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OTC Meme Corp.

🌟 INTRODUCTION

OTC Meme Corp. ("OTC Meme" or the "Company") is a Florida corporation operating a blockchain-based platform that enables the tokenization of OTC micro-cap securities as meme tokens on the Solana blockchain.

📊 Our Commitment

We publish regular updates and reports, available on our website, containing information regarding:

  • 🔧 Our operations
  • 📜 Internal policies
  • 🎯 Business practices

🌍 Scope of Application

This Corporate Code of Conduct applies to:

  • 🏢 The Company and any subsidiaries
  • 👥 All personnel working in the United States
  • 🌐 All personnel in foreign countries

This Code supplements, emphasizes, and clarifies certain aspects of the Company's internal policies.

1. ⚖️ OBEYING THE LAW

Obeying the law, both in letter and spirit, is the foundation on which OTC Meme's ethical standards are built.

🎯 Our Expectations

The Company expects its personnel to maintain the highest ethical standards of business conduct and comply with:

📊 All applicable securities laws and regulations
🚫 Anti-bribery and corruption laws (including US FCPA)
💰 Anti-money laundering (AML) and counter-terrorist financing laws
⛓️ Cryptocurrency and blockchain regulations
🔒 Data privacy and protection laws

💡 Getting Help

Although personnel are not expected to know the details of each law, we encourage seeking advice from:

  • 👨‍💼 Supervisors and managers
  • ⚖️ Legal Department
  • 🤝 Other appropriate persons when questions arise

2. 📋 REGULATORY COMPLIANCE

2.1 📈 Securities Compliance

OTC Meme operates in the highly regulated securities and cryptocurrency markets.

We maintain strict compliance with:

  • 📊 Securities Act of 1933 and Securities Exchange Act of 1934
  • 🏛️ State securities laws ("Blue Sky" laws)
  • 📜 Regulation D and other exemptions we may rely upon
  • 🏦 Transfer agent regulations (Empire Stock Transfer Inc. partnership)

2.2 ⛓️ Blockchain and Cryptocurrency Compliance

As a platform operating on the Solana blockchain, we adhere to:

// Compliance Framework:
🏛️ FinCEN guidance on virtual currency businesses
📋 State money transmitter laws (where applicable)
💰 IRS cryptocurrency reporting requirements
🌍 International crypto regulations in our operating jurisdictions

2.3 🛡️ Cybersecurity

Given our blockchain-based platform and custody of digital assets, we maintain strict cybersecurity policies:

  • 🔍 Regular security audits of smart contracts
  • 🔐 Multi-signature wallet controls
  • 🚨 Incident response procedures
  • 🛡️ Regular penetration testing

3. 🤫 CONFIDENTIAL INFORMATION AND INSIDER TRADING

We treat all non-public information about the Company, partner companies, tokenized securities, and business operations as confidential information.

❌ PROHIBITED ACTIVITIES

Personnel with access to confidential information are NOT permitted to:

❌ Use information for personal trading in tokens or securities
❌ Share information with others who might trade on it ("tipping")
❌ Discuss confidential matters in public places or social media
❌ Retain confidential information after leaving the Company

🔒 Protected Information Includes:

  • 🪙 Upcoming tokenizations
  • 📊 Trading volumes and platform metrics
  • 🤝 Partnership negotiations
  • 🔧 Technical developments or vulnerabilities
  • 👥 Customer information and trading patterns

Personnel owe a duty to the Company to advance the Company's interests whenever possible. Using non-public information for personal financial benefit is:

  • ❌ Unethical
  • ⚖️ Illegal
  • 📜 Violates OTC Meme's policies

4. ⚖️ FAIR COMPETITION AND MARKET INTEGRITY

🎯 OTC Meme is committed to:

  • 🏆 Open competition and fair dealing with clients, partners, and competitors
  • 🔍 Transparent market operations without manipulation
  • ✅ Accurate representation of our services and capabilities
  • 📢 Ethical marketing practices

👥 Personnel are expected to:

  • ⚖️ Conduct business in full compliance with all applicable competition laws
  • 🚫 Not engage in any anti-competitive behavior
  • 📊 Avoid market manipulation or wash trading
  • 🚨 Report any suspicious trading activities
  • 🔧 Maintain integrity of our bonding curve and liquidity pool mechanisms

5. 🔒 DATA PRIVACY AND PROTECTION

OTC Meme is committed to complying with all applicable data privacy laws.

