Code of Conduct & Ethics Policy¶

Document ID: AUL-POL-06 Version: 1.0 Classification: Internal Owner: Chief Executive Officer Effective: TBD-YYYY-MM-DD Next Review: TBD-YYYY-MM-DD

1. Purpose¶

This policy establishes the ethical standards and professional conduct expectations for all Aulendur Labs personnel. As a defense contractor handling CUI under DTRA SBIR Phase I (MJOLNuR) and a participant in the Werner Exchange Accelerator and Techstars Founder Catalyst, Aulendur must maintain the highest standards of integrity, compliance, and ethical behavior to preserve trust with government customers, commercial partners, and investors.

2. Scope¶

This policy applies to:

Personnel: All employees, contractors, interns, advisors, board members, and any individual acting on behalf of Aulendur Labs.
Activities: All business activities conducted for or on behalf of Aulendur Labs, including interactions with government agencies, prime contractors, subcontractors, commercial customers, investors, and the public.
Locations: All work locations, including Omaha headquarters, remote sites, conferences, and customer facilities.

3. Roles & Responsibilities¶

Role	Responsibility
Chief Executive Officer (CEO)	Owns this policy; serves as the ethics authority; receives and adjudicates ethics complaints.
Chief Technology Officer (CTO) / ISSM	Enforces security-related ethical obligations; reports security ethics violations to the CEO.
All Personnel	Read, acknowledge, and comply with this policy; report suspected violations.

4. Policy Statements¶

4.1 Integrity and Honesty¶

4.1.1 All personnel shall conduct Aulendur business with honesty and integrity. Misrepresentation of capabilities, qualifications, costs, or technical performance to any customer, partner, government agency, or investor is prohibited.

4.1.2 All personnel shall accurately record time, expenses, and deliverable status. Falsification of records, including timesheets, progress reports, and contract deliverables, is prohibited and may constitute fraud under federal law (18 USC 1001).

4.1.3 All personnel shall comply with applicable federal, state, and local laws, as well as the terms of Aulendur's government contracts and commercial agreements.

4.2 Conflicts of Interest¶

4.2.1 All personnel shall disclose to the CEO any personal, financial, or professional relationship that could create, or appear to create, a conflict of interest with their Aulendur duties. Disclosures shall be made in writing within 10 business days of the conflict arising.

4.2.2 Personnel shall not use Aulendur resources, information, or relationships for personal financial gain outside the scope of their employment or engagement.

4.2.3 Personnel shall not accept gifts, hospitality, or entertainment from vendors, contractors, or government personnel that could influence, or appear to influence, business decisions. Gifts exceeding $25 in value shall be reported to the CEO.

4.3 Government Contracting Ethics¶

4.3.1 Aulendur Labs shall comply with the Procurement Integrity Act (41 USC 2101-2107). Personnel shall not solicit or obtain proprietary or source selection information from government officials.

4.3.2 Personnel shall not engage in bribery, kickbacks, or improper payments to government officials, prime contractors, or subcontractors. Such conduct violates the Anti-Kickback Act (41 USC 8702) and the False Claims Act (31 USC 3729).

4.3.3 Personnel shall not engage in bid rigging, price fixing, or collusive practices with competitors.

4.3.4 Personnel involved in government contract performance shall comply with Organizational Conflict of Interest (OCI) requirements per FAR Subpart 9.5 and shall report potential OCIs to the CEO immediately.

4.4 Protection of Information¶

4.4.1 All personnel shall protect Aulendur proprietary information, trade secrets, customer data, and government information (including CUI and ITAR-controlled data) per the Information Classification & Handling Policy.

4.4.2 Personnel shall not disclose Confidential, CUI, or ITAR-controlled information to unauthorized individuals, including family members, former colleagues, or the media.

4.4.3 Personnel who leave Aulendur shall return all Aulendur information and shall not retain copies of proprietary, Confidential, CUI, or ITAR-controlled data.

