Code of Ethics

GEXFIX INTERNATIONAL CORP.
Official Distribution Partner of Assut Europe S.P.A.

Effective Date: July, 08, 2025.

Introduction
Gexfix International Corp., as the official distribution partner of Assut Europe S.P.A., is committed to conducting business with the highest standards of ethics, integrity, and compliance. This Code of Ethics establishes the fundamental principles and behavioral guidelines that govern all our business activities in the veterinary healthcare sector.

Our Mission
Gexfix International Corp. aims to improve the lives of pets and veterinary professionals through the distribution of innovative, high-quality surgical products that guarantee exceptional standards, ease of use for operators, and sustainability for veterinary healthcare institutions.

1. Scope and Application
1.1 Purpose
This Code expresses our commitments and ethical responsibilities in conducting business and regulates the rights, duties, and responsibilities that guide our corporate activities.

1.2 Who Must Follow This Code
This Code applies to:

Board members and executive leadership
All employees and managers
Consultants, agents, and contractors
Suppliers and business partners
Anyone acting on behalf of Gexfix International Corp.
1.3 Compliance Obligations
All recipients must:

Understand and follow this Code and applicable laws
Seek guidance when uncertain about proper conduct
Report potential violations through established channels
Cooperate with internal investigations and compliance activities
2. Core Ethical Principles
2.1 Legal Compliance
We respect and enforce all applicable laws and regulations in the United States and jurisdictions where we operate. No pursuit of business interest justifies violation of the law, and we will not maintain relationships with those unwilling to align with legal compliance.

2.2 Respect for Human Rights
We are inspired by the protection and promotion of human rights, following the principles of the Universal Declaration of Human Rights, UN Global Compact, and fundamental conventions of the International Labour Organization.

2.3 Market Integrity and Fair Competition
We compete fairly and transparently in the veterinary market, maintaining correct relationships with institutions, customers, and third parties. We observe all laws regulating the market and collaborate with regulatory authorities.

2.4 Intellectual Property Protection
We respect intellectual property rights, including patents, trademarks, and proprietary information of our manufacturing partner Assut Europe S.P.A. and third parties. We comply with all intellectual property legislation.

2.5 Honesty and Transparency
We conduct business with complete honesty, reaching clear and understandable agreements that ensure fair balancing of interests. We encourage reporting of suspected corrupt acts and protect whistleblowers from retaliation.

2.6 Sustainability
Economic and environmental sustainability are essential values that guarantee business continuity and effectiveness. However, sustainability goals must never induce violations of this Code to obtain advantageous results.

2.7 Conflict of Interest
We implement measures to prevent conflicts of interest where recipients might pursue interests conflicting with the Company’s objectives. Any potential conflicts must be disclosed and managed appropriately.

2.8 Gifts and Donations
We prohibit gifts or donations that could be interpreted as exceeding normal commercial practices or aimed at acquiring preferential treatment. Gifts and commercial courtesies are permitted only if of modest value (generally not exceeding $100) and properly authorized.

2.9 Non-Discrimination
We base our actions on the rejection of any form of discrimination based on age, gender, race, nationality, health status, sexual orientation, political opinions, or religious beliefs.

2.10 Technology and Information Systems
IT systems must be used exclusively for company purposes and in ways that respect people and their dignity. We prohibit access to inappropriate sites, use of unlicensed software, and any misuse of company technology resources.

2.11 Confidentiality and Privacy
We ensure confidentiality of information and guarantee that acquisition, processing, and storage of personal data complies with applicable privacy laws and regulations, including state privacy laws and federal requirements.

2.12 Workplace Respect
We protect individual dignity and prohibit harassment, intimidation, or creation of hostile work environments. Sexual harassment and any form of workplace misconduct are strictly prohibited.

2.13 Employee Value and Safety
We recognize human resources as fundamental to our development and guarantee:

Health, safety, and physical and moral integrity of employees
Working conditions that respect individual dignity
Safe and healthy working environments
Rejection of any form of irregular work
Fair exercise of authority in hierarchical relationships
2.14 Professional Assignments
We award professional assignments based on principles of economy, transparency, and correctness, evaluating moral and ethical integrity of consultants and paying fees proportionate to activities performed.

2.15 Information Transparency
We provide complete, transparent, understandable, and accurate information to all parties. Every operation must be correctly recorded, formally authorized, verifiable, legitimate, coherent, and appropriate with adequate documentary support.

2.16 Supplier Relations
We base relationships with suppliers on principles of transparency, correctness, professionalism, efficiency, honesty, and reliability. Selection considers economic convenience, technical capacity, quality, and compliance with our Code and applicable laws.

2.17 Customer Relations
Customer satisfaction and creating solid relationships based on transparency, correctness, honesty, efficiency, and professionalism are priority objectives. We guarantee achievement of expected quality and safety standards for veterinary products.