📋 Regulatory Compliance:

🇪🇺 General Data Protection Regulation (GDPR) for European users
🇺🇸 California Consumer Privacy Act (CCPA)
🌍 Other state and international privacy regulations

👥 Personnel Must:

  • 🔐 Handle customer data with utmost care and confidentiality
  • 📅 Follow data retention and deletion policies
  • 🚨 Report data breaches immediately
  • 📚 Complete required privacy training

📖 For more information: Company Privacy Policy

6. 💰 FINANCIAL INTEGRITY AND RESPONSIBILITY

Financial integrity and fiscal responsibility are core values of OTC Meme.

👥 All Company Team Members Are Responsible For:

  • 💸 Ensuring Company funds are appropriately spent
  • 📊 Maintaining complete and accurate financial records
  • ✅ Following internal controls and approval processes
  • 🔐 Protecting Company assets, including cryptocurrency holdings
  • 🚨 Reporting any suspected fraud or financial irregularities

🛡️ Internal Controls System:

📊 GAAP-compliant accounting practices
🔍 Regular third-party audits
📈 Transparent financial reporting
🏦 Segregation of customer and Company assets

7. ⚠️ CONFLICTS OF INTEREST

All Company personnel have an obligation to always do what is best for the Company and its users.

🚨 Potential Conflicts Include:

  • 💰 Personal investments in companies seeking tokenization
  • 🏢 Financial interests in competing platforms
  • 💼 Outside business activities interfering with job duties
  • 🎁 Accepting gifts/entertainment from vendors beyond nominal value
  • 👨‍👩‍👧‍👦 Family members working for competitors or partners
  • 📈 Personal trading in tokens listed on our platform

✅ Personnel Must:

📢 Disclose any potential conflicts to supervisor/Legal Department
🚫 Recuse themselves from decisions where conflicts exist
✋ Obtain approval before engaging in outside business activities
📋 Follow the Company's gift and entertainment policy

8. 🚫 ANTI-CORRUPTION AND SANCTIONS

8.1 💰 Anti-Bribery

OTC Meme prohibits ALL forms of bribery and corruption.

❌ Personnel May NOT:

  • 💵 Offer, promise, or give bribes to any person
  • 🤝 Request or accept bribes from any person
  • 💸 Make facilitation payments
  • 👥 Use third parties to engage in prohibited conduct

8.2 🌍 International Trade and Sanctions

We maintain policies regarding compliance with economic sanctions imposed by:

  • 🇺🇸 United States
  • 🌍 Foreign governments
  • 🏛️ United Nations

✅ Personnel Must:

🔍 Screen all users against sanctions lists
🚫 Block access from sanctioned jurisdictions
🚨 Report any suspected sanctions violations
📚 Complete required sanctions training

9. 🏢 WORKPLACE POLICIES

9.1 🏥 Health and Safety

OTC Meme strives to provide personnel with a workplace that is safe and healthy.

📋 All Company Locations Must Comply With:

  • 🏭 Occupational Safety and Health Administration (OSHA) requirements
  • 🏛️ Local health and safety regulations
  • 📜 Company safety policies and procedures

👥 Personnel Are Responsible For:

✅ Maintaining safe work practices
🚨 Reporting safety hazards immediately
🚪 Following emergency procedures
📚 Completing required safety training

9.2 🤝 Equal Opportunity Employment

OTC Meme is an equal opportunity employer. Employment decisions are based solely on merit, qualifications, and abilities.

