Code of Ethics

1.Purpose of This Code

1.1 McCray Global Protection Corp. ("McCray") provides security services that depend on trust. Clients rely on McCray to protect their people, property and reputation, and the public relies on McCray personnel to act lawfully and with restraint. This Code of Ethics states the principles that guide how McCray conducts its business.

1.2 This Code applies to McCray's officers, supervisors, managers, office personnel and leadership (together, "McCray personnel").

1.3 This Code is a statement of principles. It does not address every situation McCray personnel may face. The Employee Handbook, McCray's written policies and post orders contain the detailed requirements that apply to McCray personnel, and they control where they give more specific direction.

1.4 This Code is not a contract. It does not create a contract of employment or a guarantee of employment, and it does not change the at-will nature of employment with McCray. It does not create rights for any client, employee or other person.

2.Integrity and Honest Dealing

2.1 McCray personnel are expected to deal honestly and fairly with clients, colleagues, vendors, regulators and the public.

2.2 Reports, logs, timesheets and other business records must be accurate, complete and truthful, and must reflect what the author personally observed or did.

2.3 McCray personnel may not misrepresent McCray's services, licenses, qualifications or capabilities, or present themselves as law enforcement.

2.4 McCray property, systems, uniforms, identification and equipment are to be used only for authorized business purposes.

3.Compliance with Laws and Licensing

3.1 McCray expects its business to be conducted in compliance with applicable laws and regulations, including those governing private security licensing, employment, wages and hours, workplace safety and privacy.

3.2 McCray personnel are expected to obtain and keep current the licenses, registrations and training their roles require, and to follow the rules of the regulators that oversee private security.

4.Use of Force and Public Interaction

4.1 McCray officers receive training that includes de-escalation, and they are expected to resolve situations through communication wherever possible.

4.2 Officers use force only as permitted by law, licensing rules and post orders.

4.3 Officers are expected to treat members of the public with courtesy and respect and to act within the scope of their assignment as defined by post orders and applicable law.

5.Respect and Equal Opportunity

5.1 McCray prohibits discrimination and harassment based on any characteristic protected by law.

5.2 McCray does not honor requests to assign, exclude or remove personnel based on a characteristic protected by law.

5.3 Officers are expected to treat every person on a client's premises without bias. Decisions about whom to observe or approach must be based on conduct, not on a characteristic protected by law.

6.Confidentiality and Privacy

6.1 McCray personnel are expected to protect confidential information belonging to McCray and its clients, including security plans, post orders, client and customer information and personal information, and to use it only for authorized business purposes.

6.2 McCray personnel may not record, photograph or share information about client sites, clients, customers or colleagues except as authorized by McCray or required by law.

6.3 Only personnel authorized by McCray may speak to the media or make public statements on McCray's behalf. McCray personnel may not post confidential client, site or security information on social media or other public forums.

7.Conflicts of Interest, Gifts and Gratuities

7.1 McCray personnel are expected to avoid situations in which personal interests conflict, or appear to conflict, with the interests of McCray or its clients, and to disclose potential conflicts to management.

7.2 McCray personnel may not accept gifts, gratuities, discounts or favors from clients, customers or vendors that could influence, or appear to influence, their judgment, except as permitted by McCray policy.

8.Anti-Corruption and Fair Competition

8.1 McCray prohibits offering, paying, soliciting or accepting bribes, kickbacks or other improper payments, whether involving public officials or private parties, in connection with its business.

8.2 McCray competes on the quality of its services and does not seek business through improper means, including the misuse of another company's confidential information.

9.Fair Treatment and Safety of Personnel

9.1 McCray is committed to fair employment practices, including accurate timekeeping and the payment of wages in accordance with applicable law.

9.2 McCray personnel are expected to follow safety rules, to report to work fit for duty and not impaired by alcohol, drugs or any other substance, and to report unsafe conditions and injuries promptly.

9.3 McCray respects human rights in its operations. McCray prohibits human trafficking, forced or compulsory labor and child labor, and expects the vendors it works with to uphold the same standards.

10.Reporting Concerns

10.1 Anyone, including McCray personnel, clients, vendors and members of the public, may report a concern about a possible violation of law, this Code or McCray policy by email to ethics@mccraygp.com.

10.2 Reports sent to ethics@mccraygp.com are received by a limited group designated by McCray's leadership. McCray handles reports with discretion and shares information only as needed to review the concern, take appropriate action, comply with law or respond to legal process.

10.3 McCray personnel may also raise concerns through the reporting procedures in the Employee Handbook, including with a supervisor or Human Resources.

10.4 McCray reviews the concerns it receives and determines the appropriate follow-up. The nature and timing of any review depend on the circumstances.

10.5 A situation involving an immediate threat to life or safety should be reported first to 911 or local emergency services, and then to the McCray Operations Desk at (833) 832-6647.

10.6 McCray personnel are expected to cooperate with internal reviews and to respond truthfully to lawful requests from regulators and law enforcement.

11.Non-Retaliation

11.1 McCray prohibits retaliation against anyone who raises a concern in good faith or participates in a review or investigation. A concern is raised in good faith when the person reasonably believes the information is accurate, even if it later proves to be mistaken.

11.2 A report the person knows to be false is not made in good faith and may result in corrective action.

12.Protected Rights

12.1 Nothing in this Code limits any right protected by law, including the right to discuss wages, hours and other terms and conditions of employment, to file a charge or complaint with a government agency, to communicate with a government agency, or to take part in a government investigation or proceeding.

13.Accountability

13.1 Conduct that violates this Code or McCray policy may result in corrective action, up to and including termination of employment, consistent with McCray policy and applicable law. Nothing in this Section changes the at-will nature of employment with McCray.

14.Changes to This Code

14.1 McCray may update this Code from time to time. The updated Code will be posted on this page with a revised date.

15.Questions

15.1 Questions about this Code may be directed to ethics@mccraygp.com.