Strong Law and Compliance Code of Ethics

Document status

Strong Law and Compliance LLC, Florida, United States of America.

Effective date: 1 January 2026.

The founding principles of this Code were written by Tom and Pura Strong in December 2003.

The English version is the master text of this Code. In the event of a discrepancy in interpretation, the English version shall be treated as the principal text, without prejudice to mandatory law in any jurisdiction where Strong Law and Compliance operates.

This Code is a public statement of ethical principles and expected conduct. It does not create ownership rights, employment rights, partnership status, professional licences, or contractual rights beyond those established by applicable law and the relevant agreement.

The expression "Strong Law and Compliance" refers throughout this Code to Strong Law and Compliance LLC, a company established in Florida, United States of America, operating internationally under the Strong Law and Compliance name.

Table of contents

1. Identity, purpose and ethical heritage

Strong Law and Compliance is the operating name used in this Code by Strong Law and Compliance LLC, a Florida company with international activities. This Code defines the ethical standards that guide its professional, commercial, social and institutional conduct.

The founding principles were written by Tom and Pura Strong in December 2003. They were conceived as a practical commitment to peace, fairness, professional dignity, family life, equal opportunity, responsible work and service to others. This revised Code, effective from 1 January 2026, preserves that heritage while adapting it to the firm's current international activities.

Our purpose is not limited to legal and business performance. We aim to create useful work, protect lawful enterprise, support families and communities, and conduct every engagement with competence, independence and humanity.

We understand ethics as a daily operating standard. It must be visible in decisions, deadlines, communications, billing, treatment of colleagues, handling of information, selection of clients and suppliers, use of technology and response to mistakes.

2. Scope and persons covered

This Code applies across all international activities carried out under the Strong Law and Compliance name.

Its principles apply to all persons and organisations that maintain a professional, commercial, employment, service or collaborative relationship with Strong Law and Compliance, including:

The manner in which this Code is enforced depends on the legal relationship involved. Employees and internal personnel may be subject to employment or internal measures permitted by law. Suppliers, collaborators and external parties are expected to comply with the principles relevant to their work and may face contractual measures, suspension or termination of the relationship. This Code does not impose an internal disciplinary regime on persons who are not legally subject to one.

Every person covered must act consistently with both this Code and the laws, professional duties and contractual obligations applicable to that person and activity. Where standards differ, the stricter lawful standard should normally be followed.

3. Core ethical commitments

Strong Law and Compliance adopts the following commitments as the ethical foundation of its work:

These commitments are mutually reinforcing. No commercial objective, deadline, client pressure or internal instruction justifies abandoning them.

4. Respect, dignity, equality and inclusion

All people must be treated with dignity and professional respect, irrespective of nationality, origin, language, race, ethnicity, sex, gender, age, disability, family status, religion, belief, political opinion, sexual orientation, economic circumstances or any other status protected by applicable law.

Strong Law and Compliance does not tolerate harassment, bullying, humiliation, threats, retaliation, hostile conduct or discriminatory treatment. This applies in offices, remote work, travel, events, electronic communications and dealings with clients, authorities, suppliers and third parties.

Differences of opinion must be addressed through evidence, reasoned discussion and respectful communication. Professional disagreement is legitimate; personal degradation is not.

Accessibility and inclusion should be considered in the design of services, communications, recruitment, training and technology, so far as reasonably possible.

5. Shared responsibility and collaborative culture

Strong Law and Compliance promotes a flat, collaborative working culture in which people are encouraged to think and act with an owner's sense of responsibility. This is a cultural principle and does not imply legal ownership, partnership, voting rights or authority to bind the company.

Every person is expected to take responsibility for the quality of their work, identify risks early, report mistakes promptly, protect clients and colleagues, and propose practical improvements.

Decision-making should seek relevant input from the people closest to the work. Responsibility must nevertheless remain clear: consultation does not remove accountability, and collaboration does not authorise a person to act outside their role.

Knowledge should be shared rather than hoarded. Processes should be documented, measurable and capable of being reviewed. A task that depends entirely on one person's memory is an operational risk.

Credit for work should be allocated fairly. Blame-shifting, concealment of errors, internal competition that harms clients and appropriation of another person's work are inconsistent with this Code.

