Business Ethics Policy

Dive Gear Express LLC is committed to conducting business lawfully, fairly, and with integrity. This policy sets the standards of conduct expected of company personnel and supports compliance with applicable legal, supplier, customer, and marketplace requirements relevant to the company’s ecommerce retail operations.

1. Purpose

Dive Gear Express LLC conducts business based on honesty, lawful conduct, fair dealing, and accountability. This Business Ethics Policy establishes the company’s expectations for ethical business conduct and compliance with applicable laws, regulations, contractual obligations, and marketplace requirements.

This policy is intended to function as Dive Gear Express LLC’s written ethics and compliance statement for its operations as an ecommerce retailer of scuba diving equipment and related products.

2. Scope

This policy applies to all company personnel and to any person or entity acting on behalf of Dive Gear Express LLC in connection with company business. It also informs the company’s expectations for suppliers, service providers, and subcontractors where flow-down obligations, legal requirements, or commercial commitments apply.

3. Core Standards of Conduct

All covered persons are expected to:

• Act honestly, fairly, and in good faith.
• Comply with applicable laws, regulations, platform rules, contract terms, and company policies.
• Avoid conduct that creates actual or apparent impropriety.
• Protect the reputation of the company and its business partners.
• Raise concerns promptly when an issue is identified.

4. Compliance With Laws and Business Requirements

Dive Gear Express LLC will comply with applicable laws and regulations in the jurisdictions where it operates. This includes, as applicable, consumer protection laws, advertising and pricing laws, labor laws, workplace safety laws, environmental requirements, trade compliance rules, tax and recordkeeping obligations, privacy and data-security requirements, and supplier or marketplace requirements. Where a legal, contractual, or platform requirement is more restrictive than this policy, the stricter requirement will govern.

5. Anti-Bribery and Anti-Corruption

Dive Gear Express LLC prohibits bribery, kickbacks, and improper payments in any form. No covered person may offer, promise, give, request, or accept anything of value to improperly influence a business decision, obtain or retain business, secure preferred treatment, or gain an unfair advantage. This prohibition applies whether dealing with suppliers, service providers, logistics partners, commercial customers, public entities, or government officials, and whether acting directly or through an intermediary.

6. Gifts, Meals, Entertainment, and Business Courtesies

Business courtesies must never be used to influence decision-making improperly. Covered persons may not offer or accept gifts, meals, entertainment, favors, discounts, or other benefits that are excessive, frequent, not transparent, inconsistent with law or contract, or likely to create the appearance of impropriety. Modest and customary courtesies may be acceptable only when lawful, reasonable, infrequent, and not intended to influence a purchasing, sourcing, or business decision improperly.

7. Conflicts of Interest

Covered persons must avoid actual, potential, or apparent conflicts of interest. Examples include:

• Financial interests that could affect independent judgment.
• Personal relationships that influence purchasing, vendor selection, pricing, fulfillment, or contracting decisions.
• Outside employment or consulting that conflicts with company duties.
• Use of company opportunities, information, or property for personal gain.

Any known or potential conflict must be disclosed promptly to company management.

8. Accurate Records and Honest Communications

Dive Gear Express LLC will maintain accurate, complete, and timely records. Covered persons must not create false, misleading, incomplete, or off-book records. Invoices, order records, inventory records, shipping records, tax records, return records, certifications, and business communications must accurately reflect the facts. The company also expects truthful and accurate representations to customers, suppliers, service providers, regulators, auditors, and business partners.

9. Product Integrity, Authenticity, and Conformity

Dive Gear Express LLC is committed to selling authentic, conforming products obtained from approved or otherwise validated sources appropriate to the goods involved. The company will take reasonable measures to prevent counterfeit, suspect counterfeit, tampered, substituted, misrepresented, or nonconforming products from being sold or shipped. Nonconforming product must be identified, controlled, and handled appropriately, and known product integrity concerns must not be concealed.

