Ethics & Compliance Framework

Corporate Code of Business Conduct, Regulatory Governance, and Whistleblower Reporting

Entity #: B20260362544
FEIN/Tax ID: 42-4394264
CA DGS Cert: #2054365 (SB-Micro/DVBE)
SBA Status: Certified VOSB
SAM.gov UEI: N1AXS955R5Q5
CAGE Code: 24PR9

1. Executive Declaration & Purpose

CMKRL LLC is committed to maintaining the highest standards of integrity, transparency, and ethical conduct in all business operations, public sector procurements, and technology consulting engagements. This Code of Business Conduct and Ethics applies to all owners, officers, employees, contractors, and partners acting on behalf of CMKRL LLC.

2. Anti-Bribery, Anti-Corruption & FCPA Compliance

CMKRL LLC strictly prohibits bribery, kickbacks, improper gifts, or illicit payments of any kind to public officials, commercial partners, or third parties. CMKRL LLC fully complies with the U.S. Foreign Corrupt Practices Act (FCPA), the UK Bribery Act, California Government Code Section 1090, and all federal, state, and local anti-corruption statutes. No employee or partner may offer, promise, or give anything of value to influence an official action or obtain an improper business advantage.

3. Government Contracting Ethics & Conflicts of Interest

As a certified California Micro-Small Business (SB-Micro), Disabled Veteran Business Enterprise (DVBE), and SBA Certified Veteran-Owned Small Business (VOSB), CMKRL LLC adheres rigorously to public contracting laws and state general provisions (DGS PD 403-ITGP). All actual, potential, or perceived conflicts of interest must be disclosed immediately. CMKRL LLC prohibits revolving-door violations, improper procurement influence, organizational conflicts of interest (OCI), or misrepresentation of business certifications or qualifications.

4. Data Privacy, Cybersecurity & Confidentiality

CMKRL LLC enforces strict confidentiality and cyber governance protocols aligned with NIST SP 800-63, FIPS 140-3, and state IT security directives. Proprietary client data, government records, trade secrets, and vendor intellectual property entrusted to CMKRL LLC must be safeguarded with robust technical, administrative, and physical controls, and may never be disclosed to unauthorized entities.

5. Fair Dealing, Equal Opportunity & Non-Discrimination

CMKRL LLC competes fairly and honestly in the marketplace based on technical merit, quality, and competitive pricing. CMKRL LLC strictly complies with Government Code Section 12990 and California Fair Employment Practices, ensuring an inclusive, professional work environment free from discrimination, harassment, or unlawful labor practices.

Executive Attestation & Adoption

I hereby certify that CMKRL LLC has formally adopted this Corporate Code of Business Conduct and Ethics as an operational mandate governing all company conduct.

Homer Cleophis Thompson III

Founder, Owner & CEO, CMKRL LLC

Effective Date: August 15, 2026 | Version: 1.0 (Final & Adopted)

6. Compliance Reporting & Whistleblower Protection

CMKRL LLC maintains an open-door policy for reporting potential violations of this Code, applicable laws, or company policies. Reports may be submitted directly to executive management at hthompson@cmkrlllc.com or via our ethics reporting portal below. CMKRL LLC strictly prohibits retaliation against any individual who reports a concern in good faith.

Ethics & Compliance Intake Portal