6. Professional excellence and client service

Strong Law and Compliance is committed to competent, careful, timely and practical professional service. Advice must be based on the facts known, the scope agreed and the law or professional framework applicable to the matter.

We must explain material risks, limitations, assumptions, deadlines, documentation requirements and foreseeable costs in language appropriate to the client. We must not create false certainty, guarantee outcomes controlled by third parties or conceal significant uncertainty.

Engagements should have a clear scope. Work outside that scope should be identified before it is undertaken whenever practicable. Billing must be accurate, understandable and consistent with the engagement.

Clients must receive candid advice, including advice they may not wish to hear. Commercial pressure must not convert professional judgment into mere confirmation of a client's preferred answer.

Mistakes must be addressed promptly. The responsible person must escalate material errors, preserve relevant records, contribute to corrective action and avoid statements that could mislead the client or another person.

7. Response standard

Strong Law and Compliance is committed to responding to client communications immediately or within a maximum of 24 hours.

A response may acknowledge receipt, request missing information, identify the person handling the matter, provide the substantive answer or explain the next operational step. The standard is designed to ensure that clients are not left without confirmation or direction.

Communications concerning urgent deadlines, official notices, litigation, payroll, tax payments, employment registrations, immigration status, sanctions, suspected fraud or data security must be escalated without delay.

Internal hand-offs must be visible and documented. A message is not considered handled merely because it has been forwarded.

8. Integrity, honesty and transparency

Every record, statement, invoice, filing, time entry, report, calculation and communication must be accurate to the best of the author's knowledge.

No person may falsify, backdate, conceal, destroy, manipulate or omit information for the purpose of misleading a client, authority, colleague, auditor, bank, insurer or third party.

Material conflicts, delays, errors and limitations must be communicated to the appropriate person. Silence is not acceptable where it creates a false impression.

Marketing and public statements must be truthful and capable of substantiation. Strong Law and Compliance must not misrepresent professional qualifications, regulatory status, experience, success rates, office locations, pricing or the scope of its services.

Transparency does not require disclosure of confidential information, privileged advice, internal security arrangements or legally protected data.

9. Rule of law and responsible conduct

Strong Law and Compliance supports the rule of law, lawful administration and the protection of individual and business rights.

No person may use the firm's services, name, systems or relationships to facilitate unlawful conduct, fraud, tax evasion, corruption, money laundering, sanctions evasion, concealment of ownership, obstruction of justice or abuse of legal process.

Respect for public authorities does not require passive acceptance of error or unlawful action. Strong Law and Compliance may challenge administrative or judicial decisions firmly, accurately and through lawful procedures.

All dealings with courts, registries, tax authorities, social security bodies, immigration authorities, regulators, banks and other institutions must be professional, complete and truthful.

Where the legality of a proposed action is uncertain, the matter must be escalated and reviewed before implementation.

10. Independence and professional judgment

Professional judgment must remain independent from improper influence by clients, colleagues, commercial partners, suppliers, public officials or personal interests.

No person may allow targets, commissions, fear of losing a client, friendship, family connection or internal hierarchy to determine a legal or compliance conclusion.

Strong Law and Compliance may refuse or terminate work that is unlawful, unethical, deceptive, abusive, outside its competence, incompatible with professional duties or likely to damage the integrity of the firm.

A person who reasonably raises an ethical concern must not be pressured to approve, sign, submit or conceal work against their professional judgment.

11. Confidentiality and information protection

Confidentiality is fundamental. Client information, personal data, business plans, records, credentials, drafts, strategies, internal communications and professional advice must be protected according to applicable law, professional secrecy and contractual duties.

Access must be limited to persons who need the information for legitimate work. Curiosity is not a legitimate reason for access.

Information must be stored, transmitted and disposed of using approved systems and reasonable security measures. Passwords, digital certificates, identity documents and authentication credentials require particular care.

Confidential information must not be discussed in public places, posted on social media, sent to personal accounts without authority or entered into unapproved external systems.

Confidentiality continues after employment, collaboration or the client relationship ends.

Suspected loss, unauthorised access, phishing, malware, mistaken disclosure or compromise of credentials must be reported immediately through the appropriate security and management channels.

12. Conflicts of interest

Strong Law and Compliance must identify and manage actual, potential and perceived conflicts of interest.

