Governance & Compliance

ELYT POLICIES

Effective Date

January 29, 2026

Document Version

v2026.1.1

Section 01

SECTION 1 – CODE OF ETHICS

Elyt (hereafter the Company) has made a commitment to provide the finest direct sales experience backed by impeccable service to its Independent Business Owners (IBO’s) and customers. In turn, the Company expects Company Independent Business Owners (IBO’s) to reflect that image in their relationships with customers and fellow Independent Business Owners (IBO’s).

As a Company Associate you are expected to operate your business according to the highest standards of integrity and fair practice in your role as a Company Associate. Failure to comply with the Code of Ethics can result in your termination as a Company Associate. The Code of Ethics, therefore, states:

As an Independent Associate:

  • I will conduct my business in an honest, ethical manner always.
  • I will make no representations about the income benefits of being an Associate with Company or the benefits of the Company products or services other than those contained in officially approved Company literature.
  • I will provide support and encouragement to my customers and other Independent Business Owners (IBO’s) to ensure that their experience with Company is a successful one.
  • I will motivate and actively work with Independent Business Owners (IBO’s) in my downline organization to help them build their Company business. I understand that this support is critical to each Associate's success with the Company.
  • I will refrain from making income claims, exaggerating my personal income or the income potential in general and will stress to Associate candidates the level of effort and commitment required to succeed in the business.
  • I will not abuse the goodwill of my association with Company to further or promote other business interests (particularly those which may be competitive to Company) without the prior written consent of Company.
  • I will not make disparaging remarks about other products, services, Independent Business Owners (IBO’s), or companies; likewise, I will not willfully denigrate the activities or personalities of fellow Company Independent Business Owners (IBO’s).
  • I will abide by all the Policies and Procedures of Company as included herein, or as may be amended from time to time.
  • I will not make any payment(s) or promise to pay any prospective or existing Associate in return for such Associate's enrollment, continued enrollment, or team building or recruiting activities with Company.

Section 02

SECTION 2 – INTRODUCTION

2.1 – Policies and Compensation Plan Incorporated into Associate Agreement

These Policies and Procedures, in their present form and as amended at the sole discretion of Company, are incorporated into, and form an integral part of, the Company Associate Agreement. Throughout these Policies and Procedures, when the term "Agreement" is used, it collectively refers to the Company Associate Application and Agreement Form, these Policies and Procedures and the Company Compensation Plan. These documents are incorporated by reference into the Company Associate Agreement (all in their current form and as may be amended by Company).

2.2 – Purpose of Policies

Company is a direct sales company that markets travel products through Independent Business Owners (IBO’s). Independent Business Owners (IBO’s) could receive commissions and bonuses by selling Company products (see Company Compensation Plan). It is important to understand that your success and the success of your fellow Independent Business Owners (IBO’s) depends on the integrity of those who market our services. To clearly define the relationship that exists between Independent Business Owners (IBO’s) and Company, and to explicitly set a standard for acceptable business conduct, Company has established the Agreement. Company Independent Business Owners (IBO’s) are required to comply with all the provisions set forth in the Agreement, which Company may amend at its sole discretion from time to time, as well as with all federal, state and local laws governing their Company business and their conduct. Because you may be unfamiliar with many of these standards of practice, it is very important that you read and abide by the Agreement. Please review the information in this document carefully. It explains and governs the relationship between you, as an independent contractor, and the Company. If you have any questions regarding any policy or rule, do not hesitate to seek an answer from the Company corporate office.

2.3 – Changes to the Agreement

Because laws and the business environment periodically change, Company reserves the right to amend the Agreement, the products or services offered, the compensation plan, and the prices at the Company's sole and absolute discretion. By signing the Associate Agreement, an Associate agrees to abide by all amendments or modifications that Company elects to make. Amendments shall be effective immediately after publication. The Company shall provide or make available to all Independent Business Owners (IBO’s) a complete copy of the amended provisions by one or more of the following methods: (a) posting on the Company's official website; (b) electronic mail (email); (c) inclusion in Company periodicals; (d) inclusion with commissions or bonus checks; or (e) special mailings.

2.4 – Delays

Company shall not be responsible for delays or failures in performance of its obligations when performance is made commercially impracticable due to circumstances beyond its reasonable control. This includes, without limitation, strikes, labor difficulties, riot, war, fire, death, curtailment of a party's source of supply, government decrees or orders, and acts of God.

2.5 – Policies and Provisions Severable

If any provision of the Agreement, in its current form or as may be amended, is found to be invalid, or unenforceable for any reason, only the invalid portion(s) of the provision shall be severed, and the remaining terms and provisions shall remain in full force and effect and shall be construed as if such invalid or unenforceable provision never comprised a part of the Agreement.

