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Code of Ethics

Effective Date: [November 14 , 2019]Last Updated: [February 3 , 2026]

Purpose

Colangelo & Partners (“C&P”) is committed to conducting business with the highest standards of integrity, professionalism, and ethical responsibility.

This Code of Ethics establishes the principles and expectations that guide the behavior of all employees, partners, contractors, and representatives of the firm.

Our goal is to ensure that all activities are carried out in a manner that is:

  • Ethical
  • Transparent
  • Compliant with applicable laws and regulations
  • Respectful of clients, partners, and the public
Scope

This Code applies to:

  • All employees (full-time and part-time)
  • Senior leadership and partners
  • Contractors, consultants, and freelancers
  • Any third party acting on behalf of Colangelo & Partners

All individuals are expected to understand and comply with this Code.

Core Principles
  • Integrity
    We act honestly and ethically in all professional interactions and business decisions.
  • Accountability
    We take responsibility for our actions and their outcomes, both internally and externally.
  • Respect
    We treat colleagues, clients, partners, and stakeholders with fairness and respect.
Anti-Corruption Policy

Colangelo & Partners maintains a strict zero-tolerance policy toward corruption and bribery.

Prohibited Conduct

Employees and representatives may not:

  • Offer, promise, give, or accept bribes or improper payments
  • Provide anything of value to influence business decisions improperly
  • Engage in facilitation payments or kickbacks
  • Use third parties to circumvent anti-corruption laws

Compliance with Laws

C&P complies with all applicable anti-corruption regulations, including:

  • U.S. Foreign Corrupt Practices Act (FCPA)
  • UK Bribery Act (where applicable)
  • Local anti-corruption laws in all markets of operation

Gifts and Hospitality

  • Must be reasonable, transparent, and appropriate
  • Must not influence or appear to influence decision-making
  • Must comply with client and legal guidelines
Transparency and Business Practices

Transparency is fundamental to how we operate.

Client Transparency

We commit to:

  • Clear and accurate communication of services and deliverables
  • Transparent billing and financial reporting
  • Honest representation of results and performance

Conflicts of Interest

All employees must:

  • Disclose any actual or potential conflicts of interest
  • Avoid situations where personal interests conflict with client or company interests

Accurate Records

C&P maintains:

  • Accurate financial records
  • Clear documentation of activities and decisions
  • Proper reporting practices aligned with regulatory requirements
Confidentiality

We protect confidential and proprietary information belonging to:

  • Clients
  • Employees
  • Partners

Confidential information must not be disclosed without proper authorization.

Whistleblower and Reporting Channel

Colangelo & Partners is committed to creating a safe environment where concerns can be raised without fear of retaliation.

Reporting Misconduct

Employees and stakeholders are encouraged to report:

  • Violations of this Code
  • Unethical or illegal conduct
  • Conflicts of interest
  • Fraud, corruption, or misconduct

Reporting Channels

Reports can be submitted through the following confidential channels:

  • Email: ethics@www.colangelopr.com
  • Direct Reporting: Any member of senior leadership
    Anonymous
  • Reporting: Available upon request via secure submission process

Non-Retaliation Policy

C&P strictly prohibits retaliation against any individual who:

  • Reports a concern in good faith
  • Participates in an investigation

Any act of retaliation will be subject to disciplinary action.

Enforcement

Violations of this Code may result in:

  • Disciplinary action
  • Termination of employment or contract
  • Legal action where applicable

All reports will be reviewed and investigated appropriately.

Governance and Review

This Code is reviewed periodically to ensure alignment with:

  • Legal requirements
  • Industry best practices
  • Organizational values
Acknowledgment

All employees and representatives of Colangelo & Partners are required to:

  • Acknowledge receipt of this Code
  • Commit to compliance
Public Availability

This Code of Ethics is publicly available and reflects Colangelo & Partners’ commitment to ethical conduct, transparency, and accountability in all business activities.

Colangelo & Partners

Integrity. Transparency. Accountability.

ethics@www.colangelopr.com

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