Anti-Corruption Policy
Last Updated August 12, 2026
1. Policy Statement
TreeRing Workforce Solutions maintains an Anti-Bribery Policy prohibiting any improper or unethical payment to government officials or a party to a private commercial transaction anywhere in the world by any TreeRing Workforce Solutions officer or employee or agent of TreeRing Workforce Solutions. This Anti-Bribery Policy is designed to comply with the requirements of the U.S. Foreign Corrupt Practices Act (the “FCPA”), the U.K. Bribery Act 2010 (the “U.K. Bribery Act”) and the anti-bribery laws of those other jurisdictions in which we do business. These laws generally prohibit bribes, kickbacks, or illegal payments to influence business transactions and require us to maintain accurate books and records and a system of internal controls. Additionally, all TreeRing Workforce Solutions officers, employees, and agents are strictly prohibited from accepting gifts of substantial value from TreeRing Workforce Solutions customers, vendors, or prospective customers or vendors.
2. Policy Purpose
TreeRing Workforce Solutions’s Anti-Bribery Policy states:
a. No TreeRing Workforce Solutions employee or agent has the authority to offer payments of money or anything else of substantial value, whether directly or indirectly, to a government official or a participant in a private commercial transaction to improperly induce that person to
b. affect any act or decision in a manner that will assist TreeRing Workforce Solutions to obtain or retain business.
c. Every TreeRing Workforce Solutions employee and agent has the obligation to record accurately and fairly all of their transactions involving any expense of TreeRing Workforce Solutions or any other transaction involving the disposal or transfer of TreeRing Workforce Solutions assets.
d. No TreeRing Workforce Solutions employee or agent may accept gifts of substantial value, whether directly or indirectly, that may induce the employee or agent to affect any act or decision in a manner that will assist a customer, vendor, or prospective customer or vendor in receiving preferential pricing or terms and/or obtaining business.
3. In addition to direct payments of money, other examples of prohibited payments would include the following made at the direction, or for the benefit, of a government official or a commercial business partner:
a. gifts, travel, meals, entertainment or other hospitality expenses;
b. contributions to any political party, campaign or party official; or;
c. charitable contributions and sponsorships.
4. Policy Scope
The Anti-Bribery Policy extends to TreeRing Workforce Solutions’s operations anywhere in the world, and applies to all employees, agents, consultants or other representatives, as well as to any partnership or teaming agreement in which TreeRing Workforce Solutions is a participant. The Anti-Bribery Policy is applicable to activities of individual TreeRing Workforce Solutions employees, as well as corporate and business unit programs, events, campaigns and other initiatives.
a. Penalties
Violations by any TreeRing Workforce Solutions employee of the anti-bribery laws or this Policy will result in progressive discipline, up to and including termination of such employee’s employment with TreeRing Workforce Solutions. Violations by any TreeRing Workforce Solutions employee or agent can also result in severe penalties for both TreeRing Workforce Solutions and such individuals.
For example, individuals can receive five years of imprisonment and a $100,000 fine for each violation of the anti-bribery provisions of the FCPA, and 20 years imprisonment and a $5 million fine for each violation of the record keeping provisions of the FCPA. Under the U.K. Bribery Act, bribery and corruption is punishable for individuals by up to ten years imprisonment and companies could face an unlimited fine.
The FCPA specifically prohibits a company from reimbursing an officer, director, stockholder, employee, or agent for fines imposed for violations of the FCPA, so any fines for violations for which the individual it responsible will be paid from their personal assets. In addition, and in accordance with TreeRing Workforce Solutions’s general legal compliance policy, TreeRing Workforce Solutions will cooperate fully with law enforcement authorities in the investigation and prosecution of alleged violations of anti-bribery laws.
b. Gifts, Travel, Entertainment and Other Expenses
Government Officials
TreeRing Workforce Solutions permits TreeRing Workforce Solutions logo items to be given to government officials as modest gifts in the ordinary course of business, provided that:
I. such gifts do not exceed U.S. $25 in value; and
II. presenting any such gift will be in conformity with the applicable laws where the gift has been made.
c. TreeRing Workforce Solutions also permits reasonable expenditures for travel, meals and entertainment expenses legitimately related to training in the use of TreeRing Workforce Solutions’s products and services, or otherwise related directly to TreeRing Workforce Solutions’s promotion of its products and services, provided such expenditures are not extravagant and otherwise conform to the limitations in this Policy and to the applicable laws where the expenditures are incurred. Before providing, directly or indirectly, any such travel, meals or entertainment expenditure for a government official, employees must first obtain permission from the Chief Operating Officer, who will review the legality of the proposed expenditure.
It will never be acceptable to offer any gift or incur any expense in expectation of receiving something in return (quid pro quo).