2.6 – Waiver

The Company never gives up its right to insist on compliance with the Agreement and with the applicable laws governing the conduct of a business. No failure of Company to exercise any right or power under the Agreement or to insist upon strict compliance by an Associate with any obligation or provision of the Agreement, and no custom or practice of the parties at variance with the terms of the Agreement, shall constitute a waiver of Company's right to demand exact compliance with the Agreement. Waiver by Company can be affected only in writing by an authorized officer of the Company. Company's waiver of any breach by an Associate shall not affect or impair Company's rights with respect to any subsequent breach, nor shall it affect in any way the rights or obligations of any other Associate. Nor shall any delay or omission by Company to exercise any right arising from a breach affect or impair Company's rights as to that or any subsequent breach. The existence of any claim or cause of action of an Associate against Company shall not constitute a defense to Company's enforcement of any term or provision of the Agreement.

Section 03

SECTION 3 – BECOMING AN ASSOCIATE

3.1 – Requirements to Become an Associate

To become a Company Associate, each applicant must:

  • 3.1.1Pay the Associate Enrollment Fee. All Associate initial and monthly recurring pricing information (including any short term promotions or incentives and Founders Club details) will be presented on the official Company website and updated periodically.
  • 3.1.2Be at least 18 years of age.
  • 3.1.3Reside in Estonia, the 50 United States or other jurisdictions officially opened by the Company.
  • 3.1.4Have a valid Social Security or Tax ID number if within the United States.
  • 3.1.5Submit an accepted Company Associate Application and Agreement.

The Company reserves the right to reject any applications for a new Associate or applications for renewal. No product or service purchase is required to become a new Associate.

3.2 – Associate Benefits

Once the Associate Application and Agreement have been accepted by Company, the following benefits are available to the new Associate:

  • Market and sell Company products or services.
  • Participate in the Company Compensation Plan (receive bonuses and commissions, if eligible).
  • Enroll other individuals as Independent Business Owners (IBO’s) into the Company business and thereby, build a sales organization and progress through Company Compensation Plan.
  • Receive periodic Company literature and other Company communications.
  • Participate in Company–sponsored support, service, training, motivational and recognition functions, upon payment of appropriate charges, if applicable.
  • Participate in promotional incentives and programs sponsored by Company for its Independent Business Owners (IBO’s).

Section 04

SECTION 4 – OPERATING A COMPANY BUSINESS

4.1 – Adherence to the Company Compensation Plan

Independent Business Owners (IBO’s) must adhere to the terms of the Company Compensation Plan as set forth in official Company literature. Independent Business Owners (IBO’s) shall not offer the Company opportunity through, or in combination with, any other system, program or method of marketing other than that specifically set forth in official Company literature. Independent Business Owners (IBO’s) shall not require or encourage other current or prospective customers or Independent Business Owners (IBO’s) to execute any agreement or contract other than official Company agreements and contracts to become a Company Associate.

4.2 – Bonus Buying Prohibited

Bonus buying is strictly and absolutely prohibited. "Bonus buying" includes: (a) the enrollment of individuals without their knowledge and agreement; (b) the fraudulent enrollment of an individual as an Associate; (c) the enrollment of non–existent individuals; (d) the use of a credit card by or on behalf of an Associate when the Associate is not the account holder; (e) purchasing Company products on behalf of another Associate to qualify for commissions or bonuses.

4.3 – Business Entities

A Partnership, LLC or Corporation may hold an Associate business upon completion of the Associate Application form. Business entities must provide the applicable taxation requirements of their jurisdiction. An individual may not participate in or have any beneficial interest in more than one (1) Associate business. By signing for as a business entity, you certify that no person with an interest in the business has had an interest in an Associate business with Company within six (6) months.

4.4 – Changes to a Company Business

4.4.1 – General: Each Associate must immediately notify Company of all changes to the information contained in their Application and Agreement.

4.4.2 – Change of Enroller: Company does not allow changes in enroller for active Independent Business Owners (IBO’s). The transfer of an Company business from one enroller to another is not permitted, except in cases of Company error reported within 3 days.

4.4.3 – Cancellation and Re-application: An Associate may change organizations by voluntarily cancelling their Agreement and remaining inactive (no purchases, no sales, no enrolling, no attendance at Company functions) for 6 full calendar months.

4.5 – Unauthorized Claims and Actions

4.5.1 – Indemnification: An Associate is fully responsible for all verbal and written statements made regarding Company products and the Compensation Plan not contained in official materials. Independent Business Owners (IBO’s) agree to indemnify Company and its directors, officers, employees and agents and hold them harmless from all liability, including judgments, civil penalties, attorney fees, and court costs.

4.5.2 – Income Claims: An Associate may NOT make income projections, income claims or disclose personal Company income (including the showing of checks, bank statements or tax records).

4.5.3 – Claims of Illegal Use: Independent Business Owners (IBO’s) shall not make any statement regarding the use of Company products or services for any illegal purpose.

4.5.4 – Product Claims: No therapeutic, curative, or beneficial property claims may be made. All representations must be identical to current Company literature. Testimonials must state that the material does not represent that all people will have the same experience and include appropriate FDA disclaimers.

