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Code of Ethics

1. Purpose and scope

This Code sets out how we do business at Offsetra LLC ("Carbonmark", "the Company"). It applies to everyone who works for or on behalf of the Company, including officers, directors, employees, consultants, contractors, and temporary staff, in their professional conduct everywhere we operate. Managers carry an added responsibility: to model this Code and to address every ethical question or concern raised to them promptly.

No code can anticipate every situation. When something is unclear, ask your manager or the Company's leadership before acting.

2. Our values

Integrity, honesty, accountability, excellence, innovation, respect for others. We strive to collaborate with our clients, business partners, and industry bodies to achieve our mission of radically scaling up the flow of climate finance to high-impact environmental projects.

3. Following the law

We comply with the laws and regulations that apply to our business wherever we operate, honor the contracts we sign, and expect the same of our subcontractors, service providers, and business partners throughout our value chain.

4. Anti-corruption, gifts, and hospitality

We do not tolerate corruption in any form. No one acting for the Company may offer, promise, give, solicit, or accept any improper advantage (cash or equivalents, gifts, travel, services, or favors) to obtain, retain, or steer business. Facilitation ("grease") payments are prohibited. Occasional, customary business courtesies of trivial value are acceptable if they are infrequent and could not reasonably be seen as an attempt to influence a decision; anything more must be refused or returned, and all benefits received in the course of business must be accounted for. Bribery, whether giving, taking, or allowing it, is gross misconduct.

5. Fair competition and trade compliance

We compete on the quality and pricing of our products and services. We make pricing and marketing decisions independently, never coordinate improperly with competitors, and never interfere with a fair tendering process. We market our services fairly and accurately, treat customers and partners equally, pay our partners what we owe them when we owe it, and comply with all applicable trade controls, sanctions, and import-export restrictions.

6. Conflicts of interest

We act in the Company's best interest and keep personal interests out of business decisions. A conflict of interest exists when a personal interest (yours, or that of family or close relations) could interfere with the Company's interests. Examples include working for or holding a stake in a customer, competitor, or supplier; hiring or supervising family; serving on another organization's board; and standing to gain personally from a Company transaction. Conflicts are not always obvious. When in doubt, disclose the situation to management and ask.

7. Confidentiality and company assets

We protect non-public information about the Company, its customers, and its partners, and use it only to do our jobs. No one may trade securities on non-public information or pass it to others. We respect intellectual property, ours and everyone else's, and never acquire trade secrets by improper means or use unlicensed software. Company resources, including time, equipment, and information, are for legitimate business use; occasional personal use is fine where it is lawful and doesn't interfere with work.

8. Financial integrity

Our books and records reflect our transactions truthfully and in appropriate detail. We do not tolerate fraud in any form (falsified records, expense abuse, or misappropriation of assets), and we never improperly influence or mislead an audit. We do business only with partners engaged in legitimate activity with funds from legitimate sources, we condemn money laundering, and we commit to fair taxation and reject tax-evasion practices.

9. Respect for people

We treat everyone with dignity and respect, and we uphold human rights in everything we do. We provide equal opportunity and do not tolerate discrimination, harassment, bullying, or victimization of any kind, on any ground. We are committed to fair employment and remuneration, and we firmly oppose child, forced, or bonded labor and every unlawful labor practice, in our own work and in our supply chain. We maintain safe and healthy working conditions.

10. Environment

Sustainability is our business, and we hold ourselves to it: we weigh environmental and social factors in our decisions, work to minimize the footprint of our own operations, and comply with all applicable environmental laws.