Code of Ethics & Business Conduct

1.1 Who this Code covers

This Code covers Evntrace's principal, any employees, and every contractor, partner examiner or other person who works on Evntrace matters or acts on its behalf.

It applies to all of our work, in every state, whoever retains us: defense or civil counsel, a mediator, a public agency, a business or an individual.

If a law, a court rule, a client's written requirement or a partner examiner's own professional code sets a stricter standard than this Code, we follow the stricter standard.

• If you are unsure, ask before acting. A simple test: if you would not be comfortable explaining it openly to the client or a court, don't do it. See 2.7 for how to ask.

1.2 Our core commitments

Six commitments guide our work.

• Integrity. We are honest in our findings, reports, testimony, billing and marketing.
• Independence. Our findings follow the evidence, not who pays. Our fee never depends on the outcome.
• Confidentiality. We protect the information entrusted to us. See 1.5.
• Competence and candor. We take on only work we can do well, and tell clients plainly who does each part. Court testimony is given through a credentialed partner examiner.
• Lawfulness. We follow the law wherever we work, including anti-bribery, anti-money-laundering, sanctions and false-claims laws.
• Respect. We treat everyone fairly and with dignity.

1.3 Integrity of evidence and findings

Our findings are only as good as the evidence behind them, so the evidence comes first.

• We work from verified forensic copies wherever possible. We document how each item was received, handled and stored.
• We use documented, repeatable methods, so another qualified examiner can check our work.
• We never alter, fabricate or plant evidence. We never destroy evidence or working copies except as 1.5 describes.
• We never drop or soften a finding because it does not help whoever pays.
• We report findings to the retaining party accurately and completely within the agreed scope, whether or not they help. Who else sees them is decided by the retaining attorney and the law.
• We keep facts and opinions separate, and we say what each conclusion rests on.
• No one may pressure an examiner to change a finding — not a client, an attorney, a partner examiner or the principal. Pressure is reported under 2.7.
• Testimony, given through a credentialed partner examiner, is truthful and stays within the witness's expertise.

1.4 Honest representation

People hire us based on who we say we are, so we describe ourselves accurately.

• We never claim a qualification, credential, affiliation or experience we do not have — in marketing, proposals, reports, résumés or testimony.
• We tell clients who performs each part of the work, including when a partner examiner or other third party is involved. See 2.3.
• Our marketing makes no unsupported claims and promises no result. Examples on our website are labeled as illustrative.
• We never use a real client's name or case details in marketing.

1.5 Confidentiality and privileged information

Everything we learn in an engagement is confidential: who the client is, case facts, evidence, findings and communications.

• For work done at an attorney's request, we follow the attorney's direction on privileged and work-product material.
• Case information goes only to people working on the matter who need it. It goes to a third party only under a written confidentiality agreement. See 2.3.
• We disclose case information outside the engagement only when the retaining attorney directs it, the client consents, or a law or court order requires it. Where the law allows, we tell the retaining attorney first so they can respond.
• At the end of an engagement we return or destroy evidence and working copies, as the engagement terms or the retaining attorney direct.
• If confidential information is lost or exposed, we tell the affected client promptly.

The Part 2 policies cover Evntrace's own business dealings — who pays us, who we hire, what we give and receive. They never override this section.

How we handle information from our website is in our Privacy Policy.

1.6 Accurate records and billing

Our records and invoices have to show what actually happened.

• We keep accurate, complete records of time, expenses, evidence handling and business transactions. We never falsify or back-date a record.
• Hours billed are hours actually worked on the matter, by the person shown on the invoice, recorded at the time.
• You get a written scope and an estimate range before any work, and we ask for approval before going beyond it.
• Third-party costs are itemized and passed through at actual cost.
• For publicly funded work we follow the paying agency's pre-approval and billing rules. We never bill public funds for work that was not authorized or not done.
• We correct billing errors promptly and refund or credit any overcharge.
• If we find that public funds were billed in error, we tell the paying agency and repay the amount promptly.

