Corporate Compliance & Ethics Policy

Integrity in everything we do. Care in every relationship.

1. Our Commitment

CMR Global Mobility Services Inc. supports individuals, families and organizations at important moments of their lives and businesses. That trust depends on how we act, not only on what we deliver.

We are committed to conducting our business honestly, fairly and in compliance with the laws of every jurisdiction in which we operate, and to treating every client, supplier, colleague and community with respect.

This policy sets out the standards of conduct expected from everyone who works for or on behalf of the company.

2. Scope

This policy applies to management, employees, and authorized representatives of CMR Global Mobility Services Inc. We also expect suppliers, contractors, property partners and other third parties acting on our behalf to follow equivalent standards.

It applies to all our activities, including relocation and destination services, housing and property management, immigration documentation support coordinated with licensed professionals, and corporate reporting.

3. Compliance with Laws

We comply with the laws and regulations that apply to our activities, including, where applicable:

• The laws of Guyana, including the Local Content Act 2021 and the Anti-Money Laundering and Countering the Financing of Terrorism Act 2009.
• Brazil’s Clean Company Act (Law No. 12,846/2013), given our operations and history in Brazil.
• International anti-corruption standards required by our clients, such as the U.S. Foreign Corrupt Practices Act and the UK Bribery Act 2010, where they apply through our contracts or client requirements.

Where local practice differs from the law or from this policy, the higher standard applies.

4. Anti-Bribery and Anti-Corruption

We do not offer, promise, give, request or accept bribes, kickbacks or any improper advantage, directly or through third parties, to obtain or retain business or influence a decision.

This applies to dealings with public officials and with private parties alike. We do not make facilitation payments to speed up routine government actions, including immigration, permit or registration processes.

Any request for an improper payment must be refused and reported to management.

5. Gifts, Hospitality and Entertainment

Modest gifts and hospitality can be part of normal business courtesy. They must be:

• Reasonable in value and infrequent.
• Given or received openly, never in cash or cash equivalents.
• Never offered or accepted in exchange for a business decision, or during a tender or negotiation.
• Consistent with the client’s own policies, which may be stricter than ours.

Gifts or hospitality above USD 100 in value, or that could appear improper, must be approved in advance by management and recorded.

6. Conflicts of Interest

Employees must avoid situations where personal, financial or family interests conflict, or appear to conflict, with the interests of the company or its clients.

Examples include holding an interest in a property offered to a client, accepting any payment or benefit from landlords, agents or suppliers, or recommending a provider connected to a relative.

Potential conflicts must be disclosed to management promptly so they can be assessed and managed.

7. Fair Dealing with Clients, Landlords and Suppliers

• We present properties, services and prices honestly and do not mislead clients, assignees or property owners.
• We select suppliers and property partners on merit, quality, compliance and value.
• We do not accept commissions, referral fees or any other payment from landlords, real estate agents or suppliers. Our recommendations are made solely in the interest of our clients and the people they relocate.
• We respect fair competition and do not agree with competitors on prices, clients or markets.

8. Local Content and Community

As a Guyanese company with a local team, we support the objectives of Guyana’s Local Content framework. We aim to work with qualified Guyanese professionals, suppliers and property owners, and to represent our local content status accurately to clients and authorities.

9. Anti-Money Laundering and Financial Integrity

We handle rent, deposits and other client funds only for authorized purposes, with accurate records. We take reasonable steps to know who we are dealing with and do not accept or transfer funds where we suspect an illegal origin or purpose.

All books, records, invoices and reports must be complete, accurate and supported by documentation.

10. Human Rights, Fair Work and Respect

We treat everyone with dignity and respect. We do not tolerate discrimination, harassment, bullying or retaliation on the basis of race, ethnicity, nationality, religion, gender, sexual orientation, disability, age or any other characteristic protected by law.

We do not accept forced labour, child labour or human trafficking in our operations or supply chain, and we expect suppliers to meet the same standard.

11. Health, Safety and Wellbeing

We care for the safety of our employees, the families we support and the people who work in the homes we manage. Health and safety concerns about properties, transport or services must be reported and addressed promptly.

12. Confidentiality and Data Protection

Personal and corporate information is handled according to our Global Data Protection & Information Security Policy (DP-001).

13. Political Activity and Donations

The company does not make political contributions. Charitable donations or sponsorships must be legitimate, transparent and approved by management, and must never be used to obtain an improper advantage.

14. Third Parties

Third parties acting on our behalf, such as contractors, property agents and service providers, are expected to follow standards consistent with this policy. Where appropriate, we assess their integrity before engagement and include ethical and compliance obligations in our agreements.

15. Raising Concerns

Anyone who believes this policy or the law may have been breached is encouraged to raise the concern with management or by writing to info@cmrmobility.gy.

Concerns are handled confidentially to the extent possible. We do not tolerate retaliation against anyone who raises a concern in good faith.

16. Consequences of Violations

Violations of this policy may result in disciplinary action, up to and including termination of employment or of a business relationship, and may be reported to the competent authorities where required by law.

17. Training and Awareness

Employees receive this policy when they join and are reminded of its standards periodically. Management is available to answer questions about how the policy applies in practice.

18. Governance and Review

Management oversees this policy and its implementation. The policy is reviewed at least annually and whenever legal, contractual or operational changes require it.

19. Contact

CMR Global Mobility Services Inc.
Georgetown, Guyana
Email: info@cmrmobility.gy
Website: www.cmrmobility.com

Our Commitment to Integrity

We believe responsible relocation is built on trust. Acting with integrity in every decision, and with care in every relationship, is how we earn that trust every day.

Our business is relocation. What we do best is care for people.

© 2026 CMR Global Mobility Services Inc. All rights reserved.