BLUE GATE GROUP

INTRODUCTION

BLUE GATE GROUP INC. is dedicated to upholding the highest standards of ethics, integrity, and compliance in the United States. This Code of Conduct and Ethics outlines the principles and guidelines that govern the behavior of all employees, executives, contractors, and business partners. The company is committed to full compliance with U.S. laws and regulations, including the Anti-Money Laundering (AML) framework under the Bank Secrecy Act (BSA) and other relevant statutes.

This Code applies to all employees, officers, contractors, vendors, and any individuals or entities representing BLUE GATE GROUP INC.

FUNDAMENTAL PRINCIPLES

• Integrity: Conduct all activities with honesty, fairness, and accountability.

• Transparency: Ensure accuracy and clarity in communications and business operations.

• Regulatory Compliance: Adhere to all U.S. laws, including AML, CFT, and the Foreign Corrupt Practices Act (FCPA).

• Responsibility: Take ownership of duties and act in the best interests of the company and its stakeholders.

• Confidentiality: Protect sensitive information and prevent unauthorized access or disclosure.

• Respect and Inclusion: Promote a diverse and respectful workplace culture.

COMPLIANCE WITH AML AND CFT OBLIGATIONS

• Implement an effective AML program, including customer due diligence (CDD) and enhanced due diligence (EDD).

• Identify, assess, and mitigate the risks of money laundering and terrorist financing.

• Report suspicious activity to the Financial Crimes Enforcement Network (FinCEN) through Suspicious Activity Reports (SARs).

• Conduct regular training programs to educate employees on AML regulations, red flags, and reporting procedures.

• Maintain comprehensive records of transactions, procedures, and compliance activities as required by law.

PROHIBITED CONDUCT

• Participating in or facilitating activities that are illegal, unethical, or non-compliant.

• Forging or misrepresenting information, records, or financial data.

• Accepting or offering bribes, kickbacks, or improper gifts to influence decisions.

• Failing to identify or report suspicious financial activities.

• Sharing or misusing confidential company or client information without proper authorization.

BUSINESS RELATIONSHIPS AND ETHICS

• Conduct due diligence on customers, vendors, and partners to ensure compliance with AML laws and ethical standards.

• Avoid conflicts of interest and promptly disclose any potential or actual conflicts to the compliance team.

• Ensure transparency, traceability, and legality in all financial and business transactions.

RESPONSIBLE USE OF COMPANY RESOURCES

• Utilize company resources, including information systems, responsibly and efficiently.

• Protect company assets against loss, theft, or unauthorized use.

• Adhere to cybersecurity protocols to safeguard proprietary and sensitive information.

REPORTING MECHANISMS AND WHISTLEBLOWER PROTECTION

• BLUE GATE GROUP INC. encourages reporting any conduct that violates this Code, laws, or regulations.

• Establish secure and anonymous channels for reporting concerns, ensuring non-retaliation and confidentiality.

• Investigate all reports promptly and take appropriate corrective actions.

DISCIPLINARY ACTIONS FOR NON-COMPLIANCE

• Violations of this Code or regulatory obligations may result in disciplinary actions, including termination of employment or contracts.

• Serious breaches may be reported to law enforcement or regulatory authorities.

This Code of Conduct and Ethics will be reviewed periodically to ensure alignment with legal developments and best practices. BLUE GATE GROUP INC. remains committed to fostering a culture of ethics, transparency, and compliance in all its operations.