2.18 Environmental Protection
We recognize the importance of environmental protection and contribute to sustainable development with the lowest environmental impact. All activities must comply with applicable environmental rules and regulations.

2.19 Anti-Terrorism
We repudiate all forms of terrorism and adopt suitable measures to prevent involvement in any activity that may have terrorist purposes. We will not establish relationships with individuals or entities involved in terrorist activities.

2.20 International Operations
All relationships with international entities occur in full compliance with applicable laws. We verify reliability of operators and legitimate origin of capital and collaborate transparently with authorities when requested.

2.21 Government Relations
We conduct relationships with government agencies, regulatory authorities, and officials with maximum transparency and ethics. Relations are maintained exclusively through persons appointed for this purpose.

2.22 Veterinary Professional Relations
All relationships with veterinary professionals are based on compliance with company procedures and regulatory provisions. We prohibit promising or paying unauthorized benefits to promote company interests.

2.23 Clinical Studies
In planning and conducting trials, we adhere to relevant regulations and ensure clinical studies are conducted exclusively for scientific purposes with qualified centers and personnel.

2.24 Conference Events
In organizing or sponsoring veterinary conferences, we comply with industry codes and regulations, verifying scientific nature of events and reliability of organizers based on objective criteria.

2.25 Political and Union Relations
We do not make direct or indirect contributions to political parties, movements, or organizations except those required or permitted by specific regulations. All relationships must be authorized by relevant structures.

2.26 Board Governance
The Board of Directors performs functions with professionalism, autonomy, independence, and responsibility. Directors must avoid conflicts of interest and cannot take personal advantage of opportunities connected to their functions.

2.27 Oversight Relations
Supervisory bodies carry out functions with impartiality, autonomy, and independence to guarantee effective control. We ensure access to necessary data, documentation, and information.

2.28 Media Relations
We address press and communication bodies solely through authorized representatives who operate with correctness, availability, and transparency while ensuring truthful, respectful communication.

2.29 Legal Authority Relations
We prohibit any conditioning of persons making statements before judicial authorities and forbid helping anyone evade investigations or escape searches by authorities.

2.30 Company Reputation
Recipients are prohibited from engaging in behavior that may cause reputational damage to the Company, particularly those in management positions. Behaviors contravening laws are considered extremely serious.

2.31 Substance Abuse
We prohibit use, sale, purchase, or possession of illegal drugs and ensure compliance with smoking prohibitions. We also prohibit alcohol abuse and promote social actions for those with chronic dependencies.

2.32 Inappropriate Material
We absolutely forbid possession or dissemination of inappropriate material on company premises, equipment, or through company systems.

2.33 Company Assets
Company assets are used exclusively for institutional purposes and cannot be used for personal purposes or transferred without authorization. All recipients are responsible for protecting entrusted resources.

2.34 Tax Compliance
We carry out all tax obligations with completeness and transparency as required by current legislation and collaborate with tax administrations. Tax declarations and payments represent mandatory legal and social responsibilities.

2.35 Anti-Money Laundering
We undertake not to carry out activities involving money laundering or acceptance of proceeds from criminal activities. We verify available information on counterparties to ascertain respectability and legitimacy before establishing relationships.

3. Implementation and Reporting
3.1 Compliance Framework
Implementation of this Code includes:

Comprehensive ethics training for all recipients
Clear procedures for sensitive business areas
Regular monitoring and assessment of compliance
Appropriate sanctions for violations
3.2 Reporting Mechanisms (Whistleblowing)
All recipients are required to report non-compliance and violations of this Code. Reports can be made:

Through our confidential online reporting system
By email to: ethics@medicaldevicevet.com
By phone: +39 06 72677 348
By mail to: Compliance Officer, 55 NE 5th Avenue Suite 501, Boca Raton, FL 33432
3.3 Protection of Reporters
We guarantee:

Confidentiality of reporter identity
Protection from retaliation, discrimination, or penalization
Good faith investigations of all reports
Appropriate disciplinary action for violations
3.4 Training and Communication
We provide ongoing training on ethical principles and standards, particularly for new personnel, through specific communication tools promoting knowledge of ethical requirements.

4. Contact Information
For questions about this Code of Ethics or to seek guidance:

Compliance Officer
Gexfix International Corp.
55 NE 5th Avenue Suite 501
Boca Raton, FL 33432
Email: ethics@medicaldevicevet.com
Phone: +39 06 72677 348

General Information
Email: info@medicaldevicevet.com
Website: medicaldevicevet.com

This Code of Ethics reflects our unwavering commitment to ethical business practices and compliance with all applicable laws and regulations. We expect all recipients to embrace these principles in their daily activities and business relationships.