POOLE AUDIT
CODE OF CONDUCT

Effective Date: June 16, 2026
Version: 1.0
Approved by: Terry Poole, Owner

Purpose

This Code of Conduct translates the principles of our Code of Ethics into specific behavioral expectations and rules applicable to daily operations, client interactions, fieldwork, and internal conduct. It provides clear guidance to help all associated persons make appropriate decisions and maintain the professional standards expected of Poole Audit in the energy auditing and consulting field.

This Code applies to the Owner, COO, all independent contractors, and any other representatives. It supplements, and should be read together with, the Code of Ethics and Anticorruption Policy/Program.

Professional Conduct in Client Engagements and Fieldwork

4.1 Independence and Objectivity in Practice

• Maintain professional skepticism and base all findings, conclusions, and recommendations solely on evidence and professional judgment. - Do not allow client pressure, personal relationships, or financial considerations to influence audit scope, testing, or reporting. - Immediately disclose any situation that could create an actual or perceived impairment of independence to the engagement lead or COO/Owner. - In joint venture audits, ensure balanced, fair treatment of all interest owners’ perspectives without favoritism.

4.2 Conduct During On-Site or Client Interactions

• Arrive prepared, on time, and professionally attired appropriate to the work environment (office or field). - Treat all client personnel, partners, and stakeholders with courtesy and respect. - Limit discussions to work-related matters; avoid personal or sensitive topics. - Do not use client facilities, equipment, or resources for personal purposes without explicit authorization. - During audits, do not discuss or share findings with unauthorized parties, including other interest owners beyond approved protocols.

4.3 Communication and Reporting

• All written and oral communications shall be accurate, clear, professional, and free from misleading statements. - Draft reports and workpapers shall be reviewed appropriately before finalization. - Significant issues, scope limitations, or disagreements with client management shall be escalated promptly to the engagement lead and, if necessary, COO or Owner.

Confidentiality and Information Handling

• Protect all client data, audit workpapers, findings, and internal firm information with the same care as your own most sensitive personal information.
• Do not copy, transmit, store, or discuss confidential information on personal devices or unsecured channels unless authorized and using approved secure methods.
• Upon completion of an engagement or termination of relationship, return or securely destroy all client and firm confidential materials as directed.
• Report any actual or suspected data breach or unauthorized access immediately.

Use of Company and Client Assets

• Use firm-provided tools, software, and resources only for authorized business purposes.
• Protect laptops, phones, and access credentials; report loss or theft immediately.
• Do not install unauthorized software or access inappropriate content on firm or client systems.
• Expense reimbursement is limited to legitimate, documented, pre-approved business expenses incurred in connection with authorized work.

Conflicts, Gifts, and Outside Activities (Detailed Rules)

See the Code of Ethics and Anticorruption Policy for core rules. Additional conduct expectations: - Do not engage in outside employment, consulting, or business activities that conflict with your duties to Poole Audit or create divided loyalties, without prior written approval from the Owner. - Do not use your position or firm resources to advance personal business interests or those of family/friends. - Political activities and contributions are personal; do not imply firm endorsement or use firm resources/time for political purposes.

Workplace Conduct and Respect

Although Poole Audit primarily engages independent contractors who work remotely or on client sites, the following standards apply whenever interacting in a firm or client context: - Maintain a professional, harassment-free environment. - Do not engage in or tolerate bullying, discrimination, offensive language, or inappropriate behavior. - Report any concerns about workplace conduct promptly.

Social Media and Public Communications

• Do not post, share, or comment on social media or public forums about specific clients, engagements, findings, or internal firm matters.
• Personal opinions must be clearly distinguished from firm positions.
• Any public representation of Poole Audit (e.g., speaking engagements, publications) requires prior approval.

Compliance with Specific Laws and Client Requirements

• Comply with all client-specific codes of conduct, safety rules, access policies, and anti-corruption requirements when performing work on client premises or for client projects.
• When working internationally or with foreign counterparties (including in Mexico or with Mexican entities), be particularly vigilant regarding local anti-corruption, gifts, and facilitation payment prohibitions. Facilitation payments are prohibited under Poole Audit policy even where technically legal under local law in limited circumstances.
• Maintain awareness of and comply with data transfer restrictions and privacy laws when handling cross-border information.

Reporting Concerns and Asking Questions

If you are unsure about the application of this Code or any policy to a specific situation, or if you observe or suspect a violation, you have a duty to report.

Contact options: - Your engagement lead or project manager - COO (Evan Poole) - Owner (Terry Poole) - Dedicated compliance email or hotline (to be established or use This email address is being protected from spambots. You need JavaScript enabled to view it. for initial reports).

Reports will be handled confidentially to the extent possible, and retaliation is strictly prohibited.

Acknowledgment and Annual Certification

All associated persons must acknowledge receipt and understanding of this Code of Conduct upon engagement and certify compliance annually in writing. The certification form is included in the Appendices.

Terry Poole
Owner, Poole Audit
Date: June 16, 2026
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Document Control
Version 1.0 – June 16, 2026 – Initial Release – Approved by Terry Poole, Owner
Poole Audit – Integrity. Excellence. Trust. | Third Generation of Professional Audit Services
This document is confidential and intended solely for internal use and authorized distribution in connection with legitimate business development and contracting activities.