Code of Conduct

1. Purpose

Capital Contracts provides contract management, claims management, project controls, commercial management, delay analysis, dispute avoidance, training and related advisory services for complex capital projects. Our advice may influence commercial decisions, contractual positions, project records, negotiations and dispute outcomes. Because of that, our conduct must be professional, independent, disciplined and trustworthy.

This Code of Conduct sets out the standards expected from Capital Contracts directors, employees, consultants, secondees, representatives, subcontracted advisers and anyone working under the Capital Contracts name.

2. Core Principles

Capital Contracts expects everyone acting for or with the company to:

• act with integrity, honesty and professional care;
• avoid misleading statements, unsupported conclusions or improper pressure;
• protect client confidentiality and commercially sensitive information;
• manage conflicts of interest transparently;
• treat clients, colleagues, suppliers, counterparties and public officials with respect;
• comply with applicable laws, regulations, professional obligations and contractual requirements;
• maintain accurate project, commercial and business records;
• act fairly and responsibly in negotiations, correspondence and reporting;
• avoid conduct that could damage Capital Contracts's reputation or the trust placed in us.

3. Integrity in Advisory Work

Capital Contracts's work must be evidence-led. We do not knowingly prepare or support claims, reports, records, analysis or commercial positions that are false, misleading or unsupported. Where facts are uncertain, assumptions must be identified. Where evidence is incomplete, limitations must be disclosed. Where professional judgement is required, the basis for that judgement should be capable of explanation.

No person working for Capital Contracts should allow commercial pressure, client preference, internal convenience or personal interest to distort professional advice.

4. Independence and Objectivity

Capital Contracts may act for employers, contractors, developers, project owners, EPC companies, investors or other project participants. Regardless of client identity, our role is to provide practical and professionally grounded advice. We must distinguish between advocacy, analysis, assumption and fact.

Where Capital Contracts is engaged to support a claim, negotiation or dispute process, we may assist the client in presenting its position. However, that support must be based on credible records, contract interpretation, project facts and reasoned analysis.

5. Conflicts of Interest

Actual, potential or perceived conflicts of interest must be identified and escalated before an engagement is accepted or as soon as they arise. A conflict may exist where Capital Contracts has acted for another party on the same project, holds confidential information relevant to another party, has a financial or personal relationship that could affect judgement, or where another engagement could compromise independence.

Capital Contracts may decline work, restrict information access, obtain informed consent, create internal separation measures or take other appropriate steps depending on the nature of the conflict.

6. Confidentiality

Project and client information must be treated as confidential unless it is public, authorised for disclosure or required to be disclosed by law. Confidential information may include contracts, claims, schedules, cost data, correspondence, meeting records, drawings, commercial strategy, dispute positions, personal data, internal reports and digital platform records.

Confidential information must not be used for personal benefit, shared casually, discussed in public areas or transmitted through inappropriate channels.

7. Respectful Professional Conduct

Capital Contracts expects professional behaviour in all interactions. Harassment, bullying, discrimination, intimidation, retaliation, abusive communication, threatening behaviour or deliberate exclusion is not acceptable. Professional disagreement is expected in complex project environments; disrespectful conduct is not.

8. Records and Communications

Capital Contracts records must be accurate, timely and professional. Reports, emails, meeting notes, advice, claim narratives and analysis should be written with the expectation that they may later be reviewed by clients, auditors, legal counsel, tribunals, adjudicators or courts.

We do not alter, destroy or conceal records for improper purposes. Corrections should be made transparently and in line with document control practices.

9. Use of Technology and Digital Systems

Capital Contracts uses digital tools to support communication, document handling, analysis and project delivery. Users must protect login credentials, follow access rules, avoid unauthorised downloads, comply with client system requirements and use approved channels where confidential information is involved.

Where Capital Contracts introduces or refers to AYATA or other digital platforms, the roles of Capital Contracts as adviser and AYATA as technology platform must remain clear.

10. Reporting Concerns

Anyone who becomes aware of conduct that may breach this Code should report it to Capital Contracts management or through the appropriate engagement contact. Capital Contracts will review concerns in a fair and proportionate manner. Retaliation against a person raising a concern in good faith is not acceptable.

11. Review

This Code may be reviewed periodically to reflect changes in Capital Contracts's operations, legal obligations, client expectations and professional standards.