Before accepting material new work, reasonable checks should be performed against current and relevant former clients, counterparties, related companies, beneficial owners and other persons whose interests may be affected.

A person must disclose any personal, financial, family, business or professional interest that could impair, or reasonably appear to impair, independent judgment.

A conflict may require informed consent, safeguards, separation of personnel, limitation of scope, refusal of the engagement or withdrawal. Consent is not sufficient where the conflict cannot lawfully or ethically be managed.

Information obtained for one client must never be used to benefit another client, the firm or an individual without lawful authority.

13. Fair competition and loyalty

Strong Law and Compliance competes through quality, service, knowledge, organisation and integrity.

We do not obtain business through deception, disparagement, misuse of confidential information, hidden commissions, collusion, coercion or improper interference with another professional relationship.

Personnel and collaborators must protect legitimate business opportunities, confidential methods, client relationships, intellectual property and resources belonging to Strong Law and Compliance, while respecting applicable labour law, competition law and individual rights.

The duty of loyalty does not require a person to conceal wrongdoing, surrender lawful rights or place the firm's commercial interests above law, safety or professional duty.

Any restriction on competition, solicitation or outside activity must arise from applicable law or an enforceable agreement, not from this Code alone.

14. Anti-money laundering, sanctions and client due diligence

Strong Law and Compliance complies with applicable anti-money laundering, counter-terrorist financing, sanctions, client-identification and beneficial-ownership requirements in the jurisdictions in which it operates, including applicable United States federal and Florida law and any mandatory local rules governing the relevant activity.

Risk-based due diligence may include verifying identity, authority, beneficial ownership, business activity, source of funds, source of wealth, tax residence, geographic exposure, political exposure, sanctions status and the purpose of the engagement.

Clients and counterparties must provide complete and accurate information. Strong Law and Compliance may delay, limit, refuse or terminate work where information is missing, contradictory, unreliable or gives rise to unacceptable legal, sanctions, fraud or reputational risk.

No person may structure, divide, disguise or misdescribe an arrangement to avoid identification, reporting, sanctions or other lawful controls.

Suspicious activity or inconsistencies must be escalated internally and handled in accordance with applicable law. No person may alert a client or third party where doing so would be prohibited.

Strong Law and Compliance does not maintain client funds. The firm must not hold itself out as a bank, payment institution, escrow provider or custodian of client money.

15. Anti-bribery and anti-corruption

Strong Law and Compliance opposes corruption in every form, including bribery, extortion, kickbacks, secret commissions, facilitation payments, influence trading and improper advantages.

No person may offer, promise, authorise, request, receive or accept anything of value to influence an official, commercial or professional decision.

Payments must correspond to legitimate services, be accurately recorded and be supported by appropriate documentation. False descriptions, off-book arrangements and payments to unexplained intermediaries are prohibited.

Particular care is required when dealing with public officials, politically exposed persons, public procurement, licences, inspections, immigration procedures, tax matters, registries and customs.

Charitable activity, sponsorship, employment opportunities, travel and hospitality must never be used as indirect methods of obtaining an improper advantage.

16. No-gifts policy

Strong Law and Compliance does not accept gifts.

This prohibition applies to gifts, hospitality, gratuities, commissions, personal benefits, discounts offered because of a professional relationship, cash, cash equivalents and any other advantage offered by clients, suppliers, public officials, counterparties or third parties.

No person may accept a gift on behalf of Strong Law and Compliance or personally where it is connected with work performed for, by or through Strong Law and Compliance.

Items received unexpectedly must be reported and returned, refused or otherwise handled in a manner consistent with this prohibition and applicable law.

The policy exists to protect independence, equality of treatment and public trust. Service quality and professional decisions must never depend on personal benefits.

17. Relationships with clients, authorities, suppliers and third parties

Clients must be treated fairly, respectfully and consistently. Strong Law and Compliance must not exploit a client's lack of knowledge, language difficulties, urgency or dependence.

Authorities and institutions must receive accurate, complete and professionally presented information. Disagreement must remain lawful and respectful.

Suppliers and external professionals should be selected on objective criteria including competence, reliability, security, ethics, value and ability to meet the firm's requirements.

No supplier or collaborator may be selected because of an undisclosed personal benefit. Related-party relationships must be disclosed.

