No Windsor Fountains Homeowner Association (“WF”) director, officer, employee, management company under contract with WF (collectively, “Fiduciaries”) may accept anything of value in exchange for allowing a third party an improper business advantage in doing business with WF. WF prohibits any bribes, kickbacks or other corrupt or illicit payments to any Fiduciary for any reason whatsoever. This includes, but is not limited to, contracts for goods and services (including construction contracts and Change Orders). This Policy strictly prohibits the creation, alteration or destruction of records for the purpose of concealing the true nature of a payment. Under no circumstances may false, misleading, or artificial entries be made in the books and records of WF.

WF Fiduciaries are required to report actual or suspected violations of this Policy. This includes any request for, or receipt or offer of a bribe or illicit payment by anyone. WF Fiduciaries are required to cooperate with WF in connection with any inquiry or investigation of an alleged violation of this Policy. Every WF Fiduciary hereby represents that he or she has never asserted, in either a criminal or civil matter (including in a deposition under oath) their Fifth Amendment right against self-incrimination.

All present WF Fiduciaries should sign, under penalty of perjury, that she or he is in and has always been in compliance with the WF Business Conduct Policy (“Statement of Compliance). For current Fiduciaries, Statements of Compliance must be executed at a minimum once a year in the form set forth immediately below. In addition, to ensure confidence in the operation of WF, several WF Officers or Directors who are no longer serving as Fiduciaries have been requested to execute the WF Business Conduct Policy.

I am either a present or former WF Fiduciary as defined above. I hereby represent that I have read and reviewed the WF Business Conduct Policy. I represent and certify, under penalty of perjury, that I presently, and at all times, have been in full compliance with the WF Business Conduct Policy.

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In addition, all current or future vendors providing goods and services to WF must execute the written representation set forth below. Such vendors would include, but are not be limited to, companies or entities performing construction, plumbing, roofing, landscaping, cleaning services, security services, painting or other work or services where the contract amount (or the amount is likely to be paid) would be greater than $5,000. Such Statements of Compliance shall be kept with the vendor’s contract and a file copy kept by the Management Company.

I (or behalf of) , am a WF vendor. I hereby represent and warrant that I have read and reviewed the WF Business Conduct Policy. I represent and warrant, under penalty of perjury, that I am presently, and at all times, have been in full compliance with the WF Business Conduct Policy.

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