Code of Practice

1. Purpose and Scope

This Code of Practice sets out the standards, principles and behaviours that govern how RAM Utility Group conducts its business across all areas of energy advisory, procurement and portfolio management.

The UK energy market has evolved into a complex, volatile and highly regulated environment. In this context, organisations require not only access to competitive pricing but also structured guidance, transparency and disciplined decision-making. This Code exists to ensure that every interaction, recommendation and outcome delivered by RAM Utility Group reflects these requirements.

It applies to all employees, consultants and representatives acting on behalf of RAM Utility Group and covers all stages of the client relationship—from initial engagement through to ongoing portfolio oversight.

2. Our Role as an Independent Energy Advisor

RAM Utility Group operates as an independent energy advisory firm. We do not act as an energy supplier, nor do we represent the interests of any individual supplier or market participant.

Our role is to interpret market complexity and translate it into clear, commercially aligned strategies for our clients. This includes:

• Designing procurement strategies aligned to financial objectives
• Providing structured access to the wholesale and supplier markets
• Supporting risk-managed purchasing decisions
• Delivering ongoing oversight to ensure sustained performance

Independence is fundamental to our model. It ensures that every recommendation we provide is based solely on what is most appropriate for the client, rather than influenced by supplier relationships or commercial incentives.

3. Principles of Conduct

Our work is underpinned by a set of core principles that guide both our strategic approach and day-to-day behaviour.

3.1 Acting in the Client's Best Interests

We are committed to acting in the best interests of our clients at all times. This means prioritising long-term value, financial alignment and risk management over short-term gains or transactional outcomes.

Every recommendation is developed with a clear understanding of the client's operational requirements, financial constraints and appetite for market exposure.

3.2 Transparency and Clarity

Energy markets are inherently complex. Our responsibility is to simplify that complexity without reducing its accuracy.

We ensure that all advice, pricing information and contractual details are presented in a clear and transparent manner. Clients are provided with full visibility of:

• Pricing structures and cost components
• Contract terms and obligations
• Assumptions underpinning recommendations
• Risks associated with each available option

We do not obscure information, rely on ambiguity or present selective data to influence decisions.

3.3 Professional Discipline

Energy procurement is a financial discipline, not a speculative exercise. Our approach is structured, methodical and grounded in data.

We do not promote reactive decision-making or attempt to "time the market" based on short-term sentiment. Instead, we implement disciplined strategies that reflect long-term objectives and controlled exposure to volatility.

3.4 Accountability

We take responsibility for the quality and integrity of our advice. Our role does not end at contract placement; it extends throughout the lifecycle of the agreement.

We remain accountable for ensuring that strategies continue to perform as intended and that any issues are addressed proactively.

4. Client Engagement and Advice Process

Our engagement with clients is structured and consultative. We begin by developing a detailed understanding of the organisation's:

• Energy consumption profile
• Contractual position
• Budgetary expectations
• Operational requirements
• Risk tolerance

This initial assessment forms the foundation for all subsequent recommendations.

Advice is always tailored. We do not adopt a one-size-fits-all approach, nor do we recommend procurement strategies without a clear and documented rationale.

Communication throughout this process is clear, professional and responsive. Clients are encouraged to ask questions, challenge assumptions and fully understand the decisions being made.

5. Market Engagement and Supplier Interaction

When engaging with the energy market, RAM Utility Group follows a structured and consistent process.

We approach a broad panel of suppliers to ensure competitive tension and comprehensive market coverage. All suppliers are treated fairly and consistently, and pricing is collected and recorded in a transparent manner.

Our analysis considers not only headline pricing but also:

• Contract flexibility
• Volume tolerances
• Risk allocation
• Non-commodity costs
• Supplier performance and reliability

We do not favour suppliers based on undisclosed incentives, nor do we recommend options that are not aligned to the client's objectives.

6. Commercial Transparency and Remuneration

Transparency in cost is a fundamental requirement of our service.

Where RAM Utility Group receives remuneration—whether through brokerage, commission or agreed fees—this is disclosed clearly to the client. We ensure that clients understand:

• How we are paid
• What services are included
• How costs are incorporated into pricing

We do not introduce hidden charges or structure agreements in a way that obscures cost visibility.

7. Risk Management and Strategy Alignment

Energy procurement exposes organisations to financial risk due to market volatility. Managing this risk is central to our advisory role.

We work with clients to define clear risk parameters, including:

• Acceptable levels of market exposure
• Budget thresholds
• Approval processes for purchasing decisions

Procurement strategies—whether fixed, flexible or hybrid—are then designed to operate within these parameters.

We ensure that clients fully understand the implications of each approach, including the potential benefits and risks. No strategy is implemented without informed consent.

8. Data Integrity and Decision Support

Accurate data is essential for effective energy management.

We rely on consumption data, billing information and market intelligence to inform our recommendations. Where data is incomplete or inconsistent, we highlight these issues and, where possible, support their resolution.

Our reporting and analysis are designed to provide clear, actionable insights rather than unnecessary complexity. Data is used to support decision-making—not to overwhelm it.

9. Ongoing Management and Oversight

Effective energy strategy does not end at procurement.

RAM Utility Group provides ongoing oversight to ensure that contracts perform as expected and that opportunities for improvement are identified.

This includes:

• Monitoring consumption and usage patterns
• Validating billing accuracy
• Providing market updates and strategic guidance
• Supporting renewal planning

This ongoing engagement ensures that energy remains a controlled and managed component of the organisation's cost base.

10. Confidentiality and Data Protection

We recognise the importance of confidentiality in all client relationships.

All client data is handled in accordance with UK data protection legislation, including UK GDPR. We implement appropriate technical and organisational measures to ensure that information is:

• Stored securely
• Accessed only by authorised individuals
• Used solely for agreed purposes

We do not share client information with third parties without explicit consent, unless required by law.

11. Conflicts of Interest

RAM Utility Group actively identifies and manages any potential conflicts of interest.

Where a conflict arises, we will disclose it clearly and take appropriate steps to mitigate its impact. Our priority is to ensure that all advice remains impartial and aligned to the client's interests.

12. Complaints and Dispute Resolution

We are committed to maintaining high standards of service and addressing any concerns promptly.

Clients are encouraged to raise any issues directly with us. All complaints are:

• Acknowledged promptly
• Investigated thoroughly
• Resolved in a fair and transparent manner

Where necessary, we will implement corrective actions to prevent recurrence.

13. Regulatory Awareness and Compliance

While the energy advisory sector is evolving, RAM Utility Group operates in line with recognised industry standards and regulatory expectations.

We monitor developments in:

• Ofgem guidance
• Energy market regulations
• Industry best practices

and ensure that our processes remain compliant and up to date.

14. Continuous Improvement

We are committed to continuous improvement in all aspects of our business.

This includes reviewing our processes, incorporating client feedback and adapting to changes in the market. Our objective is to ensure that our service remains relevant, effective and aligned to the evolving needs of our clients.