Vendor Code of Conduct

CODE OF ETHICS AND PROFESSIONAL CONDUCT

This Code of Ethics and Professional Conduct (“Code”) sets out the principles that govern our business and our expectations for all of the third-party vendors of Atmos Financial, PBC (“Atmos” or the “Company”).

Honest and Ethical Conduct

We expect everyone to act and perform their duties ethically and honestly and with the utmost integrity. Honest conduct is considered to be conduct that is free from fraud or deception. Ethical conduct is considered to be conduct conforming to accepted professional standards of conduct. Ethical conduct includes the ethical handling of actual or apparent conflicts of interest between personal and professional relationships.

Conflicts of Interest

A conflict of interest exists where the interests or benefits of one person or entity conflict or appear to conflict with the interests or benefits of the Company. Individuals must never use or attempt to use their position to obtain improper personal benefits.

Transparency

In addition to performing duties free from fraud or deception, all individuals are expected to maintain transparency in the workplace. Consistent with our Company Values, transparency ensures the free and open flow of ideas and engenders trust across all stakeholders.

Mutual Respect

All individuals must behave in an honest, fair and respectful manner in their professional relationships.

Compliance

It is the Company's policy to comply with all applicable laws, rules and regulations. It is the personal responsibility of all individuals to adhere to the standards and restrictions imposed by those laws, rules and regulations in a professional manner.