Third parties acting for Strong Law and Compliance must not be used to perform conduct that would be prohibited if performed directly.

Strong Law and Compliance seeks constructive relationships but reserves the right to discontinue relationships inconsistent with law, professional standards or this Code.

18. Human rights and working conditions

Strong Law and Compliance respects internationally recognised human rights and rejects forced labour, child labour, trafficking, exploitation, violence and unsafe or degrading working conditions.

Work must be organised with regard to health, reasonable workload, rest, safety, dignity and the practical realities of family life.

Recruitment, remuneration, training and advancement should be based on objective and relevant criteria.

People must be able to raise workload, safety, ethical and operational concerns without retaliation.

Suppliers and collaborators are expected to maintain lawful and humane working practices relevant to the services they provide.

19. Family life, development and participation

Strong Law and Compliance recognises that a strong and supportive family environment contributes to individual performance and sustainable professional life.

Subject to applicable law and operational requirements, the firm supports parental leave, reasonable flexibility, responsible scheduling and practical measures that help people combine work and family responsibilities.

Training, mentoring, skills development and leadership opportunities should be available according to role, performance and organisational need.

People are encouraged to participate actively in improving processes, technology, client service, sustainability and workplace culture.

Constructive criticism is a contribution. Repeatedly identifying problems without proposing or supporting workable solutions is not enough.

20. Responsible use of resources and technology

Firm resources must be used lawfully, efficiently, securely and primarily for legitimate professional purposes.

Systems, subscriptions, devices, software, data, templates, digital certificates, brands and intellectual property must be protected against misuse, loss and unauthorised disclosure.

Technology purchases and process changes should be evaluated for security, cost, efficiency, environmental impact and operational resilience.

Access rights must follow the principle of least privilege and be removed or changed promptly when roles or relationships change.

Unauthorised software, unlicensed content, pirated materials, insecure storage and deliberate circumvention of controls are prohibited.

21. Artificial intelligence and digital responsibility

Artificial intelligence may support research, drafting, translation, analysis, workflow and client service, but it does not replace professional judgment, verification or accountability.

No confidential, privileged or personal information may be entered into an AI system unless its use is authorised and appropriate safeguards are in place.

AI-generated content must be reviewed for accuracy, bias, completeness, confidentiality, legal relevance and fabricated sources before use.

A person remains responsible for work produced with technological assistance. "The system generated it" is not an acceptable explanation for an error.

Automated decisions affecting people, rights or material client outcomes require proportionate human review.

22. Public communications and social media

Public communications must be accurate, respectful and consistent with confidentiality, professional duties and the firm's brand.

No person may speak on behalf of Strong Law and Compliance without authority.

Personal social media activity must not disclose confidential information, misrepresent the person's role, harass others or create the false impression that personal opinions are official firm positions.

Reviews, testimonials and endorsements must not be purchased, fabricated or conditioned on undisclosed benefits.

Errors in public content should be corrected promptly and transparently.

23. Environmental responsibility and paperless operations

Strong Law and Compliance supports the preventive approach to environmental protection, greater environmental responsibility and the development and dissemination of environmentally respectful technologies.

The firm has pursued paper reduction since its early years and has operated as a paperless professional organisation since 2007. Digital document management developed through successive internal systems and later through Tempo®, enabling documentation and client processes to be managed electronically.

The introduction of virtual communications and VOIP systems reduced hardware, energy use and unnecessary movement of information. The later development of Tempo® and cloud-based collaboration reinforced digital delivery and reduced dependence on physical files.

Strong Law and Compliance operates through three offices. Office use, lighting, heating, cooling, equipment and materials should follow applicable efficiency standards and responsible consumption practices.

Every team member is strongly encouraged to conserve energy, avoid unnecessary printing, extend the useful life of equipment, reduce waste and use technological resources reasonably.

Environmental improvement is a continuing process. Suggestions from the team are welcome and should be assessed on measurable operational and environmental benefits.

24. Philanthropy and the "Give Work" philosophy

Strong Law and Compliance was founded on the practical philosophy associated with Leila Janah: "Give work."

The principle begins with creating dignified, useful and sustainable work. The firm seeks to provide people with the opportunity to develop their profession, support their families, improve their skills and participate meaningfully in the organisation.

