Code of Business Conduct

Express Tools is built on the principle that contractors deserve a supplier they can trust. That means honest product descriptions, fair prices, and accurate information — no misleading claims about compatibility, condition, or delivery times.

We stock only genuine, authorized inventory from the brands we represent. We do not knowingly sell counterfeit, grey-market, or diverted products, and we will remove any product from sale the moment we have reason to believe it may not meet our authenticity standards.

Our employees and contractors are expected to be truthful with customers, suppliers, and each other. Misleading a customer — even through omission — is a violation of this code.

We do not offer, give, request, or accept bribes or improper inducements of any kind — whether in cash, gifts, entertainment, or any other form of value — to influence a business decision. This applies to relationships with customers, suppliers, government entities, and any other third parties.

Reasonable, modest business hospitality (a working lunch, branded merchandise of nominal value) is acceptable when it is transparent and not intended to create an obligation. When in doubt, disclose it to management before accepting.

We comply with all applicable anti-corruption laws, including the U.S. Foreign Corrupt Practices Act (FCPA) where applicable.

We compete on the merits of our products, pricing, and service — not by disparaging competitors or exploiting supplier relationships unfairly. We do not engage in price-fixing, bid-rigging, or any other anticompetitive conduct.

We treat all customers fairly and consistently. Pricing and terms disclosed to one customer in the same purchasing tier should be available to comparable customers on the same terms. We do not discriminate in our commercial dealings on any basis prohibited by law.

We respect our suppliers' confidential business information and honor the terms of our authorized-dealer agreements. We do not pressure suppliers to act in ways that would violate their obligations to other parties.

A conflict of interest exists when a personal relationship or financial interest could — or could appear to — influence a business decision. We require employees and contractors to disclose any actual or potential conflicts to management promptly.

Common situations requiring disclosure include: a personal or financial relationship with a customer, supplier, or competitor; a secondary employment or ownership interest in a business that competes with or does business with Express Tools; or a family member involved in a transaction with the company.

Disclosure does not automatically mean disqualification — but the affected person should recuse themselves from decisions where the conflict could affect the outcome.

If you believe this code has been violated — by an employee, contractor, supplier, or anyone acting on behalf of Express Tools — we want to know. You can report concerns by email:

Reports may be made with your name or anonymously. We investigate all credible reports promptly and confidentially to the extent practicable. We do not tolerate retaliation against anyone who reports a concern in good faith.

Express Tools strictly prohibits retaliation against any person who, in good faith:

• Reports a suspected violation of this code or applicable law
• Participates in an investigation of a potential violation
• Declines to participate in conduct they believe is unethical or unlawful

Retaliation is itself a violation of this code and may result in disciplinary action up to and including termination of employment or business relationship.