Code of Business Ethics

REF: GOV-2026-A // INTEGRITY

SMC Global Holdings Inc. operates in a regulated telecommunications environment where integrity is our license to operate. We adhere strictly to the U.S. Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act.

No officer, director, or employee may offer, promise, or give anything of value to a government official or commercial partner to gain an improper advantage.

Whistleblower Policy

REF: WB-2026-C // INTERNAL CONTROLS

SMC Global Holdings is committed to high standards of ethical, moral, and legal business conduct. This policy provides an avenue for employees and partners to raise concerns regarding financial malpractice, regulatory violations, or ethical breaches.

Reporting Mechanism: Concerns may be submitted confidentially to the General Counsel via our secure channel: compliance@smcholdingsinc.com

Modern Slavery Statement

REF: UK-MSA-2015 // SUPPLY CHAIN

We maintain a zero-tolerance approach to modern slavery. Our supply chain consists of Tier-1 network carriers, chipset manufacturers, and software infrastructure. We conduct due diligence on all hardware vendors.

CPNI Data Privacy

REF: FCC-47-CFR // FEDERAL LAW

Customer Proprietary Network Information (CPNI) includes call logs, location data, and usage patterns. SMC Global Holdings does not sell, trade, or share CPNI with third parties for marketing purposes.

Regulatory Filings

REF: USAC-499 // FCC

SMC Global Holdings Inc. complies with all federal contribution requirements for the Universal Service Fund (USF) and Telecommunications Relay Service (TRS).