Code of Business Conduct & Ethics

This Code of Business Conduct & Ethics (“Code”) establishes the principles and ethical standards governing all business activities conducted by or on behalf of Rockart Inc. (“Rockart” or the “Company”).
The Code applies across all Rockart operations, controlled brands, technology platforms, and licensed deployment structures, including but not limited to:
— FluidCore Systems™
— COAXA Alta Fera™
The purpose of this Code is to:
— Promote lawful, ethical, and responsible business conduct
— Protect the integrity and reputation of Rockart and its platforms
— Ensure compliance with applicable laws and international standards
— Provide a framework for decision-making consistent with corporate governance best practices
All covered parties are expected to:
— Act with integrity, honesty, and professionalism
— Conduct business in a transparent and responsible manner
— Comply with all applicable laws, regulations, and contractual obligations
— Uphold Rockart’s standards of ethical conduct in all jurisdictions in which they operate
Compliance with this Code is a condition of employment, engagement, licensing, or partnership with Rockart Inc.
Failure to comply may result in disciplinary measures, contractual remedies, or termination of business relationships, consistent with applicable law and contractual provisions.

All employees, officers, directors, contractors, licensees, suppliers, distributors, and other representatives acting on behalf of Rockart Inc. or its controlled platforms, including FluidCore Systems™ and COAXA Alta Fera™, are required to comply with all applicable laws and regulations in the jurisdictions in which they operate.
Covered parties must adhere to, including but not limited to:
— Applicable local, national, and international laws and regulatory requirements
— Anti-corruption and anti-bribery legislation, including the U.S. Foreign Corrupt Practices Act (FCPA), the UK Bribery Act 2010, and other applicable anti-corruption laws
— International sanctions regimes, trade restrictions, and export control laws, including U.S., UK, EU, and UN sanctions frameworks
— Data protection and privacy regulations applicable to their operations
— Competition, antitrust, and fair-trade laws
— Anti-money laundering (AML) and counter-terrorism financing (CTF) regulations where applicable
No covered party may engage in conduct that would cause Rockart Inc. to violate applicable law or expose the Company to regulatory, civil, or criminal liability.
In the event of uncertainty regarding legal obligations, covered parties are expected to seek guidance from Rockart’s designated compliance or legal contact prior to proceeding with any action that may present regulatory risk.
Compliance with legal and regulatory requirements is a fundamental condition of continued engagement with Rockart Inc.

Rockart Inc. maintains a strict zero-tolerance policy toward bribery and corruption in any form.
All covered parties, including employees, officers, contractors, licensees, suppliers, distributors, and representatives acting on behalf of Rockart Inc. or its controlled platforms, including FluidCore Systems™ and COAXA Alta Fera™, must comply with applicable anti-corruption laws and internal standards.
Prohibited conduct includes, but is not limited to:
— Offering, giving, soliciting, or accepting bribes
— Making or authorizing facilitation payments where prohibited by applicable law
— Providing improper gifts, hospitality, travel, entertainment, or other inducements intended to influence business decisions
— Engaging in kickbacks, rebate schemes, or undisclosed commissions
— Using third parties, intermediaries, consultants, or agents to circumvent anti-corruption laws
No employee, partner, or representative may directly or indirectly offer, promise, authorize, request, or accept any payment or thing of value intended to improperly influence a public official, private counterparty, regulator, or business partner to secure or retain business advantage.
All business decisions must be based on merit, quality, pricing, and lawful commercial considerations.
Where gifts or hospitality are permitted under applicable law and industry standards, they must be reasonable, proportionate, transparent, and properly recorded in accordance with internal policies and contractual obligations.
Violations of anti-corruption requirements may result in disciplinary measures, termination of contracts, and referral to relevant authorities where required by law.
Anti-corruption compliance forms a core component of Rockart’s corporate governance framework.

Rockart Inc. is committed to fair, open, and lawful competition in all markets in which it operates.
All employees, contractors, licensees, suppliers, distributors, and partners acting on behalf of Rockart Inc. or its controlled platforms, including FluidCore Systems™ and COAXA Alta Fera™, must comply with applicable competition and antitrust laws in every jurisdiction of operation.
Covered parties must:
— Avoid entering into anti-competitive agreements or arrangements
— Refrain from engaging in price-fixing, bid-rigging, market allocation, or customer allocation practices
— Avoid improper exchanges of competitively sensitive information with competitors
— Not engage in collusion, coordinated conduct, or other practices that distort fair competition
— Compete lawfully, independently, and ethically
Agreements or informal understandings with competitors that restrict competition, limit output, manipulate pricing, or divide markets are strictly prohibited.
All commercial negotiations must be conducted independently and based on legitimate business considerations.
Any employee or partner who becomes aware of potential anti-competitive conduct must promptly report the concern in accordance with Rockart’s reporting procedures.
Compliance with competition and antitrust laws is a fundamental condition of continued engagement with Rockart Inc.

