Bauer Accountants Limited

Introduction

This Code of Ethics and Professional Standards ("the Code") sets out the principles and expectations that govern the conduct of Bauer Accountants Limited (the "Company"). As a professional accounting practice regulated under UK law and professional bodies, the Company is committed to the highest standards of integrity, objectivity, professional competence and due care, confidentiality, and professional behaviour. These five fundamental principles form the foundation of our professional and ethical commitments, ensuring that our services are delivered with trust, independence, and accountability.

This Code applies to all partners, employees, consultants, trainees, and representatives of the Company. It ensures that all services are delivered with competence, independence, and transparency, while safeguarding the interests of clients, regulators, and the public.

Our Core Ethical Principles

At the foundation of our professional conduct are the five fundamental principles of the accounting profession, and we commit to living them in every engagement.

Integrity means we act with honesty, fairness, and truthfulness in all professional and business relationships. We show strength of character under pressure, and we do not associate ourselves with false, misleading, reckless, or incomplete information.

Objectivity means our professional judgments are independent and free from bias, conflict of interest, or undue influence. Independence of mind is essential to trust, and we do not undertake any activity where that independence is compromised.

Professional competence and due care mean we maintain the knowledge, skills, scepticism, and diligence necessary to deliver competent services. We perform our work in accordance with current laws, regulations, and professional standards, engage in continuing professional development, and provide training and supervision to ensure consistent quality.

Confidentiality means we respect and protect information obtained through professional and business relationships throughout its lifecycle—from collection and use to storage, sharing, and lawful destruction. This duty extends to present and former clients, as well as to third parties, and all staff and advisers are bound by it.

Professional behaviour means we comply with all applicable laws and regulations and conduct ourselves in ways that uphold the reputation of the profession. Bullying, harassment, victimisation, or unfair discrimination have no place in our firm. We treat everyone with fairness, respect, and dignity.

Professional Standards in Practice

Independence is central to public trust in our work as auditors and accountants. We avoid relationships, financial interests, or situations that impair-or could reasonably be seen to impair-our objectivity. Conflicts of interest are disclosed promptly and either managed or eliminated.

We are committed to quality in every engagement. We accept only assignments we can perform competently, apply scepticism and sound judgment, and operate a system of quality management. Technology supports our work but never replaces professional judgment; we apply oversight, controls, and expertise to ensure its responsible use.

Confidentiality and Data Protection

We safeguard confidential and personal data in compliance with the UK GDPR and the Data Protection Act 2018. Information entrusted to us is protected throughout its lifecycle, and any breach of confidentiality or data security is treated as serious professional misconduct, and any breach may result in disciplinary or legal consequences.

Speak Up and Whistleblowing

Speaking up protects our people, our clients, and the public. Anyone may raise concerns about unethical, unlawful, or unsafe behaviour. We provide secure and confidential reporting channels, including a designated email address and confidential hotline, ensure concerns are investigated promptly and fairly, and protect those who raise issues in good faith. Retaliation of any form is prohibited. We recognise and support the protections provided by the Public Interest Disclosure Act 1998.

Anti-Bribery, Financial Crime and Tax Integrity

We operate zero tolerance for bribery, corruption, fraud, tax evasion, and money laundering. We comply with the Bribery Act 2010 and maintain procedures to prevent bribery. We comply with the Criminal Finances Act 2017, which makes it an offence to fail to prevent the facilitation of tax evasion, and we implement training and prevention procedures accordingly. We meet our obligations under the Proceeds of Crime Act 2002 and the Money Laundering Regulations 2017, including client due diligence, risk assessments, recordkeeping, and suspicious activity reporting. We also comply with UK sanctions law under the Sanctions and Anti-Money Laundering Act 2018. In all tax work, we act in accordance with both the letter and the spirit of the law.

Statutory Audit Responsibilities

When performing statutory audits, we comply with the Companies Act 2006, the Statutory Auditors and Third Country Auditors Regulations 2016, and the auditing and ethical standards of the Financial Reporting Council. We meet our duties to investigate and report faithfully on matters required by law, always guided by independence, objectivity, and the public interest.

Decision-Making and Ethical Judgement

When faced with dilemmas, we ask whether the action is lawful, whether it is consistent with this Code and professional standards, and whether a reasonable and informed third party would consider it appropriate in the public interest.

Accountability and Enforcement

Compliance with this Code is mandatory. Breaches may lead to disciplinary action, including suspension or dismissal, reporting to regulators, and, where applicable, civil or criminal proceedings. Every person at Bauer Accountants Limited shares responsibility for upholding this Code and ensuring our conduct reflects the highest professional standards.

Review and Amendments

This Code is subject to review on an annual basis by the Board of Directors. Updates may be made as necessary to reflect changes in legal obligations, business operations, or ethical priorities. All amendments will be communicated in writing and made available to all relevant parties within the Bauer Accountants Limited and its subsidiaries.

Last Updated: August 2025