Code of Ethics

Effective 3 September 2026

1. Purpose and scope

This Code governs Apogee Defense LLC, a Texas limited liability company (“Apogee Defense”), and everyone who performs advisory work in its name. It applies to every engagement, every public statement, and every recommendation. Where a signed client agreement imposes a stricter obligation, the stricter obligation controls.

2. The client's interest governs

We are engaged to give advice whose only test is whether it serves the client. When the right advice is to spend less, buy nothing, stop a funded initiative, or not hire us, that is the advice we give. No compensation structure, relationship, or interest of ours may alter a recommendation.

3. Vendor neutrality

Apogee Defense does not resell security products, holds no vendor partnerships, accepts no referral fees, commissions, or placement compensation from any vendor, and has no product of its own to steer a client toward. Where we recommend a product category or assess a vendor's fit, the recommendation is analysis and opinion; the purchasing decision remains the client's. Any offer of vendor compensation is declined and disclosed to the affected client.

4. Related parties and conflicts of interest

A related party is any company in which a principal or employee of Apogee Defense holds a financial interest or a management role. Before any recommendation that could benefit a related party, the relationship is disclosed to the client in writing, the client's written acknowledgment is obtained, and the client may direct that an unconflicted alternative be evaluated. Apogee Defense does not represent a related party's product or service as independent third-party technology. Where a conflict cannot be cured by disclosure, we decline or withdraw from the affected scope.

5. Independence from assessment

We prepare clients for audits, assessments, and certifications; we do not conduct them for the same environment we advised on, and we are not a CMMC Third-Party Assessment Organization. We do not grade our own work.

6. Gifts, hospitality, and anti-bribery

No one acting for Apogee Defense offers, gives, solicits, or accepts anything of value to improperly influence a decision. Ordinary business courtesies of modest value are permitted where lawful and disclosed on request. The Company's Anti-Bribery Policy governs in detail; its Anti-Bribery Committee is the Board of Managers of the Company, and reports to ethics@apogeedefense.com route directly to that body.

7. Confidentiality and publication discipline

Client information is protected under the applicable agreement and professional care regardless of agreement. Public references to client work follow our published anonymization rules: no client names, no geography, no calendar dates; sector generalized where sector alone identifies; numbers published only where substantiable. Nothing is published that a knowledgeable reader could resolve to a client without the client's consent.

8. Reporting and non-retaliation

Concerns about conduct under this Code may be raised by anyone — employee, client, vendor, or third party — to ethics@apogeedefense.com, which routes directly to the Board of Managers, ensuring review by persons other than any individual who may be the subject of the report. Reports may be made anonymously. Retaliation against a good-faith reporter is itself a violation of this Code.

9. Claim discipline

We publish and represent only what we can substantiate. Forward-looking statements are identified as such. Where an error in a public statement is found, it is corrected, not defended.

10. Administration

The Board of Managers administers this Code, reviews it at least annually, and approves any waiver in writing. Waivers of Section 4 additionally require disclosure to any affected client.

Further information

Questions about this Code can be directed to info@apogeedefense.com.