Rockart Inc. expects all partners, suppliers, licensees, contractors, distributors, and other third parties acting on behalf of Rockart Inc. or its controlled platforms, including FluidCore Systems™ and COAXA Alta Fera™, to uphold internationally recognized human rights and labor standards.
Partners must:
— Prohibit all forms of forced labor, bonded labor, involuntary servitude, human trafficking, and unlawful child labor
— Comply with applicable labor and employment laws in the jurisdictions in which they operate
— Provide safe, healthy, and secure working conditions consistent with applicable occupational health and safety standards
— Avoid discrimination, harassment, or retaliation based on race, ethnicity, gender, religion, disability, age, sexual orientation, or other protected characteristics under applicable law
— Respect workers’ rights to freedom of association and lawful collective bargaining, in accordance with local legal frameworks
— Promote fair treatment, dignity, and respect in the workplace
Partners are expected to maintain appropriate internal policies and procedures to ensure compliance with these standards and to implement corrective measures where violations are identified.
Rockart reserves the right to require remediation, enhanced monitoring, or termination of business relationships in cases of material non-compliance with human rights and labor standards.
Compliance with these requirements is a condition of continued engagement with Rockart Inc.

Rockart Inc. requires all employees, contractors, licensees, suppliers, distributors, and partners acting on behalf of Rockart Inc. or its controlled platforms, including FluidCore Systems™ and COAXA Alta Fera™, to protect confidential information and comply with applicable data protection and privacy laws.
All covered parties must:
— Safeguard confidential, proprietary, and commercially sensitive information obtained in the course of business
— Comply with applicable data protection and privacy regulations, including but not limited to GDPR, U.S. state privacy laws, and other relevant jurisdictional requirements
— Implement appropriate technical and organizational security measures to protect personal data and business information against unauthorized access, disclosure, alteration, or destruction
— Limit access to confidential information to authorized individuals on a need-to-know basis
— Avoid unauthorized disclosure, misuse, copying, or distribution of intellectual property, trade secrets, technical documentation, source code, customer data, or strategic information
Confidential information includes, but is not limited to:
— Technical designs and system architecture
— Commercial agreements and pricing structures
— Customer and transaction data
— Intellectual property and proprietary methodologies
— Non-public financial or operational information
Data and information must be handled in accordance with contractual obligations and Rockart’s internal governance framework.
Any suspected data breach, unauthorized disclosure, or cybersecurity incident must be reported promptly through designated reporting channels.
Failure to comply with data protection and confidentiality obligations may result in disciplinary action, contractual remedies, and potential legal consequences.

Rockart Inc. places critical importance on the protection of its intellectual property and proprietary technologies.
All employees, contractors, licensees, suppliers, distributors, and partners acting on behalf of Rockart Inc. or its controlled platforms, including FluidCore Systems™ and COAXA Alta Fera™, must respect and protect Rockart’s intellectual property rights.
These rights include, but are not limited to:
— Patents and pending patent applications
— Trade secrets and confidential know-how
— Software rights, including source code, object code, firmware, and embedded systems
— Trademarks, service marks, trade names, and branding elements
— Industrial designs and system configurations
— Proprietary methodologies, documentation, and technical specifications
Partners may use Rockart’s intellectual property solely in accordance with the terms of a valid written agreement.
The following activities are strictly prohibited unless expressly authorized in writing:
— Unauthorized replication, copying, or reproduction of hardware, software, or system architecture
— Reverse engineering, decompiling, disassembling, or attempting to derive source code or trade secrets
— Unauthorized modification, adaptation, or derivative development
— Unauthorized use of trademarks, branding, or marketing materials
— Misappropriation or disclosure of confidential technical or commercial information
Partners are expected to implement reasonable safeguards to prevent unauthorized access to Rockart’s intellectual property and to notify Rockart promptly of any suspected infringement or misuse.
Violation of intellectual property rights may result in immediate termination of contractual relationships, legal enforcement actions, and claims for damages where permitted by law.
Protection of intellectual property is fundamental to Rockart’s licensing model, innovation strategy, and long-term commercial sustainability.

Rockart Inc. requires all employees, officers, contractors, licensees, suppliers, distributors, and partners acting on behalf of Rockart Inc. or its controlled platforms, including FluidCore Systems™ and COAXA Alta Fera™, to avoid situations that create, or may reasonably appear to create, actual or perceived conflicts of interest.
A conflict of interest arises when personal, financial, or other interests interfere, or could reasonably be perceived to interfere, with the ability to act objectively and in the best interests of Rockart Inc.
Covered parties must:
— Disclose any actual, potential, or perceived conflicts of interest promptly
— Avoid using their position for personal gain or improper advantage
— Refrain from participating in decisions where a personal interest could impair impartial judgment
— Ensure that outside business activities, investments, or relationships do not compromise their professional obligations
Examples of potential conflicts may include:
— Financial interests in a competitor, supplier, or business partner
— Undisclosed family or close personal relationships with contracting parties
— Acceptance of benefits that could improperly influence decision-making
— Engagement in competing business activities
All disclosed conflicts will be reviewed in accordance with Rockart’s governance procedures, and appropriate mitigation measures may be implemented.
Failure to disclose material conflicts of interest may result in disciplinary action, contractual remedies, or termination of engagement, consistent with applicable law and contractual obligations.
Maintaining objectivity and transparency is essential to preserving trust in Rockart’s corporate governance framework.