1.7 Fair dealing and respect

• We deal honestly with clients, opposing parties, courts, vendors and competitors. We make no misleading statements.
• We do not discriminate against or harass anyone based on race, color, religion, sex, sexual orientation, gender identity, national origin, age, disability or any other status protected by law.
• We follow the employment, tax and business laws that apply to us.
• We never use confidential information from one matter to benefit another client or ourselves.

1.8 When this Code is breached

We take every breach of this Code seriously.

• Consequences fit the facts: correcting the work, removing someone from a matter, or ending a contract or engagement.
• If a breach affects a client's matter, we tell that client.
• If the law requires a report to authorities, we make it, consistent with 1.5.
• Breaking the law can also bring personal civil or criminal penalties.
• An honest mistake reported promptly is treated as a mistake. Hiding one is a breach.

2.1 Anti-bribery and anti-corruption

• We never offer, promise, give, ask for or accept a bribe: anything of value meant to improperly influence a decision or action, or to reward one — directly or through someone else.
• "Anything of value" is broad. It includes:
  • cash, gift cards, gifts, meals, entertainment and travel;
  • jobs or internships, loans, discounts, donations, favors and referral payments.
• Public officials need extra care. They include:
  • judges, court staff, prosecutors, law enforcement officers and public-defense agency staff;
  • any other federal, state, local, tribal or foreign government employee, plus anyone acting for them.
  We give them nothing of value. See 2.2.
• Kickbacks. We do not pay or accept kickbacks, commissions or referral fees for getting or giving work — including to or from attorneys, investigators or vendors.
• Facilitation payments. Small "speed-up" payments to officials for routine actions are banned, even where local custom tolerates them.
• We never let a partner examiner, contractor or anyone else do on our behalf what we may not do ourselves. See 2.3.
• Politics and charity. Evntrace makes no political contributions. Personal contributions are personal: never made on Evntrace's behalf and never reimbursed. Charitable donations are never linked to a decision about our work.
• Records. Every payment is recorded accurately. No off-the-books accounts, no vague invoices.

This policy supports the U.S. Foreign Corrupt Practices Act, which covers U.S. businesses of every size, and federal and state bribery and gratuity laws, including those of Oregon and Hawaii. The Foreign Corrupt Practices Act has a narrow exception for facilitating payments. Our policy bans those payments anyway.

Red flags. Watch for:

• a request for payment in cash, or to an unrelated person or account;
• a go-between who wants secrecy or an unexplained fee;
• an official hinting at a "donation" or favor;
• an invoice with no clear service behind it.

What to do. Refuse, do not pay, write down what happened, and report it (2.7).

2.2 Gifts, entertainment and hospitality

A gift can create a real or apparent obligation, and an expert's independence may be tested in court.

• Public officials. They include judges, court staff, prosecutors, law enforcement, public-defense agency staff, and other public employees connected to our work. Attorneys employed by a government agency count as public officials under this policy. We give them nothing of value — no gifts, meals, drinks, tickets, travel or hospitality — and we accept nothing from them.
• Everyone else — clients, attorneys, mediators, vendors, partner examiners. Gifts and hospitality given or received must be:
  • occasional and modest: no more than $50 in value per person per year;
  • never cash or cash equivalents, such as gift cards, prepaid cards or cryptocurrency;
  • never offered or accepted while a decision involving us is pending — an engagement, a proposal, an invoice approval, or testimony;
  • given openly and suitable for a professional relationship.
• We accept nothing from opposing parties, witnesses, or their counsel.
• Travel and expenses paid under a written engagement — for example, travel to an examination site or court — are business expenses billed under the engagement's terms, not gifts.
• Services we offer every prospective client on the same terms, such as a free case consultation, are not gifts.
• We decline anything outside this policy politely and explain why.
• We keep a simple register of gifts and hospitality given, received or declined, beyond a token item such as a branded pen or a cup of coffee.

