About This Code

This Code of Ethics and Business Conduct (Code of Ethics) is a statement of our principal commitment to integrity and the highest ethical standards in all that we do. This Code of Ethics defines the standards of conduct that we expect from our directors, members, and employees and guides us to make the right decisions when conducting our business.

This Code of Ethics cannot address every potential concern. However, the standards, values and other guidelines set forth in this Code of Ethics can help members act ethically and with sound, reasoned judgment even in the absence of specific laws, regulations, or policies.

A Culture Founded on Five Core Values

At BRM Holdings, we are committed to fostering and maintaining a culture based on our five core values: Lead with Exceptional Ideas, Communicate Honestly & Transparently, Commit to Collaboration, Commit to “Do the Right Thing”, and Give Back. Living these values means, above all, conducting ourselves and our business activities in accordance with the letter and spirit of applicable laws and regulations and company policies, and acting with integrity to deliver business solutions in a first‐class way. As members, and employees, we must protect our reputation by dealing fairly and transparently with partners, clients, the public, competitors, and suppliers. We strive to not take advantage of anyone through manipulation, concealment, improper handling of confidential information, misrepresentation of material facts or other unfair dealing or practices.

Treating Others with Dignity and Respect

BRM Holdings is committed to providing environments where everyone feels a sense of belonging and is treated with dignity and respect. Misconduct, including discrimination, harassment, retaliation, or other forms of unprofessional behavior, is not tolerated.

How We Conduct Our Business

We strive to adhere to the highest standards of ethical conduct. We will not compromise the legal, regulatory, or policy requirements that govern our activities. Our commitment to ethical conduct means that we abide by the letter and the spirit of applicable laws and regulations. These principles are hallmarks of BRM Holdings’ culture and reflect our pledge to Do the Right Thing.

Each member of the company is responsible for addressing Conduct Risk by:

complying with relevant local conduct standards, including acting with integrity, due skill, care, and diligence at all times and observing proper standards of market conduct

refraining from any act, on or off company premises, that threatens the reputation of the BRM Holdings or any of its clients
being alert to any potential adverse consequences that our actions or the actions of others might have for our clients, the markets, or BRM Holdings

Conflicts of Interest

We take responsibility for taking appropriate actions in accordance with regulatory requirements and policies when we become aware of an actual or potential conflict.

We strive to avoid investment activity or relationships that could or could appear to impair judgment or interfere with the responsibilities of BRM Holdings and our partners and clients.

Anti-Corruption

BRM Holdings prohibits all forms of bribery and corruption. In particular, we do not: offer, promise, give or authorize others to offer, promise or give anything of value, either directly or indirectly, to any party in order to gain an unfair or improper business advantage, such as obtaining or retaining business; or receive, or agree to receive, anything of value that results or may result in improperly influencing our duties as directors or officers.

There are heightened risks when interacting with Government Officials. Government Officials include officers, employees, or representatives (such as agents, advisors, or consultants) of a Government Entity, or any other person acting in an official capacity on behalf of a Government Entity. Government Entities include:
- Governments, Governmental Agencies, and Public International Organizations
- Companies or organizations that are partially or wholly owned or controlled by governments or governmental agencies (even if the company is publicly listed)
- Political Parties and Candidates of Political Parties
- Monarchies and Royal Families

Protecting Confidential Information

Confidential Information

Protecting confidential information is critical to our reputation for integrity and our relationship with partners or clients and ensures compliance with regulations governing transactions we participate in. Much of BRM Holdings' information is confidential information. Confidential information is information that we create, develop, receive, use, learn or have access to that is not generally known by the public, is price sensitive, or is sufficiently sensitive where loss or unauthorized disclosure or access could result in legal, business, regulatory or reputational harm to BRM Holdings or our partners or clients.

We protect all confidential information, regardless of its form or format. We use due care in the handling of such information, and follow all applicable policies with respect to its treatment. We strive to take all reasonable measures to prevent unauthorized persons from obtaining confidential information.

Communications Protected by Law

Nothing in this Code of Ethics shall prohibit or restrict BRM Holdings and its members or employees from:

Initiating communications directly with, cooperating with, providing information to, or otherwise assisting in an investigation by any governmental or regulatory body or official or self-regulatory organization (SRO) regarding a possible violation of any applicable law, rule, or regulation:
Testifying, participating, or otherwise assisting in any regulatory or governmental action or proceeding relating to a possible violation of a law, rule, or regulation; or
Making any other disclosures that are protected by any applicable law or regulation.

Personal Commitment

Employees, officers, and directors of BRM Holdings are committed to and continuously live the company’s core values. Only by doing so can we realize the potential of our organization and the talents of our partners around the world.