Philanthropy is not treated as a substitute for ethical business. The first responsibility is to conduct the firm's own work fairly, lawfully and responsibly. Social projects then extend that commitment into education, art, community support, health and economic opportunity.

The projects described below form part of the history and continuing social responsibility of Strong Law and Compliance.

25. Tenerife Street Art and Solar Graffiti

Strong Law and Compliance supports artistic initiatives that use public space, abandoned structures and open-air performance to promote environmental awareness, critical thought and access to art.

Tenerife Street Art documents and develops street-art projects and community interventions. Solar Graffiti has included the use of solar "eye lamps" and anti-corruption artistic actions in Madrid and Santa Cruz de Tenerife.

Further information:

26. Bintang Beat educational project

Tom Strong founded a preschool project in Jakoi Bintang, The Gambia. Strong Law and Compliance financed materials, while the village community contributed the construction, painting and murals.

Since the project's foundation, the firm has supported the salaries of two teachers providing English-language education to girls and boys. Mothers in the community participate by preparing meals for the children attending the school.

The project also supported a small microcredit initiative connected with weaving and cotton printing. Local mothers repaid the initial funds through sales and reinvested them, developing a self-managed cooperative.

Further information: https://bintangbeat.com/

27. Fonkoze

Pura Strong became involved with Fonkoze's microfinance work in Haiti in 1997. The relationship expanded through fundraising and institutional support, including service on the council until 2015.

Strong Law and Compliance continues to support Fonkoze and commits a minimum of 2% to 5% of annual net profits to the foundation.

This commitment reflects the firm's belief that access to work, finance and local economic organisation can strengthen families and communities.

Further information: https://fonkoze.org/

28. Aldeas Infantiles

Since 2019, Strong Law and Compliance has collaborated with the Tenerife programme of Aldeas Infantiles in activities connected with nature, play, companionship, equestrian support and family participation.

The purpose is to support children and families through inclusive experiences that reinforce confidence, contact with nature and community.

Further information: https://www.aldeasinfantiles.es/nuestros-programas/sostenibilidad-y-naturaleza

29. Blood donation commitment

Strong Law and Compliance recognises blood donation as a direct and personal act of solidarity.

A member of the Strong Law and Compliance team who donates blood is entitled to one paid day of leave, subject to reasonable evidence of donation and the operational arrangements required by applicable law.

The policy expresses gratitude to voluntary donors whose generosity enables medical treatment and recovery.

Further information on ethical principles of blood donation: https://www.donarsangre.org/todo-sobre-la-sangre/principios-eticos/

30. Matching employee donations

Where a member of the team makes a donation to a non-governmental organisation, Strong Law and Compliance will match that donation, thereby strengthening the combined social responsibility of the individual and the firm.

The matching process must be documented and directed to a legitimate organisation. It must not be used to obtain personal, commercial, political or regulatory advantage.

Administrative procedures may be established to verify the donation and ensure accurate accounting.

31. Internal reporting and protection against retaliation

Strong Law and Compliance maintains an internal reporting and whistleblowing channel on its website.

Concerns may relate to unlawful conduct, fraud, corruption, harassment, discrimination, retaliation, data misuse, serious professional breaches, conflicts of interest, sanctions risk, financial irregularities or violations of this Code.

Reports must be handled confidentially and in accordance with the privacy and whistleblowing information published by Strong Law and Compliance and any applicable law.

Retaliation against a person who raises a concern in good faith or provides truthful information is prohibited.

Knowingly false allegations, fabricated evidence and misuse of the channel to harass another person are also inconsistent with this Code.

Nothing in this Code prevents lawful reporting to competent public authorities or the exercise of legally protected rights.

32. Implementation, interpretation and review

Every person within the scope of this Code is expected to know the provisions relevant to their work and seek guidance when uncertain.

Managers and persons responsible for work must model the standards, respond to concerns, correct weaknesses and avoid creating incentives that encourage misconduct.

Violations may result in corrective, contractual, employment, professional or legal measures, depending on the relationship involved and applicable law.

The Code should be reviewed periodically to reflect changes in the firm's activities, technology, risk profile and applicable legal standards.

The effective date of this revised edition is 1 January 2026.

The founding ethical principles were written by Tom and Pura Strong in December 2003.

Thank you for making it possible.

Strong Law and Compliance