Ethics & Whistleblower Policy

Aliff Solutions FZC is committed to conducting business with integrity, transparency, and respect for the law. This Ethics and Whistleblower Policy sets out the standards of conduct expected of all personnel, contractors, and partners, and establishes a safe mechanism for reporting concerns.

As a company serving the government contracting marketplace, we hold ourselves to a high standard of ethical behavior. Trust is the foundation of our business, and we take seriously our responsibility to earn and maintain that trust with every client interaction.

All personnel acting on behalf of Aliff Solutions are expected to:

• Act with integrity: Conduct all business honestly and ethically, avoid misrepresentation, and uphold the trust placed in us by our clients
• Comply with the law: Follow all applicable laws, regulations, and contractual obligations, including export controls, sanctions, anti-corruption, and data protection laws
• Protect confidential information: Safeguard all client data, proprietary information, and business intelligence according to our confidentiality obligations
• Avoid conflicts of interest: Disclose any personal, financial, or business relationships that could create or appear to create a conflict with Aliff Solutions' duties to its clients, as outlined in our OCI Policy
• Maintain fair dealing: Treat all clients, partners, and competitors fairly. Do not engage in unfair business practices, deceptive conduct, or manipulation of competitive processes
• Promote a respectful environment: Treat all individuals with dignity and respect, regardless of race, gender, religion, national origin, disability, age, sexual orientation, or any other characteristic protected by applicable law

Aliff Copilot and our analytical engines (win probability, pricing optimization, recompete prediction, and incumbent scoring) use AI models that may reflect biases present in training data. We are committed to:

• Bias monitoring: Regularly evaluating our AI models for biases that could lead to unfair outcomes, including biases related to company size, geographic location, demographic characteristics of company ownership, or socioeconomic set-aside categories
• Transparency: Clearly disclosing the advisory nature of all AI-generated outputs, as documented in our AI Terms of Service
• Human oversight: Requiring human professional judgment before any AI-generated output is used in a business decision, proposal submission, or government communication
• Automated decision-making: The Aliff Solutions platform does not make automated decisions with legal or similarly significant effects on individuals without human review. All AI outputs are advisory and require human action to implement. This is consistent with GDPR Article 22 regarding automated individual decision-making
• Continuous improvement: Incorporating feedback from clients and users to identify and address potential fairness issues in our AI models

If you believe an AI output from our platform reflects unfair bias, please report it through our contact page. We take all bias reports seriously.

Aliff Solutions encourages the reporting of any conduct that may violate this policy, applicable law, or our contractual obligations. We provide the following protections for individuals who report concerns in good faith:

• Non-retaliation: We will not retaliate against any individual who reports a concern in good faith, even if the report ultimately proves unfounded. Retaliation includes termination, demotion, suspension, harassment, or any other adverse action
• Confidentiality: Reports will be treated with the highest degree of confidentiality consistent with the need to investigate the matter. The identity of the reporting individual will not be disclosed without their consent, except as required by law
• Investigation: All reports will be investigated promptly and thoroughly. Appropriate corrective action will be taken where warranted
• Anonymous reporting: Anonymous reports may be submitted through our contact page. While we encourage providing contact information to facilitate investigation, anonymous reports will be investigated to the extent possible

If you have a concern about a potential violation of this policy, applicable law, or ethical standards, you may report it through the following channels:

• Online: aliffsolutions.com/contact — select "Ethics / Compliance Concern" as the topic
• In writing: Send a written report addressed to the CEO, Aliff Solutions FZC, United Arab Emirates

Reports should include as much detail as possible, including:

• A description of the conduct or concern
• The date(s) and location(s) of the events
• The names of individuals involved, if known
• Any supporting documentation or evidence

Aliff Solutions recognizes the importance of procurement integrity in government contracting and is committed to supporting our clients in maintaining compliance. We specifically note:

• False Claims Act awareness: Clients should be aware that submitting false claims to the U.S. government — including false pricing, false certifications, or misrepresented qualifications — can result in severe civil and criminal penalties. AI-generated outputs from our platform must be verified by qualified professionals before inclusion in any government submission
• Procurement Integrity Act: Aliff Solutions does not solicit, obtain, or distribute source selection information or contractor bid/proposal information as defined under the Procurement Integrity Act (41 U.S.C. 2101-2107)
• Accurate representations: We make accurate representations about the capabilities and limitations of our platform. We do not claim certifications we do not hold or compliance status we have not achieved

For questions about this policy or to report an ethical concern, please contact us.

Entity: Aliff Solutions FZC, Ras Al Khaimah, United Arab Emirates