Updated as of June 2023

About This Code

 This Code of Ethics and Business Conduct (Code of Ethics) is a statement of our principal commitment to integrity and the highest ethical standards in all that we do. This Code of Ethics defines the standards of conduct that we expect from our directors, members, and employees and guides us to make the right decisions when conducting our business.

This Code of Ethics cannot address every potential concern. However, the standards, values and other guidelines set forth in this Code of Ethics can help members act ethically and with sound, reasoned judgment even in the absence of specific laws, regulations, or policies.

A Culture Founded on Five Core Values 

Exotropin, LLC (Exotropin) including its brands Exoceuticals® and Exo Skin Simple®, are committed to fostering and maintaining a culture based on five core values: Lead with Science, Communicate Honestly & Transparently, Make the Customer the Priority, commit to “Do the Right Thing”,and Give Back. Living these values means, above all, conducting ourselves and our business activities in accordance with the letter and spirit of applicable laws and regulations and company policies, and acting with integrity to deliver our products in a first‐class way. Members, and employees of Exotropin work hard to protect our reputation by dealing fairly and transparently with partners, customers, the public, competitors, and suppliers. We strive to not take advantage of anyone through manipulation, concealment, improper handling of confidential information, or other unfair dealing or practices.

Treating Others with Dignity and Respect

Exotropin is committed to providing environments where everyone feels a sense of belonging and is treated with dignity and respect.  Misconduct, including discrimination, harassment, retaliation, or other forms of unprofessional behavior, are not tolerated.

How We Conduct Our Business

We strive to adhere to the highest standards of ethical conduct. We will not compromise the legal, regulatory, or policy requirements that govern our activities. Our commitment to ethical conduct means that we abide by the letter and the spirit of applicable laws and regulations. These principles are hallmarks of the Exotropin culture and reflect our pledge to Do the Right Thing.

Each member of the company is responsible for addressing Conduct Risk by:

• complying with relevant local conduct standards, including acting with integrity, due skill, care, and diligence at all times and observing proper standards of market
• refraining from any act, on or off company premises, that threatens the reputation of the Exotropin or any of its partners.
• being alert to any potential adverse consequences that our actions or the actions of others might have for our partners, the customers or Exotropin.

Conflicts of Interest

We take responsibility for taking appropriate actions in accordance with regulatory requirements and policies when we become aware of an actual or potential conflict.

We strive to avoid investment activity or relationships that could or could appear to impair judgment or interfere with the responsibilities of Exotropin and our partners.

Anti-Corruption 

Exotropin prohibits all forms of bribery and corruption. We do not: offer, promise, give or authorize others to offer, promise or give anything of value, either directly or indirectly, to any party in order to gain an unfair or improper business advantage, such as obtaining or retaining business; or receive, or agree to receive, anything of value that results or may result in improperly influencing our duties as directors or officers.

Protecting Confidential Information 

Confidential Information

Protecting confidential information is critical to our reputation for integrity and our relationship with partners or clients and ensures compliance with regulations governing transactions we participate in. Much of Exotropin’s information is confidential information. Confidential information is information that we create, develop, receive, use, learn or have access to that is not generally known by the public, may be price sensitive or is sufficiently sensitive where loss or unauthorized disclosure or access could result in legal, business, regulatory or reputational harm to Exotropin or our partners.

We protect all confidential information, regardless of its form or format, and use due care in the handling of such information and follow all applicable policies with respect to its treatment. We strive to take all reasonable measures to prevent unauthorized persons from obtaining confidential information.

Personal Commitment 

Employees, officers, and directors of Exotropin are committed to and continuously live the company’s core values. Only by doing so can we realize the potential of our organization and the talents of our partners around the world.