10. Human Rights, Labor Standards, and Anti-Trafficking

Dive Gear Express LLC prohibits human trafficking, forced labor, debt bondage, involuntary labor, child labor, coercion, deceptive recruiting, and the confiscation of identity documents. The company expects lawful employment practices and respectful treatment of workers. Where applicable, the company will require suppliers and service providers to maintain similar standards.

11. Equal Opportunity, Respect, and Professional Conduct

Dive Gear Express LLC is committed to a professional business environment free from unlawful discrimination, harassment, retaliation, and abusive conduct. Employment and business decisions must be based on legitimate, lawful, and job-related considerations.

12. Health, Safety, and Environmental Responsibility

The company will conduct operations in a manner that supports workplace safety and compliance with applicable environmental and safety requirements. Covered persons must follow reasonable safety procedures, report unsafe conditions, and handle, store, package, and ship products in a manner consistent with applicable law and good practice.

13. Trade Compliance

Where applicable, Dive Gear Express LLC will comply with import, export, sanctions, customs, and trade-control laws. Covered persons must not misclassify goods, misstate country of origin, ship to prohibited parties or destinations, or ignore red flags relating to restricted end uses or diversion risk.

14. Confidential Information, Customer Data, and Intellectual Property

Covered persons must protect confidential, proprietary, and non-public information belonging to Dive Gear Express LLC, its customers, and its suppliers. This includes customer account information, order details, pricing information, internal business data, and other sensitive commercial information. Such information may be used only for legitimate business purposes and disclosed only to authorized persons with a need to know.

Nothing in this policy is intended to restrict any rights protected by applicable law, including the right to report possible violations of law to government agencies or, where protected by law, to discuss wages, hours, or other terms and conditions of employment.

15. Fair Competition and Truthful Market Conduct

Dive Gear Express LLC will compete fairly and lawfully. Covered persons must not engage in price-fixing, market allocation, misuse of competitor information, deceptive advertising, false product claims, or misleading statements about availability, performance, origin, or compatibility. The company’s qualifications, inventory, capabilities, policies, and representations to customers must be accurate and supportable.

16. Reporting Concerns and Non-Retaliation

Covered persons are expected to report known or suspected violations of law, this policy, company procedures, or applicable contractual or business requirements. Reports may be made to company management using the contact information published on the company’s website. Dive Gear Express LLC prohibits retaliation against anyone who raises a concern in good faith, asks a compliance question, participates in an investigation, or refuses to engage in conduct the person reasonably believes is unlawful or unethical.

17. Investigations and Corrective Action

The company will review credible concerns promptly and take appropriate action where needed. This may include internal investigation, corrective action, employee discipline, supplier corrective action requests, customer notification where required, refunds or order correction where appropriate, or termination of a business relationship when warranted.

18. Supplier and Service Provider Expectations

Dive Gear Express LLC expects suppliers, service providers, and subcontractors to conduct business ethically and in compliance with applicable law. Where appropriate or required, the company expects such parties to support standards relating to:

• Anti-bribery and anti-corruption compliance.
• Conflict-of-interest disclosure.
• Accurate records and truthful representations.
• Human rights, lawful labor practices, and anti-trafficking controls.
• Product authenticity, traceability, and conformity.
• Compliance with applicable shipping, fulfillment, and product-handling requirements.

19. Training and Awareness

Dive Gear Express LLC will provide reasonable ethics and compliance awareness to relevant personnel based on role, risk, and business requirements. This may include written acknowledgments, training, procedural guidance, policy distribution, or role-specific compliance instructions.

20. Responsibility and Oversight

Company management is responsible for implementing this policy, promoting ethical conduct, responding to concerns, and ensuring that the company’s business practices support lawful and responsible ecommerce retail operations.

21. Contact

Questions regarding this policy may be directed to Dive Gear Express LLC through company management using the contact information published on the company’s website.