The following persons are considered “government officials”:
i. officers and employees of any government, department, agency, bureau, authority, instrumentality or public international organization;
ii. persons acting in an official capacity on behalf of a government;
iii. employees of entities that are owned or controlled by a government; and
iv. candidates for political office.
d. Commercial Partners
Other than for gifts with a value of no more than U.S. $25 given or received in the normal course of business, TreeRing Workforce Solutions employees and agents shall not give gifts to, or receive gifts, directly or indirectly, from TreeRing Workforce Solutions’s current or prospective customers, vendors or any other commercial partners. Presenting or accepting any other gifts to or from private commercial parties requires prior written approval from the Chief Operating Officer, who will review the legality of the proposed gift.
TreeRing Workforce Solutions permits accepting or incurring proportionate and reasonable expenditures for travel, meals and entertainment expenses legitimately designed to provide training to existing business partners, present products and services, or establish cordial business relations, provided that such expenditures:
I. are not excessive and always appropriate to the nature of business relationship with the recipient;
II. conform with the applicable laws where the gift has been
III. made.
IV. do not place the recipient under an obligation or expectation to confer any business advantage in return for such hospitality (quid pro quo), or create an impression that the recipient’s independence will be affected; and
V. occur only occasionally.
e. Before providing or accepting, directly or indirectly, any travel, meals or entertainment expenditure reasonably valued at more than U.S. $250 for each guest, employees must first obtain written permission from the Chief Operating Officer, who will review the legality of the proposed expenditure.
f. It is crucial that entertainment should not be given or received on such a scale that it forms an inducement to enter into a business transaction or arrangement which would not otherwise be undertaken.
g. Moreover, in no event may any gift or hospitality cause any other provision of this Policy or any provision of the Employee handbook to be violated, or put TreeRing Workforce Solutions in a position that may cause embarrassment.
5. Third Parties’ Compliance with TreeRing Workforce Solutions’s Anti-Bribery Policy
TreeRing Workforce Solutions’s obligation of ethical and legal behavior includes and encompasses the activities of TreeRing Workforce Solutions’s agents, representatives, consultants, vendors and business partners. TreeRing Workforce Solutions may be held liable for the actions of third parties doing business with or on behalf of TreeRing Workforce Solutions, so every employee and agent is required to ensure such third party’s actions are consistent with this Policy. Willful ignorance of facts or circumstances which make it likely that bribery could be occurring will be a violation of this Policy and may amount to a violation of anti-bribery laws.
Before establishing a relationship with any third party to, sufficient due diligence must be performed to determine that the third party’s commitment to ethical business practices is consistent with TreeRing Workforce Solutions’s high standards, this Policy and the TreeRing Workforce Solutions Vendor Terms and Conditions.
Any arrangement with such third party should include proper contractual provisions and monitoring procedures to ensure compliance with anti-bribery laws and consistency with TreeRing Workforce Solutions’s Anti-Bribery Policy. Particular care should be taken in any instance where the third party has interactions with government officials in the performance of its services on behalf of TreeRing Workforce Solutions.
6. Reporting Violations
Each employee and agent’s conduct can reinforce an ethical atmosphere and positively influence the conduct of fellow employees. If you are aware of or suspect misconduct, you should report it to the appropriate level of management.
If an employee or agent is still concerned after speaking with your manager or feel uncomfortable speaking with them, you should contact the TreeRing Workforce Solutions Legal Department by email at legal@TreeRingWS.com or the Chief Operating Officer.
Any reports that involve the Chief Executive Officer, Chief Financial Officer, Chief Operating Officer or Vice President of Accounting should be immediately communicated to the Chairman of the Board of Directors.
All calls, detailed notes and/or emails will be dealt with confidentially, unless it is necessary to share such information in order to address the matter appropriately.
Nothing in this or any other TreeRing Workforce Solutions policy prohibits employees or agents from providing information to the U.S. Securities and Exchange Commission or any government agency in a manner contemplated by relevant law or regulation.
A failure to report known or suspected wrongdoing in connection with TreeRing Workforce Solutions’s business of which a TreeRing Workforce Solutions employee or agent has knowledge may, by itself, subject that individual to disciplinary action.
7. Administration of Anti-Bribery Policy
The Anti-Bribery Policy will be administered by TreeRing Workforce Solutions’s Chief
Operating Officer. Any violations of the Anti-Bribery Policy will be reported to
the President, Chief Executive Officer and TreeRing Workforce Solutions’s Board of
Directors.
8. Further Information
Should you have any other questions about the Anti-Bribery Policy, please contact the TreeRing Workforce Solutions Legal Department at
legal@TreeRingWS.com
TreeRing Workforce Solutions, Inc
4780 Ashford Dunwoody Rd, Ste A-145
Atlanta, GA 30338
1-855-861-4381