HouseKeys Corporate Compliance Policy Statement

HouseKeys is committed to the highest standards of legal and ethical conduct in all areas of our operations. Our compliance framework covers key areas of regulatory and ethical risk, including anti-bribery, anti-money laundering, political contributions, gifts and entertainment, and corporate ethics. This document summarizes our written policies in these areas and aligns with the detailed Conflict of Interest and Gift Policy (July 2025).

(a) Anti-Bribery and Anti-Corruption Policy

HouseKeys maintains a strict zero-tolerance policy toward bribery and corrupt practices. All employees, officers, contractors, and stakeholders must comply with:

  • The U.S. Foreign Corrupt Practices Act (FCPA)

  • The California Political Reform Act

  • Government Code Section 1090 and other applicable laws

Prohibited Activities:

  • Offering or accepting anything of value to influence a public or private decision

  • Providing gifts or incentives to public officials to secure contracts or approvals

  • Participating in any decision-making where there is a personal or financial interest

Enforcement: Violations may result in termination of employment or contracts and referral to authorities.

(b) Anti-Money Laundering (AML) Policy

While HouseKeys is not a financial institution, we recognize the importance of complying with anti-money laundering standards. We prohibit:

  • Accepting funds from anonymous or suspicious sources

  • Processing payments that are inconsistent with program participation or contract terms

  • Failing to report suspicious financial activity by applicants, partners, or stakeholders

Obligations: All employees are responsible for reporting concerns to the Chief Compliance Officer (CCO). We will cooperate fully with law enforcement or regulatory inquiries.

(c) Charitable Contributions, Political Contributions & Lobbying Policy

HouseKeys does not use company funds to make political contributions or support lobbying activities without prior written approval from executive leadership and legal review.

Donation & Campaign Guidelines:

  • Personal political contributions by employees must not imply endorsement by HouseKeys.

  • Any charitable donation involving public partners must avoid creating a perceived conflict of interest.

  • Employees must not use their HouseKeys position to influence government action for personal or political purposes.

Crowdfunding participation by government employees is regulated under our Conflict Policy (Sections 4, 5, and 8), including Form 700 disclosures and recusal obligations from contract decisions.

(d) Gifts, Entertainment, and Expense Policy

HouseKeys prohibits gifts, entertainment, or hospitality that could create a conflict of interest or the appearance of one.

Gifts & Hospitality Rules:

  • Employees may not accept gifts >$50 from applicants, contractors, or vendors.

  • "Thank you" gifts under $50 may be accepted post-decision with CCO disclosure.

  • No gifts or hospitality may be offered to government employees under any circumstances.

  • All entertainment or business-related expenses must be pre-approved and documented.

Violations may result in disqualification from programs, termination of vendor contracts, or disciplinary action.

(e) Code of Ethics and Conduct

HouseKeys maintains a Code of Ethics incorporated into all compliance materials, which includes:

  • Upholding transparency, impartiality, and fairness in decision-making

  • Disclosing conflicts of interest (Sections 2, 3, 4, 9 of the Conflict Policy)

  • Avoiding insider trading or misuse of confidential information (Section 6)

  • Recusal from decisions where a personal interest exists (Sections 4 and 8)

Oversight: The Chief Compliance Officer (CCO) is responsible for compliance and may be supported by legal counsel or the CEO as Interim CCO. Employees and contractors are required to complete compliance acknowledgments and periodic disclosures.

Annual Review and Updates

This compliance statement will be reviewed annually and updated to reflect:

  • Changes in federal, state, or local law

  • Regulatory or agency partner requirements

  • Operational developments that impact conflict risk

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