Oregon's and Hawaii's government ethics laws, which limit gifts to public officials, are among the rules behind this policy.

What to do. If unsure, ask first. Report pressure or improper offers (2.7).

2.3 Engaging third parties

Who counts as a third party:

• partner examiners, subcontractors and specialist labs;
• transcription and translation services, and other service providers who work on our matters or see case information;
• anyone else who acts on our behalf.

We are responsible for work done in our name, and clients rely on it. So before we engage a third party, we:

• confirm who they are and that their business is genuine and in good standing;
• verify claimed credentials directly with the issuing body — for partner examiners, before they work on any matter;
• run a conflict check for the matter (2.6);
• search the U.S. Treasury Department's OFAC sanctions list (2.4);
• confirm they can protect confidential information and handle evidence properly.

Our written agreement with each third party covers:

• scope and fees, and confidentiality;
• evidence handling and chain of custody;
• compliance with this Code, including anti-bribery;
• no subcontracting without our written approval;
• return or destruction of case information at the end;
• our right to end the relationship if they breach it.

• We tell clients when a third party will do part of their work. Testimony through a credentialed partner examiner is quoted as its own line.
• We pay only for documented work at agreed rates, to an account in the third party's own name, never in cash. Third-party costs are itemized and passed through at actual cost. We pay no referral fees or commissions to anyone for sending us work (2.1).
• Red flags: requests for unusual payment methods or accounts, secrecy, unexplained fees, lapsed credentials, or a conflict that appears mid-matter. We pause the work, review, and end the relationship if the issue cannot be resolved.
• We keep a file for each third party with these checks and the signed agreement.

What to do. Raise any concern about a third party under 2.7.

2.4 Anti-money laundering and sanctions

Evntrace is not a bank. We still will not let our services or accounts be used to hide where money came from, or to deal with sanctioned people or countries.

• Know who we work for. Before work begins we confirm who the client is and who is paying:
  • for attorney engagements, the attorney and firm;
  • for publicly funded work, the agency's authorization;
  • for individuals and businesses, their identity.
• Sanctions. We search the U.S. Treasury Department's OFAC sanctions list for every new client, payer and third party before work begins. We do not proceed with a possible match until it is resolved, and we decline confirmed matches.
• How we accept payment. Check, bank transfer or card, from the client, the retaining law firm or the paying public agency. We do not accept cash, cryptocurrency, gift cards or money orders.
• Any other payer needs the principal's approval, after we confirm who they are and why they are paying.
• Refunds go only to the original payer, by the original method where possible. We do not accept overpayments to be refunded elsewhere.

Red flags:

• payment from someone unconnected to the matter, or from an unexpected country;
• a request to overpay and refund the difference;
• payments split up to avoid attention;
• reluctance to give identity or payment details;
• pressure to start before checks are done;
• a retainer far larger than the work.

What we do. We pause, ask questions, and decline the engagement or the payment if the concern is not resolved. We make any report the law requires, without disclosing confidential case information except as 1.5 allows.

When our casework involves financial records or suspected laundering by others, that information is case information. It is handled under 1.5, not this policy.

This policy supports U.S. sanctions administered by the Treasury Department's Office of Foreign Assets Control (OFAC).

What to do. Raise any concern under 2.7.

2.5 Fraud prevention

Fraud means deliberately deceiving someone to gain something or to cause a loss.

Examples we guard against:

• billing time that was not worked, or not worked by the person shown;
• padding expenses, or misstating qualifications;
• altering or fabricating evidence, reports or records;
• misusing a client's money, or redirecting payments;
• false claims for public funds;
• people impersonating Evntrace.

Controls:

• time recorded at the time, by matter;
• invoices that itemize time and third-party costs, with receipts available on request;
• estimates approved before work and before any overrun;
• the paying agency's rules for publicly funded work;
• the evidence safeguards in 1.3.

