Code of Ethics & Business Conduct

Document Reference: AUC-GOV-COE-001
Version: 3.1.0
Effective Date: October 24, 2026
Last Updated: October 24, 2026
Classification: Public / Corporate Governance
Standards Alignment: Sarbanes-Oxley Act § 406 | Foreign Corrupt Practices Act (FCPA) | UK Bribery Act 2010 | OECD Guidelines

Executive Summary (ISO 24495-1 Plain-Language Overview)

[!IMPORTANT] Legal Precedence Notice: This plain-language summary is provided solely for reader convenience and compliance audit navigation pursuant to ISO 24495-1:2023. It does not constitute binding legal terms, covenants, or warranties. In the event of any ambiguity, conflict, or inconsistency between this summary and the operative articles below, the operative articles strictly govern and control.

• Purpose & Scope: Establishes mandatory ethical standards, statutory compliance rules, and professional conduct expectations for all Auctoric employees, officers, directors, and independent contractors worldwide.
• Anti-Bribery & Corruption Stance: Imposes absolute zero tolerance for bribery, kickbacks, or improper gratuities involving domestic or foreign government officials (FCPA) and private commercial partners (UK Bribery Act).
• Algorithmic Integrity & Safety: Mandates algorithmic honesty—strictly prohibiting benchmark manipulation, concealment of model vulnerabilities, or misrepresentation of safety thresholds.
• Customer Content Confidentiality: Forbids personnel from accessing, viewing, or duplicating customer prompts or completions except under audited emergency break-glass procedures.
• Protected Reporting Channels: Provides secure, anonymous reporting options through ethics@auctoric.ai backed by enforceable anti-retaliation guarantees.

High-Intent Ethics FAQ (AEO Direct Answers)

How does Auctoric enforce anti-bribery and anti-corruption laws?

Auctoric maintains an absolute zero-tolerance policy regarding bribery and improper inducements. Under Section 2.2, personnel are strictly prohibited from offering or receiving gifts, kickbacks, or favors to influence commercial decisions or governmental actions, adhering fully to the FCPA and UK Bribery Act 2010.

What are Auctoric’s standards regarding algorithmic integrity and benchmark transparency?

Under Section 3, Auctoric engineers and researchers must uphold algorithmic honesty: synthetic benchmarks cannot be manipulated, model safety limitations must not be concealed, and systemic vulnerabilities must be escalated immediately without fear of reprisal.

Can Auctoric personnel inspect or access customer prompts and completions?

No. Under Section 4.2, personnel are strictly barred from browsing, accessing, or duplicating Customer Content or prompts. Access is only permissible under audited, least-privilege break-glass protocols to troubleshoot validated platform incidents.

1. Executive Message & Commitment

At Auctoric, LLC (“Auctoric”), our reputation for integrity, technical excellence, and ethical leadership is our most valuable asset. As pioneers in Governed Artificial Intelligence, we operate at the frontier of technology where technical capability must be matched by profound ethical accountability.

This Code of Ethics and Business Conduct (“Code”) outlines the fundamental ethical principles, legal standards, and professional conduct expected from every employee, officer, director, contractor, and representative acting on behalf of Auctoric globally.

2. Core Tenets of Business Conduct

2.1 Compliance with Laws and Regulations

Auctoric operates in full compliance with all applicable laws, rules, and regulations in every jurisdiction where we conduct business. Ignorance of the law is never an acceptable defense.

2.2 Anti-Bribery and Anti-Corruption (FCPA / UK Bribery Act)

• Zero Tolerance: Auctoric strictly prohibits bribery, kickbacks, extortion, or improper inducements of any kind.
• Government Officials: No employee may offer, promise, authorize, or give anything of value directly or indirectly to any government official, candidate, or public agency to obtain or retain business or secure an improper advantage.
• Commercial Bribery: Offering or receiving improper commercial advantages from vendors, suppliers, or customers is strictly prohibited.

2.3 Fair Dealing and Antitrust

Auctoric competes aggressively, ethically, and independently:

• We never enter into agreements with competitors to fix prices, divide markets, allocate customers, or manipulate bidding processes.
• We gather competitive intelligence through lawful, public channels and never through misrepresentation, corporate espionage, or violation of non-disclosure agreements.

2.4 Conflicts of Interest

All personnel must avoid any situation where personal interests conflict, or appear to conflict, with the interests of Auctoric:

• Outside Employment & Board Roles: Holding positions with customers, suppliers, or competitors requires prior written approval from the General Counsel.
• Financial Interests: Employees may not hold significant financial interests in vendors, competitors, or partners without formal disclosure.
• Gifts & Entertainment: Modest business meals and promotional items are permissible; gifts exceeding $100 USD or any cash equivalent are prohibited.

3. Responsible AI Development & Algorithmic Integrity

As an AI organization, our ethical responsibilities extend into our codebases:

1. Algorithmic Honesty: We never manipulate synthetic benchmarks, conceal model limitations, or misrepresent algorithmic performance metrics to clients or auditors.
2. Safety First: If an employee discovers a systemic safety flaw, dangerous vulnerability, or toxic output mode that circumvents platform guardrails, they are obligated to escalate the issue immediately without fear of retaliation.
3. Respect for IP & Creators: We train and fine-tune models respecting intellectual property rights and explicit data licenses.

4. Protection of Company, Customer, and Partner Assets

4.1 Proprietary Information and Trade Secrets

Auctoric proprietary algorithms, source code, neural model weights, strategic roadmaps, and customer lists are confidential company assets. Personnel must safeguard these assets even after leaving Auctoric.

4.2 Customer Content & Confidentiality

Customer trust is paramount. Personnel must never access, inspect, or duplicate Customer Content, prompts, or model completions unless authorized under strict operational break-glass protocols to debug a validated incident.

4.3 Insider Trading

Personnel who possess Material Non-Public Information (MNPI) regarding Auctoric or publicly traded partners/customers may not buy or sell securities, nor may they “tip” others to trade on such information.

5. Workplace Culture, Human Rights, and Inclusivity

• Equal Opportunity: Auctoric provides equal opportunity in employment and prohibits discrimination or harassment based on race, color, religion, sex, sexual orientation, gender identity, national origin, disability, veteran status, or genetic profile.
• Safe & Respectful Workplace: We maintain a zero-tolerance stance against bullying, intimidation, sexual harassment, or verbal/physical abuse.
• Human Rights: We respect international human rights standards across our global operations and supply chains, opposing all forms of forced labor or human trafficking.

6. Financial Integrity and Recordkeeping

• All corporate books, financial statements, timecards, expense reports, and audit logs must accurately, truthfully, and fairly reflect transactions in reasonable detail.
• Creating off-the-books funds, falsifying records, or deliberately circumventing internal accounting controls is strictly prohibited.

7. Governance, Reporting, and Administration

7.1 Seeking Guidance & Reporting Violations

If you witness, suspect, or are asked to participate in any activity that violates this Code or applicable law:

1. Speak with your direct manager or People Business Partner;
2. Contact the Legal & Compliance Office at legal@auctoric.ai;
3. Submit a confidential or anonymous report via our Whistleblower Portal at https://trust.auctoric.ai/whistleblower or ethics@auctoric.ai.

7.2 Non-Retaliation Commitment

Auctoric strictly prohibits retaliation against any individual who reports a known or suspected violation in good faith. See our Whistleblower & Non-Retaliation Policy.

7.3 Disciplinary Action

Violations of this Code will result in formal disciplinary action up to and including termination of employment, forfeiture of equity awards, and civil or criminal prosecution.