4.6 – Corporate Events

4.6.1 – No Selling or Recruiting: Selling and recruiting at official Company corporate events is not permitted to protect the professional image of the Company.

4.6.2 – Other Companies: IBO's shall not sell products or recruit for any other direct sales or marketing program during Company events.

4.7 – Conflicts of Interest

4.7.1 – Competition Policy: IBO's are free to participate in other network marketing ventures, except for those products/services in the same generic category as Company offerings.

4.7.2 – Non–solicitation: During the term of this Agreement and for one year thereafter, IBO's may not recruit other Company Associates or customers for another network marketing business, unless such company is doing business with Xstream Travel.

4.7.3 – Downline Reports: Downline Activity Reports are confidential proprietary information and business trade secrets belonging to the Company.

4.8 – Cross–Enrolling

Actual or attempted cross–enrolling (enrolling an existing customer or Associate within a different line of enrollership) is strictly prohibited.

4.9 – 4.14 – Identification & Compliance

4.9 – Errors: Notification of errors in commissions or reports must be made within 15 days.

4.11 – Governmental Approval: No regulatory agencies approve or endorse any direct selling program; IBOs must not represent otherwise.

4.13 – Identification: All IBOs must provide an SSN or Tax ID number. A unique Associate Identification Number will be assigned.

4.14 – Income Taxes: Each Associate is responsible for paying all applicable taxes. The Company will provide Form 1099 as required by law.

4.15 – Independent Contractor Status

IBOs are independent contractors, not employees, agents, or franchise holders. Associates have no authority to bind the Company to any obligation. Each Associate establishes their own goals, hours, and methods of sale.

4.28 – Telemarketing

Independent Business Owners (IBO’s) must not engage in telemarketing. "Cold calls" are strictly prohibited. Permissible calls include those where a prior relationship exists, written permission was granted, or to immediate family/friends.

Section 05

SECTION 5 – RESPONSIBILITIES OF IBO'S

5.1 – Change of Address or Telephone

IBOs must notify the Company of address or telephone changes immediately to ensure timely delivery of support materials and commission checks.

5.2 – Continuing Development Obligations

5.2.1 – Ongoing Training: Enrollers must perform a bona fide training function for their Downline, including product knowledge and Compensation Plan compliance.

5.2.3 – Ongoing Sales: IBOs have an ongoing obligation to personally promote sales through generation and servicing of customers.

5.3 – Non–disparagement

IBOs must not disparage, demean or make negative remarks about the Company, its services, directors, or other Associates.

5.5 – Reporting Policy Violations

IBOs observing a policy violation should submit a written report directly to the Company Compliance Department.

Section 06

SECTION 6 – SALES REQUIREMENTS

6.1 – Product Sales

The Compensation Plan is based on sales to end users. IBOs must fulfill personal and Downline sales requirements to be eligible for bonuses and advancement.

6.2 – Online Sales Prohibited

Sales of Company products through online classifieds or auction sites (Amazon, eBay, Craigslist) are strictly prohibited without written consent.

6.3 – Territory Restrictions

There are no exclusive territories granted. No franchise fees are required.

Section 07

SECTION 7 – BONUSES AND COMMISSIONS

7.1 – Qualifications

Associates must be active and in compliance to qualify. The minimum commission payment is $40.00; smaller amounts will accrue until the threshold is met.

7.3 – Adjustments for Returns

Commissions attributable to cancelled or refunded services will be deducted from the Associate in the month the refund occurs.

7.4 – Report Accuracy

Sales volume information is provided "as is" and is not guaranteed for accuracy or timeliness due to potential human or mechanical error.

Section 08

SECTION 8 – RETURNS AND REPURCHASE

8.1 – Customer Returns

Customers have a 3-day full money-back guarantee. Resalable products returned within 90 days receive a 100% refund (minus shipping and 20% restocking fee).

8.2 – Sales Aids

IBOs may return unused, resalable sales aids purchased within one year for a 90% refund of the net cost upon cancellation.

Section 09

SECTION 9 – DISPUTE RESOLUTION

9.1 – Sanctions

Violations result in corrective measures including warnings, fines, withholding of commissions, or involuntary termination.

9.3 – Arbitration

Any controversy shall be settled by arbitration in Estonia. IBOs waive all rights to trial by jury or to any court.

9.4 – Governing Law

The laws of Estonia govern all matters relating to or arising from the Agreement.

Section 010

SECTION 10 – CANCELLATION

10.1 – Effect of Cancellation

Terminated Associates lose all rights, titles, and interests to their marketing organization and future commissions.

10.2 – Involuntary Termination

Violations of the Agreement may result in immediate involuntary termination, effective upon notice via courier, fax, or actual receipt.

10.3 – Voluntary Termination

Associates may cancel at any time. Re-application is possible after a 6-month period of inactivity.

10.5 – Complete Agreement

These Policies, along with the Terms and Conditions and Compensation Plan, constitute the entire agreement between Associate and Company.

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