4.5 Respect and Non-Discrimination¶

4.5.1 All personnel shall treat colleagues, customers, partners, and the public with respect and professionalism.

4.5.2 Aulendur Labs prohibits discrimination, harassment, and retaliation based on race, color, religion, sex, sexual orientation, gender identity, national origin, disability, veteran status, age, or any other characteristic protected by law.

4.5.3 Aulendur Labs shall comply with Executive Order 11246 (Equal Employment Opportunity) and Section 503 of the Rehabilitation Act as applicable to its federal contracts.

4.6 Responsible Use of AI and Technology¶

4.6.1 Personnel developing or deploying DeepLoom, WeaveCast, or other AI/ML systems shall consider the ethical implications of their work, including potential for bias, misuse, and unintended consequences. Concerns shall be raised to the CTO/ISSM.

4.6.2 Personnel shall not use Aulendur AI systems or technical capabilities for purposes that violate law, contract terms, or this policy.

4.7 Reporting Violations¶

4.7.1 All personnel shall report suspected violations of this policy, applicable laws, or contract requirements to the CEO or CTO/ISSM. Reports may be made verbally, in writing, or via the Whistleblower & Reporting Policy (forthcoming).

4.7.2 Aulendur Labs prohibits retaliation against any individual who, in good faith, reports a suspected violation. Retaliation itself constitutes a violation of this policy and may violate federal whistleblower protection statutes (10 USC 4701 for contractor employees on DoD contracts).

4.7.3 The CEO shall investigate all reported violations promptly and document findings and corrective actions.

4.8 Acknowledgment¶

4.8.1 All personnel shall acknowledge this policy in writing (electronic signature accepted) within 10 business days of hire or engagement and annually thereafter. Acknowledgments shall be retained in personnel files.

5. Standards & Procedures Referenced¶

The following companion documents implement this policy:

Information Security Policy
Information Classification & Handling Policy
Acceptable Use Policy
Whistleblower & Reporting Policy (forthcoming)
Insider Threat Program Policy (forthcoming)

6. Compliance & Enforcement¶

Violations of this policy may result in disciplinary action up to and including termination of employment or contract, civil penalties, and criminal prosecution where applicable. Violations involving government contracting ethics may be reportable to the cognizant Inspector General and may result in suspension or debarment.

7. Exceptions¶

No exceptions to ethical conduct requirements are permitted. Procedural exceptions to this policy require CEO written approval and documentation in the Exception Register.

8. Definitions¶

Term	Definition
Conflict of Interest	A situation in which a person's private interests could improperly influence, or appear to influence, their professional judgment or actions on behalf of Aulendur.
OCI	Organizational Conflict of Interest — a situation where a contractor's objectivity, or ability to perform, may be impaired due to other activities or relationships.
Procurement Integrity Act	41 USC 2101-2107, prohibiting improper solicitation or disclosure of proprietary or source selection information.
CUI	Controlled Unclassified Information, per 32 CFR Part 2002.
Retaliation	Adverse action taken against an individual for reporting a violation in good faith.

9. References¶

41 USC 2101-2107, Procurement Integrity Act
41 USC 8702, Anti-Kickback Act
31 USC 3729, False Claims Act
18 USC 1001, Statements or Entries Generally (false statements to government)
10 USC 4701, Contractor Employees: Protection from Reprisal
FAR Subpart 9.5, Organizational and Consultant Conflicts of Interest
Executive Order 11246, Equal Employment Opportunity
NIST SP 800-171 Rev. 3, Protecting Controlled Unclassified Information in Nonfederal Systems and Organizations

10. Control Mappings¶

Framework	Control ID	Control Title	Coverage
NIST SP 800-53 R5	PL-4	Rules of Behavior	Supports — primary coverage in AUL-POL-05
NIST SP 800-53 R5	PS-6	Access Agreements	Supports — acknowledgment requirement
NIST SP 800-53 R5	PM-12	Insider Threat Program	Supports — ethical reporting channel

11. Revision History¶

Version	Date	Author	Changes
1.0	TBD-YYYY-MM-DD	J. Gershenson	Initial issue.