Introduction

1.1 – This Drug, Alcohol and Smoking Policy (the “Policy”) has been approved by the Shareholders (the “Shareholders”) of Blacksync Inc. and is intended to assist all employees, officers, directors, agents and contractors (the “BSNC Representatives”) of Blacksync Inc. and each of its direct and indirect subsidiaries and branches (collectively, the “BSNC”) to maintain the highest standards of ethical conduct in company affairs. This Policy is intended to comply with US and State of Delaware law requirements. The Shareholders have determined that this Policy shall be always in compliance with the anticorruption US and State of Delaware laws.

1.2 – This Policy will supersede any other existing BSNC policies relating to drugs, alcohol, and smoking use or abuse.

Drugs and Alcohol in the Workplace

2.1 – The BSNC’s Policy on drugs and alcohol in the workplace is designed to address the BSNC’s concern for the health and well-being of its employees and to ensure that the BSNC Representatives comply with the federal Drug-Free Workplace Act of 1988. Penalties for violations of this Policy, or violations of the laws regarding controlled substances or alcohol, range from warning to permanent separation from the BSNC depending on the seriousness of the infraction and the degree to which violation of the Policy adversely affects the well-being of the BSNC Representatives or the fulfillment of the BSNC’s business mission.

Application of the Policy

3.1 – The Policy applies to all directors, officers, employees, consultants, and contractors of BSNC. Compliance with this Policy constitutes terms of service for each director, conditions of employment for each officer and employee, and conditions of providing services to BSNC for each consultant and contractor. Each such person agrees to be bound by the provisions of this Policy upon notification of the most recent copy being given to them or upon notification that an updated version has been placed on BSNC’s website for review.

Controlled Substances

4.1 – BSNC Representatives may not consume, manufacture, distribute, dispense, or be under the influence of controlled substances in the workplace, including in vehicles provided by BSNC , at any worksite or location at which BSNC duties are being performed by BSNC Representatives, or as part of any other BSNC activities. Common examples of controlled substances include but are not limited to cocaine, marijuana, and heroin.
BSNC will take disciplinary action against violators, consistent with BSNC Policy, and federal, state, and local laws. Such disciplinary action may include satisfactory participation in a substance abuse treatment, counseling, or education program as a condition of reinstatement or continued employment, suspension, termination of employment, and referral for prosecution.

Reporting Requirements

5.1 – The Drug-Free Workplace Act requires that employers who are engaged in activities funded by federal grants or contracts notify the relevant federal agency of convictions under the criminal drug laws for violations occurring in the workplace. To ensure BSNC’s compliance with this federal law, BSNC Representatives must report any criminal drug statute conviction for a violation occurring in the workplace to their immediate supervisor, department director, dean, vice president, or human resources officer within five days of the conviction. Within ten days of learning of such a conviction of any individual engaged in work under federal grants or contracts, BSNC is required to notify the relevant federal agency. Upon notification of a conviction, supervisors should immediately contact their local human resources office.

Alcoholic Beverages

6.1 – All BSNC Representatives are prohibited from consuming alcohol or being under the influence of alcohol during work hours or in the workplace (except that it will not be a violation of this Policy for an employee to engage in the responsible consumption of alcohol at approved social functions held during work hours or in the workplace, provided that the use of alcohol has been permitted in these circumstances.) Under no circumstances may a BSNC Representative consume or be under the influence of alcohol while operating BSNC vehicles or equipment. The consumption of alcohol will not constitute a mitigating circumstance when it contributes to the violation of BSNC policies.
President, Vice Presidents, CEO, and heads of administrative units have the authority and responsibility to govern the use of alcohol in areas they control, and to require measures to ensure that at events where alcohol will be served only individuals of legal age will have access. Those hosting such events must take reasonable steps to ensure that the acquisition, distribution, and consumption of alcohol otherwise comply with applicable law and BSNC Policy.

No Smoking

7.1 – Smoking is prohibited inside all BSNC buildings or properties. All forms of tobacco use including cigarettes, cigars, e-cigarettes, and smokeless tobacco are prohibited inside all BSNC buildings, offices, properties.

Review of this Policy

8.1 – The Compliance Officer and the Shareholders will review and evaluate this Policy on an annual basis to determine whether it is effective in ensuring compliance by BSNC , its directors, officers, employees, consultants, or contractors with all relevant anti-corruption laws, rules, and regulations.

Acceptance

9.1 – By accepting this Policy, directors, officers, employees, family members, consultants and contractors of BSNC accept BSNC ’s values and standards and are obliged to comply with them during the contractual relationship with BSNC . Any violation of this Policy will thus be deemed as a severe breach of contract which entitles BSNC to withdraw from the contract unless the directors, officers, employees, family members, consultants and contractors manage after being granted a reasonable period of grace to eliminate / resolve the circumstances / issues which led to non-compliance within such period. However, in case of deliberate or repeated non-compliance or in case BSNC’s business and or reputation might be affected by the non- compliance of the directors, officers, employees, family members, consultants and contractors, BSNC is entitled to withdraw from the contract with immediate effect (i.e. without necessity to allow for a period of grace before withdrawal).

Approval and Amendment

10.1 – This Policy was approved and adopted by the Shareholders. BSNC is committed to reviewing and updating its policies and procedures on a continuing basis. This Policy may be revised, changed, or amended at any time by the Shareholders, and amendment to the Policy will be disclosed promptly to directors, officers, employees, family members, consultants and contractors and will be disclosed publicly in accordance with applicable laws.

Publication of the Policy

11.1 – This Policy will be posted on BSNC’s website at www.blacksync.com. For any further information you may need, related to this document, we kindly invite you to write to the Compliance Team.

Reference

Blacksync Inc.
14 Wall Street, 20th Floor
Manhattan, New York
NY 10005, United States
Registration no. DE-3221551
Last Update: February 28, 2025