Rockart Inc. encourages the prompt reporting of any suspected violations of this Code, applicable laws, or ethical standards within its operations or across its controlled platforms, including FluidCore Systems™ and COAXA Alta Fera™.
Suspected violations may be reported confidentially to:
— legal@fluidcoresystems.com
— legal@coaxa-altafera.com
All reports submitted in good faith will be handled with appropriate confidentiality and reviewed in accordance with Rockart Inc.’s internal compliance and governance procedures.
Rockart is committed to conducting proportionate and impartial investigations of credible allegations and to taking appropriate corrective, disciplinary, or contractual action where violations are substantiated.
Retaliation, intimidation, or adverse treatment against any individual who reports a concern in good faith or participates in an investigation is strictly prohibited.
All reporting channels operate under the centralized compliance oversight of Rockart Inc., and material matters may be escalated to executive management where appropriate.

Compliance with this Code of Business Conduct & Ethics is a fundamental condition of employment, engagement, licensing, or partnership with Rockart Inc. and its controlled platforms, including FluidCore Systems™ and COAXA Alta Fera™.
Violations of this Code, applicable laws, or contractual compliance obligations may result in appropriate enforcement measures, including but not limited to:
— Termination of employment or contractual relationship
— Suspension or revocation of licensing, deployment, or integration rights
— Removal from approved supplier or partner status
— Withholding of payments or contractual remedies as permitted by agreement
— Legal action to protect Rockart’s rights and interests
— Referral to relevant regulatory or law enforcement authorities where required
Enforcement actions will be determined proportionately, based on the nature, severity, and impact of the violation, and in accordance with applicable law and contractual terms.
Rockart Inc. reserves the right to take immediate protective action where necessary to safeguard its intellectual property, regulatory compliance position, or commercial integrity.
Adherence to this Code is essential to maintaining trust, operational integrity, and long-term business relationships within the Rockart ecosystem.

Rockart Inc. recognizes that long-term corporate success requires responsible stewardship of environmental, social, and governance (ESG) factors.
Accordingly, Rockart is committed to integrating ESG principles into its corporate governance, operational strategy, licensing model, and partner ecosystem.

Rockart expects all covered parties to:
— Comply with applicable environmental laws and regulations
— Promote environmentally responsible operational practices
— Minimize waste, emissions, and environmental impact where reasonably practicable
— Support sustainable design, energy efficiency, and responsible resource use within licensed systems and deployments
Where applicable, partners are encouraged to implement environmental management systems consistent with internationally recognized standards.

Rockart is committed to:
— Ethical labor practices
— Respect for human rights
— Non-discrimination and equal opportunity
— Safe and responsible working environments
— Responsible supply chain practices
Business decisions shall consider broader stakeholder impact, including employees, partners, communities, and long-term ecosystem sustainability.

Rockart maintains a governance framework designed to ensure:
— Transparency in decision-making
— Ethical leadership
— Risk oversight
— Compliance with applicable legal frameworks
— Accountability at executive and operational levels
ESG considerations form part of Rockart’s risk management and strategic planning processes.
Rockart reserves the right to require ESG compliance representations, contractual commitments, or monitoring mechanisms from partners and licensees where appropriate.

Oversight of this Code and related compliance matters is vested in Rockart Inc.’s executive leadership and corporate governance structure.
The Board of Directors (or equivalent governing body, where applicable) retains ultimate responsibility for oversight of:
— Ethical governance
— Regulatory compliance
— Risk management
— Anti-corruption compliance
— Intellectual property protection
— ESG integration
Operational responsibility for implementation and monitoring of this Code may be delegated to a designated Compliance Officer or equivalent responsible executive.
The Compliance Officer (or designated responsible officer):
— Oversees internal compliance procedures
— Reviews reported violations
— Coordinates investigations
— Recommends corrective measures
— Reports material compliance matters to executive leadership and, where appropriate, the Board
Rockart may establish additional internal governance mechanisms, policies, or committees to support compliance oversight.
Nothing in this section creates third-party beneficiary rights or independent causes of action.

This Code of Business Conduct & Ethics shall be reviewed at least annually by Rockart Inc.’s executive leadership and/or designated Compliance Officer to ensure:
— Continued alignment with applicable laws and regulations
— Incorporation of evolving regulatory requirements
— Reflection of operational developments
— Integration of updated ESG standards and governance practices
— Adaptation to international compliance expectations
Where necessary, revisions will be approved by executive leadership and/or the Board (where applicable).
Updated versions will be published with a revised Effective Date.
Material updates may be communicated to employees, partners, licensees, and other covered parties through appropriate notice mechanisms.
Continued engagement with Rockart Inc. following publication of updated versions constitutes acknowledgment of the revised Code.