Code of Business Conduct & Ethics

1. Compliance with Law

ATX Global Ventures, LLC and all persons acting on its behalf must comply with applicable federal, state, and local laws and regulations in all business activities. This includes, without limitation, procurement integrity laws, the False Claims Act, anti-kickback statutes, FCPA where applicable, export control regulations, and all applicable provisions of the Federal Acquisition Regulation (FAR).

When in doubt about whether a course of action complies with applicable law, employees and agents must consult with management before proceeding.

2. Gifts, Entertainment & Anti-Corruption

No employee, agent, or representative of ATX Global Ventures may offer, give, solicit, or receive any gift, gratuity, or payment of value — including meals, entertainment, travel, or any other item — in connection with any government procurement, vendor relationship, or business transaction that could reasonably be construed as an attempt to influence a business decision improperly.

All gifts and entertainment must comply with applicable law and be consistent with normal business courtesy, not intended to create an obligation or improper influence. Government officials are subject to separate, stricter standards under federal and state ethics laws.

3. Conflicts of Interest

All personnel must avoid situations in which personal interests conflict, or appear to conflict, with the interests of ATX Global Ventures or its clients. Actual or potential conflicts of interest must be promptly disclosed to management. Examples include:

Financial interests in a vendor, supplier, or competitor
Outside employment or consulting relationships affecting objectivity
Family or personal relationships that influence business decisions
Receipt of outside compensation related to ATX business activities

This section is specific to ATX Global Ventures' unique position as a separately owned company with family relationships to other government-contracting entities.

ATX Global Ventures is independently owned and managed. Its principals have family and, at times, commercial relationships with other companies, including Lyfe Global Solutions. The companies are separately owned, separately led, and operate independently.

We disclose related-party relationships in procurement submissions wherever required by law, regulation, or the terms of the solicitation. We do not submit bids or proposals on the same solicitation as a related company except with full disclosure to the buyer and where expressly permitted by the applicable procurement rules.

Any question about related-party bidding — including whether a teaming arrangement, subcontract relationship, or dual submission triggers disclosure requirements — is escalated to our compliance contact and, where needed, outside procurement counsel before any submission is made.

Under SBA regulations, affiliation between companies (including through family relationships, shared facilities, financing arrangements, or economic dependence) may affect size status determinations. We confirm size-status questions with qualified counsel before certifying small-business status on any solicitation.

5. Confidentiality

All personnel must protect confidential information — including client data, bid strategies, pricing, vendor relationships, and proprietary business information — from unauthorized disclosure during and after their engagement with ATX Global Ventures. Confidential information may be used only for authorized business purposes.

6. Accurate Representations & Record Integrity

All bid submissions, certifications, invoices, capacity statements, and business records must be accurate, complete, and not misleading. No employee or agent may:

Make false statements to any government agency, contracting officer, or prime contractor
Certify compliance with requirements known to be unmet
Submit capacity figures, certification claims, or past-performance references that are not current and verifiable
Alter, falsify, or destroy business records in violation of applicable record-retention requirements

7. Reporting Violations

Any employee, agent, or business partner who becomes aware of a potential violation of this Code, applicable law, or company policy is encouraged — and in some cases required — to report the concern promptly. Reports may be made to:

Email: compliance@atxglobalventures.com
Mail: ATX Global Ventures, LLC, 1108 Lavaca St, Suite 110-283, Austin, TX 78701

All reports will be reviewed promptly and handled with appropriate confidentiality.

8. Non-Retaliation

ATX Global Ventures prohibits retaliation against any individual who makes a good-faith report of a suspected violation or who cooperates in any investigation of a reported concern. Any confirmed retaliation will itself constitute a serious violation of this Code and will result in disciplinary action.