Payment details. We never change our payment details by email alone. If you get a message saying Evntrace's payment details have changed, call (530) 435-5055 before you pay. We verify any change to a vendor's payment details by phone, at a number we already have.

Protecting the public from impersonators. We never ask anyone to pay with gift cards or cryptocurrency, or by wire to anyone other than Evntrace. We never guarantee that lost money will be recovered. If someone claiming to be Evntrace asks you to pay in one of those ways, or promises to recover lost money, contact us at info@evntrace.com or (530) 435-5055.

Among the laws behind this policy are the federal False Claims Act and the false-claims laws of Oregon and Hawaii.

What happens after a report. We look into it promptly, fix what went wrong, and repay anyone harmed. We act under 1.8 and make any report the law requires, consistent with 1.5.

What to do. Report suspected fraud under 2.7.

2.6 Conflicts of interest

A conflict exists when a personal, financial or professional interest or relationship could affect — or reasonably appear to affect — our independence or loyalty on a matter.

We run a conflict check before any substance. The check covers:

• the parties, their counsel and known witnesses;
• any past or current work for anyone in the same or a related matter;
• personal, family or financial relationships;
• any financial interest in the outcome.

Outcomes:

• No conflict — we proceed.
• A potential conflict — we disclose it to the client in writing and proceed only with their informed consent, where that is permitted.
• A real conflict — we decline.

• We never take on work for one side of a matter after working for another side of it.
• We re-check whenever new parties, counsel or witnesses appear, and tell the client promptly if a conflict arises.
• We hold no financial interest in the outcome of any matter we work on. Our fee never depends on the outcome. Gifts follow 2.2.
• Conflict-check information is used only for the check and kept confidential. That is why our attorney and mediation request forms ask people to leave party names out until the check.
• Partner examiners and subcontractors run the same check before working on a matter.
• We keep a record of every conflict check and its outcome.

What to do. Raise any conflict question under 2.7.

2.7 Speaking up and non-retaliation

Anyone can raise a concern: clients, attorneys, partner examiners, contractors, vendors and members of the public.

What to raise:

• a possible breach of this Code or the law;
• pressure to change a finding;
• a bribe or improper gift;
• a billing concern;
• suspected fraud or impersonation.

How. Email info@evntrace.com with "Ethics concern" in the subject line, or call (530) 435-5055. You do not need proof — an honest concern is enough.

• You may raise a concern without giving your name. We will look into it as far as we can, though we may not be able to follow up with you.
• Because Evntrace is a small firm, a concern about the principal can also be raised with the retaining attorney, the agency paying for the work, or a government agency.

What happens next:

• we acknowledge your concern within one business day;
• we look into it promptly and fairly;
• we keep your identity and the details confidential, except as needed to look into it or as the law requires;
• we fix what we find;
• we tell you the outcome where we can.

No retaliation. We never end a relationship, withhold work or payment, or otherwise penalize anyone for raising a concern in good faith or for helping with a review. Retaliation is itself a breach of this Code. Knowingly false reports made to harm someone are also a breach.

Nothing in this Code stops anyone from reporting a possible violation of law by Evntrace, or by anyone acting for it, to a government agency, or requires them to tell us first.

3.1 Ownership, acknowledgment and review

Evntrace's principal owns this Code, approves every change, and is accountable for following it.

• Everyone the Code covers reads it and confirms in writing that they will follow it before working on an Evntrace matter, and again when it changes. For partner examiners and contractors, this is part of their written agreement.
• Questions go to the contacts in 2.7. Ask before acting.
• The records this Code requires — conflict checks, the gift register, third-party files, sanctions searches — are kept with our business records.
• We review the Code at least once a year and whenever our services or the laws that apply to us change. The next review is due by September 2027.
• Clients and prospective clients may ask us about it at any time.

3.2 Version history