POOLE AUDIT
CODE OF ETHICS
Effective Date: June 16, 2026
Version: 1.0
Approved by: Terry Poole, Owner
Statement of Commitment
Poole Audit is committed to conducting all business activities with the highest standards of integrity, transparency, accountability, and ethical conduct. We maintain an absolute rejection of corruption, bribery, fraud, and any form of improper influence. Our ethical standards are essential to building and maintaining trust with our clients, partners, contractors, and the communities in which we operate.
As a specialized audit firm in the energy sector, we recognize that our work often involves sensitive financial information, multiple stakeholders in joint ventures, and high expectations for independence and objectivity. This Code of Ethics sets forth the core principles that guide every decision and action by the Owner, management, independent contractors, and any representatives acting on behalf of Poole Audit.
This Code applies to all persons associated with Poole Audit, regardless of position or engagement type. Compliance is mandatory and non-negotiable.
Core Ethical Principles
- Integrity: We act with honesty, fairness, and consistency in all matters. We do not compromise our principles for personal gain, client pressure, or business advantage. We are truthful in communications, reports, and representations.
- Transparency and Accountability: We are open and accountable for our actions and decisions. We maintain accurate records and provide timely, truthful information to clients and internal stakeholders within the bounds of confidentiality and professional standards.
- Compliance with Laws and Regulations: We comply fully with all applicable laws and regulations in every jurisdiction where we conduct business or perform services. This includes U.S. laws such as the Foreign Corrupt Practices Act (FCPA), relevant foreign anti-corruption statutes when applicable, data protection laws, and professional standards governing auditors and consultants.
- Independence and Objectivity (Auditor-Specific): We maintain independence in fact and appearance in all audit and assurance engagements. We avoid any financial, personal, or business relationships that could impair—or appear to impair—our objectivity. This is particularly critical in joint venture audits where we must serve the interests of fairness and accuracy for all parties without favoritism.
- Confidentiality and Data Protection: We protect all confidential, proprietary, and personal information entrusted to us by clients, partners, or through our work. We do not disclose, use, or permit unauthorized access to such information. We comply with all applicable data privacy and security requirements.
- Professional Excellence and Due Care: We perform all work with due professional care, competence, and diligence. We continuously develop our skills and knowledge. We issue only reports and opinions supported by sufficient, appropriate evidence and professional judgment.
- Respect for Individuals and Fair Dealing: We treat everyone with dignity and respect. We do not engage in or tolerate harassment, discrimination, or retaliation. We deal fairly with clients, contractors, vendors, and competitors.
- Zero Tolerance for Corruption: We prohibit bribery, kickbacks, facilitation payments, extortion, and any offer, promise, or acceptance of anything of value intended to improperly influence a decision or obtain an unfair advantage. This applies to interactions with public officials, private parties, clients, and any third parties.
Conflicts of Interest
All associated persons must promptly disclose to the Owner or COO any actual, potential, or perceived conflict of interest. Examples include:
- Personal or family financial interest in a client, auditee, or vendor involved in an engagement
- Prior or current employment or significant relationship with a party to an audit
- Acceptance of gifts, hospitality, or favors from parties with interest in our work product
- Any situation where personal interests could conflict with professional duties or firm interests
Upon disclosure, the Owner or designated reviewer shall determine appropriate mitigation, which may include recusal from the engagement, enhanced supervision, or other safeguards. No engagement shall proceed where independence is compromised.
Gifts, Hospitality, and Business Courtesies
We do not accept or offer gifts, meals, entertainment, travel, or other courtesies that could influence—or appear to influence—business decisions or create an obligation.
- Nominal courtesies of modest value (e.g., under $100 USD or local equivalent) that are customary, transparent, and have a clear business purpose may be accepted or offered with appropriate documentation and approval where required by the Anticorruption Policy.
- Cash or cash equivalents are never acceptable.
- Gifts or hospitality involving public officials are subject to heightened scrutiny and generally prohibited unless minimal, transparent, and legally permissible.
- All gifts/hospitality above de minimis thresholds must be logged and pre-approved per the Anticorruption Program procedures.
Reporting and Whistleblower Protection
We encourage and expect all associated persons to report, in good faith, any suspected violations of this Code, other policies, or applicable laws. Reports may be made to the Owner, COO, or through designated channels (including anonymous options where available).
Poole Audit prohibits retaliation against anyone who reports concerns in good faith or participates in an investigation. Any form of retaliation is itself a violation of this Code and will result in disciplinary action.
Training, Acknowledgment, and Certification
All associated persons shall receive training on this Code upon engagement and at least annually thereafter. Each person must sign an annual acknowledgment confirming understanding and commitment to comply. Failure to complete training or provide acknowledgment may result in suspension or termination of engagement.
Consequences of Violations
Violations of this Code undermine our values and reputation and will not be tolerated. Depending on severity, consequences may include: - Formal warning and required remedial training - Removal from specific engagements or clients - Termination of independent contractor agreement or relationship - Reporting to relevant authorities or professional bodies where required or appropriate - Civil or criminal liability where conduct violates law
The Owner has final authority on disciplinary matters, subject to legal requirements.
Annual Review and Updates
This Code shall be reviewed at least annually by the Owner, with input from the COO and consideration of changes in laws, business activities, risk profile, or best practices. Updates shall be communicated promptly and acknowledged by all associated persons.
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