3. Governance – We Are Open, Straightforward & Compliant

Governance – We Are Open, Straightforward & Compliant

Atlas Professionals strives to be a partner our Clients can trust with their legal and compliance related matters. For us, effective governance refers to adopting a set of rules or principles defining rights, responsibilities, and expectations between different stakeholders within our company. Our Code of Conduct, Whistleblower Policy, Fraud Rules, and other company policies ensure that we provide equal opportunities to our people, defining guidance and setting standards regarding expected ambition, behaviour, rules of conduct and performance for our Staff, Professionals and various partners within our supply chain.

Compliance & Anti-Corruption / Fraud Risk Analysis

Atlas Professionals works to create a safe culture and environment in which Staff, Professionals, Clients and other stakeholders can be sure that any suspicion of fraud is reported and adequately managed.

In addition to the Code of Conduct, Whistleblower Policy and Fraud Rules, Atlas Professionals protects itself and its employees from the consequences of such behaviour by implementing a company-wide internal governance framework. In response to identi ed potential fraud risks, several compensating controls are present within Group procedures to detect and prevent these from happening.

Such controls are largely concentrated around:

• A strong segregation of duties (relating expense reports and approvals, payroll processes, cash disbursement processes, compensation and bene ts processes, banking and master data changes),

• High quality and largely standardized internal and external reporting requirements, all of which are subject to various levels of review,

• A strict gifts policy,

• The absence of business with external agents who are paid via commissions.

Financial reporting, risk management and control systems include clear accounting policies and a standard chart of accounts.

Risk Management

Atlas Professionals have a Risk Appetite Statement in place and are continuously seeking opportunities for growth, while taking controlled risks.

By conducting an annual risk review, Atlas Professionals ensures that the risks of the Group are identified and managed effectively, and that operational and financial objectives are met in compliance with local applicable laws and regulations.

The risk management process forms part of our Integrated Management System, and is subject to regular external audits. Furthermore, risk assessments are included in business planning, performance monitoring processes, common processes, system implementations, acquisitions, and integration activities.

Risk Exposure Strategy

Atlas Professionals operates on a global scale with offices located in places which may be vulnerable to (geo-) political unrest. For Atlas Professionals, the safety of our Staff and Professionals is a top priority and hence our risk tolerance in this respect is low. Risk assessments are in place for office and home working, Staff travel, and for work in high-risk areas.

Since February 2022, many of our back-office Staff working from the Odesa office (Ukraine) have been relocated to our Riga office in Latvia (and elsewhere working remotely), with little or no effect to continued operations.

With an increase in our activities directly or indirectly related to the Energy Transition, broadening our scope of services, and seeking new markets; we are becoming less dependent on the Oil & Gas industry, and have targets in place for Energy Transition – to reach > 50% turnover in the Renewables sector (via M&A and autonomous growth) by 2030.