🚫 OTC Meme Does NOT Discriminate Based On:

  • 🎨 Race, color, or national origin
  • ⛪ Religion or creed
  • 👫 Gender, gender identity, or gender expression
  • 🏳️‍🌈 Sexual orientation
  • 📅 Age
  • ♿ Disability (physical or mental)
  • 🎖️ Military or veteran status
  • 🧬 Genetic information
  • 🤱 Pregnancy, childbirth, or related medical conditions
  • ⚖️ Any other characteristic protected by law

9.3 🚫 Anti-Harassment

We are committed to maintaining a workplace free from all forms of harassment, including sexual harassment.

❌ OTC Meme Will NOT Tolerate:

🚫 Unwelcome sexual advances or requests
🗣️ Verbal or physical harassment
😤 Hostile work environment
⚖️ Retaliation against those who report harassment

✅ All Personnel Are Required To:

  • 🤝 Treat colleagues with respect and professionalism
  • 🚨 Report harassment immediately
  • 🔍 Cooperate with investigations
  • 📚 Complete required training

10. ⛓️ MODERN SLAVERY AND HUMAN TRAFFICKING

OTC Meme is committed to ensuring that modern slavery and human trafficking are NOT taking place in our business or supply chain.

🛡️ We Will:

  • 🔍 Conduct due diligence on suppliers and partners
  • 📜 Include anti-slavery provisions in contracts
  • 🎓 Train personnel on recognizing signs of modern slavery
  • 🚨 Report any suspected instances to authorities

11. 📢 REPORTING VIOLATIONS

11.1 📋 Reporting Obligation

All personnel have an obligation to report:

  • ❌ Violations of this Code of Conduct
  • ⚖️ Violations of law or regulation
  • 🚫 Unethical business conduct
  • 💰 Concerns about accounting or auditing matters

11.2 📞 Reporting Channels

Reports can be made to:

👨‍💼 Your immediate supervisor
👥 Human Resources Department
⚖️ Legal Department
📞 Anonymous ethics hotline: [To be established]

11.3 🛡️ No Retaliation

OTC Meme prohibits retaliation against anyone who:

  • ✅ Makes a good faith report of violations
  • 🔍 Participates in investigations
  • 🚫 Refuses to participate in wrongdoing

12. ⚠️ CONSEQUENCES OF VIOLATIONS

Violations of this Code of Conduct may result in:

📢 Verbal or written warnings
📋 Performance improvement plans
⏸️ Suspension with or without pay
❌ Termination of employment
⚖️ Legal action
👮‍♂️ Referral to law enforcement

13. ✅ ACKNOWLEDGMENT AND CERTIFICATION

All personnel must:

  • 📖 Read and understand this Code of Conduct
  • ✍️ Acknowledge receipt and understanding annually
  • ✅ Certify compliance with all provisions
  • 🎓 Complete required training

14. 📝 AMENDMENTS

This Code of Conduct may be amended at any time by the Company's Board of Directors.

All amendments will be:

  • 📢 Communicated to personnel
  • 🌐 Posted on the Company website

15. 📞 CONTACT INFORMATION

For questions about this Code of Conduct:

⚖️ Legal Department
🏢 OTC Meme Corp.
📍 240 Vaughn Dr, Ste 8
   Alpharetta, GA 30009

📧 Email: legal@otc.meme
📞 Phone: 1-404-734-3277

📅 FINAL ACKNOWLEDGMENT

Last Updated: August 4, 2025

By working at OTC Meme Corp., you acknowledge that you have:

  • ✅ Read this Corporate Code of Conduct
  • 🧠 Understood all provisions and requirements
  • 🤝 Agreed to comply with this Corporate Code of Conduct

💼 Professional Excellence Through Ethical Conduct - Your commitment to these standards helps build trust in our platform and protects our community of users and stakeholders.

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