This Code of Conduct outlines the standards of behaviour expected of all individuals working with or on behalf of Mohr & Coleman (“Mohr & Coleman”, “we”, “us”, “our”), a trading name of Ricochet Group Ltd.

It applies to employees, contractors, suppliers, and partners, and reflects our commitment to operating responsibly, ethically, and professionally across all aspects of our work.

1.1 The purpose of this Code of Conduct is to define how we operate and the standards we expect in our business relationships.

1.2 It supports our legal and contractual obligations and underpins our approach to governance, responsibility, and risk management.

All individuals working with Mohr & Coleman are expected to:

2.1 Act with integrity, honesty, and professionalism at all times.

2.2 Comply with applicable laws, regulations, and contractual obligations.

2.3 Treat others with respect, fairness, and consideration.

2.4 Exercise sound judgement in all business activities.

2.5 Avoid behaviour that could harm our clients, partners, or reputation.

3.1 We conduct business in a fair, transparent, and responsible manner.

3.2 We do not engage in: bribery or corruption, deceptive or misleading practices, and unlawful or unethical conduct.

3.3 Conflicts of interest must be identified and managed appropriately. Individuals must disclose any situation that could compromise their objectivity or independence.

4.1 We are committed to maintaining a professional environment that is respectful, inclusive, and free from discrimination.

4.2 We do not tolerate: discrimination based on protected characteristics, harassment, bullying, or intimidation, or any form of unfair or unequal treatment.

4.3 Individuals are expected to behave in a way that supports a positive and inclusive working environment.

5.1 We take a zero-tolerance approach to modern slavery, forced labour, and human trafficking.

5.2 Individuals must not engage with or support any organisation or practice that involves: exploitation of workers, unsafe or inhumane working conditions, or unlawful labour practices.

5.3 Concerns relating to labour standards within our supply chain must be raised promptly.

6.1 All individuals must handle data responsibly and in accordance with applicable data protection laws and contractual obligations.

6.2 Confidential Information must not be disclosed or used improperly.

6.3 Access to data and systems must be used only for legitimate business purposes.

6.4 Appropriate security practices must be followed at all times.

7.1 Systems, tools, and infrastructure must be used responsibly and securely.

7.2 Individuals must not: misuse systems or access unauthorised data, introduce security risks intentionally or negligently, or attempt to bypass security controls.

7.3 Any suspected security issue must be reported promptly.

8.1 We expect suppliers, contractors, and partners to meet standards consistent with this Code.

8.2 Individuals engaging third parties must: act responsibly in selection and management, avoid relationships that present ethical or legal risks, and ensure third parties understand expected standards of conduct.

9.1 Individuals are expected to raise concerns about: unethical behaviour, legal or regulatory breaches, security risks, and misconduct or inappropriate behaviour.

9.2 Concerns should be raised promptly through appropriate internal channels.

9.3 Concerns will be treated seriously and handled appropriately.

10.1 All individuals are responsible for complying with this Code of Conduct.

10.2 Failure to comply may result in: termination of engagement, removal from projects, or other appropriate action.

11.1 This Code of Conduct may be updated from time to time to reflect changes in legal, regulatory, or operational requirements.

11.2 Individuals are expected to remain aware of the current version and comply with its requirements.