, employee, agent or subcontractor has committed a violation of federal criminal law involving fraud, conflict of interest, bribery or gratuities, or a violation of the civil False Claims Act, in connection with a Government contract or subcontract, Hillstone will disclose it in writing to the agency Office of the Inspector General and the Contracting Officer as required by FAR 52.203-13.

15. Training, Acknowledgment and Enforcement

All personnel receive this Code at onboarding and acknowledge it in writing; refresher training is provided annually.
Violations may result in disciplinary action up to and including termination of employment or of the business relationship, and may be reported to the authorities.
This Code is reviewed at least annually and whenever laws or customer requirements change.

Anti-Corruption, Trade Compliance and Quality Assurance Policy

Document HC-POL-003 · Revision 00 · Effective October 20, 2026 · Approved by Suham B. Faqi, Founder & CEO

1. Purpose and Scope

This Policy explains how Hillstone prevents bribery and corruption, complies with trade and sanctions laws, and assures the quality and authenticity of the products it delivers. It supports the Code of Business Ethics and Conduct (HC-POL-001).

Part A – Anti-Corruption

2. Prohibited Payments

No one acting for Hillstone may offer, promise, give, solicit or accept money or anything of value to improperly influence any official or business decision.
This applies to government officials, military personnel, employees of prime contractors and suppliers, and their family members, directly or through any third party.
Kickbacks are prohibited under the Anti-Kickback Act (41 U.S.C. §§ 8701–8707). Any suspected kickback is reported to the Contracting Officer or the Inspector General as the Act requires.
Hillstone makes no political contributions on behalf of the company.

3. Facilitation Payments

Hillstone prohibits facilitation payments – small payments to speed up routine government actions such as customs clearance, visas, residence permits, licenses, inspections or base and port access – even where local law or practice allows them.

The only exception is a payment made under duress where there is an imminent threat to a person’s health or safety. Any such payment must be reported to the Ethics & Compliance Officer within 24 hours and recorded accurately.

4. Customs-Clearance Procedure

Customs clearance is central to our work in Qatar, Kuwait, Bahrain and Iraq. The following controls apply to every shipment:

Only licensed customs brokers and freight forwarders that have passed Hillstone due diligence are used.
Every broker signs a written agreement containing anti-bribery commitments, a prohibition on facilitation payments, and Hillstone’s right to audit.
All duties, taxes and fees are paid to the government authority against an official receipt. No cash is paid to any official.
Broker invoices must itemize every charge with supporting official receipts. Unexplained, round-sum or “miscellaneous” charges are rejected and investigated.
Any request for an unofficial payment is refused and reported to the Ethics & Compliance Officer.
Clearance documents, receipts and broker invoices are retained with the shipment file.

5. Gifts and Hospitality

No gifts, meals, travel or entertainment are offered to U.S. Government personnel.
Business courtesies to commercial customers and suppliers must be modest, infrequent, lawful, permitted by the recipient’s own rules, and accurately recorded. Procurement staff of customers and prime contractors are offered nothing beyond small promotional items of very low value.
Hillstone personnel may not accept any gift or courtesy that could influence, or appear to influence, a purchasing decision.

6. Third Parties

Agents, sponsors, consultants, brokers and subcontractors are screened before engagement, paid only by bank transfer against documented services at market rates, and bound by written anti-corruption terms. Red flags – such as requests for cash, unusual commissions, payments to third countries or a close relationship with an official – are investigated before any payment is made.

7. Books and Records

All payments and expenses are recorded accurately and in reasonable detail. No off-the-books account or undisclosed fund may be kept for any purpose.

Part B – Trade Compliance and Screening

8. Screening and Sanctions

Suppliers, subcontractors, consignees and end users are screened against the SAM.gov exclusions list and the U.S. Government Consolidated Screening List, including the OFAC Specially Designated Nationals list.
Hillstone does not deal in goods, services or technology of Iranian origin, or in any transaction prohibited by U.S. sanctions regulations.
Hillstone does not supply covered telecommunications or video surveillance equipment or services prohibited by Section 889 (FAR 52.204-25).

9. Export, Import and Anti-Boycott

Export classification and licensing requirements under the EAR and ITAR are confirmed before any export or re-export.
Accurate country-of-origin, value and classification information is declared to customs authorities.
Hillstone does not participate in or cooperate with unsanctioned foreign boycotts. Any boycott-related request in a tender, purchase order, letter of credit or shipping document is refused and reported as required under the EAR (15 C.F.R. Part 760).

Part C – Quality Assurance and Counterfeit Prevention

10. Sourcing and Traceability

Products are sourced from the original manufacturer (OEM) or its authorized distributors wherever possible.
Where an authorized source is not available, the risk is assessed, the customer’s approval is obtained where required, and enhanced inspection is performed before delivery.
Each delivery is supported by traceability documents, such as manufacturer certificates of conformance, certificates of origin, packing lists and warranty documents.

11. Receiving Inspection and Nonconforming Items

Items are inspected on receipt against the purchase order, specifications, markings, quantities and documents.
Nonconforming items are tagged, segregated and not delivered until the nonconformance is resolved.
Corrective action is taken for each nonconformance, and supplier performance is evaluated on quality and delivery.

12. Suspected Counterfeit Items

A suspected counterfeit item is quarantined immediately and is not returned to the supplier.
The customer is notified promptly in writing.
Counterfeit or suspect counterfeit items are reported to the Government-Industry Data Exchange Program (GIDEP) where required by FAR 52.246-26, and the requirements of DFARS 252.246-7008 are flowed down for electronic parts where the contract requires it.

13. Quality Records

Inspection records, certificates, test reports and corrective-action records are retained in accordance with the Hillstone Integrated Management System (IMS) quality procedures and contract requirements.

Part D – Reporting and Enforcement

14. Reporting and Discipline

Suspected violations of this Policy must be reported through the channels listed below. Hillstone does not retaliate against anyone who reports in good faith. Violations may lead to disciplinary action, termination of employment or of the business relationship, and referral to the authorities.

Channel	Contact
Ethics & Compliance Officer	Suham B. Faqi, Founder & CEO \| Suham@hillstoneus.com \| +1 (619) 902-9073
Company mailbox	info@hillstoneus.com (mark the subject line “CONFIDENTIAL – ETHICS”)
DoD Hotline	www.dodig.mil/hotline \| 1-800-424-9098
Global Human Trafficking Hotline	1-844-888-FREE (3733) \| help@befree.org