Integrity is how we work.

Purpose, scope and personal responsibility

Everyone covered by this policy must understand the rules relevant to their role, complete required training, seek advice when uncertain, report concerns and cooperate with reviews or investigations. Leaders must model ethical conduct, create space for challenge and never encourage results at the expense of our standards.

• No one may instruct, authorise, assist or ignore conduct that would breach this policy.
• No commercial target, deadline, client request or local custom justifies misconduct.
• Attempted misconduct, deliberate blindness and indirect action through another person are also prohibited.
• Questions should be raised before acting where facts, approvals or legal requirements are unclear.

Anti-bribery and anti-corruption

A bribe is any financial or non-financial advantage offered, promised, given, requested or accepted to improperly influence a decision, reward improper performance or secure an unfair benefit. “Anything of value” can include cash, gifts, travel, hospitality, employment, internships, discounts, confidential information, charitable support or favours.

• Kickbacks and secret commissions: prohibited, including any return of fees or contract value to influence an award or payment.
• Facilitation payments: prohibited, even where described as small, customary or necessary to accelerate a routine action.
• Extortion or safety threats: if a payment is unavoidable to protect life, health or immediate safety, prioritise safety; report and record the incident promptly and accurately.
• Indirect payments: funds must never be channelled through agents, relatives, charities, subcontractors or intermediaries to do what Finaffairs cannot lawfully do itself.

Gifts, hospitality, travel and expenses

Reasonable and proportionate hospitality can support legitimate business relationships. It must never create an obligation, influence a decision or appear to do so.

All gifts and hospitality must comply with applicable client rules and any Finaffairs country or engagement threshold. Anything beyond nominal value, involving a public official, or reasonably capable of influencing judgement requires prior written approval and entry in the gifts-and-hospitality register.

Public officials and politically exposed persons

Interactions with government carry heightened risk. “Public official” is interpreted broadly and may include elected or appointed officials; civil servants; employees of state-owned or controlled entities; political-party officials; candidates; judges; members of royal households; and officials of public international organisations.

• Obtain enhanced review before appointing an intermediary who will engage public officials.
• Do not offer gifts, travel, hospitality, employment or other benefits to influence official action.
• Political contributions using Finaffairs funds, resources or name require explicit governing-body and legal approval and must never seek a business advantage.
• Personal political activity must be lawful, undertaken in a personal capacity and kept clearly separate from Finaffairs.
• Charitable or community contributions require due diligence, approval and verification that the recipient is legitimate and independent of any pending decision.

Third parties, partners and supply chains

Finaffairs may be responsible for misconduct carried out by people acting on its behalf. Third parties must therefore be selected for competence, integrity and legitimate need—not for access, influence or personal connections.

• Apply proportionate due diligence before appointment, including ownership, reputation, qualifications, government connections, sanctions exposure and adverse information.
• Use written contracts defining services, reasonable fees, audit rights, ethical duties, record requirements and termination rights.
• Pay only against verifiable services, proper invoices and bank accounts held in the contracting party’s name in an appropriate jurisdiction.
• Monitor higher-risk relationships, refresh due diligence and investigate warning signs before proceeding.

Conflicts of interest and independence

A conflict arises where personal, financial, family or outside interests could—or could reasonably appear to—impair objective judgement. Actual, potential and perceived conflicts must be disclosed promptly.

• Declare relevant investments, outside roles, close personal relationships, client connections and financial interests.
• Do not participate in a decision affecting a related person or organisation unless the conflict has been assessed and formally managed.
• Protect confidential information and never use client or Finaffairs information for personal gain.
• Record agreed safeguards, which may include recusal, information barriers, independent review, reassignment or declining the engagement.

Financial integrity, fraud, money laundering and sanctions

Complete, accurate and timely records are a core anti-corruption control. No undisclosed, off-book or misleading account, invoice, expense, time entry, contract, side letter or payment is permitted.

• Transactions must have a legitimate purpose, correct description, appropriate approval and supporting evidence.
• Never falsify records, misclassify expenditure, conceal beneficiaries or override controls without authorised and documented justification.
• Conduct risk-based client and counterparty checks, including beneficial ownership and applicable sanctions screening.
• Do not accept or move funds suspected to represent criminal proceeds; escalate unusual payment structures or unexplained sources of wealth.
• Preserve records in line with legal, contractual and retention requirements and never destroy information relevant to an audit, inquiry or investigation.

Fair competition, procurement and client conduct

We compete on the quality and value of our work. We do not collude, manipulate tenders, exchange competitively sensitive information or make false statements about our experience, people, pricing, competitors or results.

• Respect procurement rules, evaluation processes, client delegations and communication protocols.
• Do not seek or use confidential competitor bids, non-public evaluation information or improperly obtained data.
• Avoid bid rigging, cover pricing, market sharing and agreements that improperly restrict competition.
• Present credentials, case studies and impact claims accurately; anonymise client information where required.
• Decline work that would compromise independence, professional obligations or lawful client interests.

Respect for people, information and responsible technology

Ethical conduct extends to how we treat people, protect information and use technology. We provide a workplace free from discrimination, harassment, bullying, retaliation, exploitation and forced or child labour.

• Protect personal, client and commercially sensitive information and share it only for authorised purposes.
• Use Finaffairs and client assets responsibly; prevent theft, misuse and unauthorised access.
• Apply human oversight, data quality, fairness, privacy, security and explainability when using analytics or artificial intelligence.
• Respect intellectual property, licence conditions and source attribution.
• Consider environmental and social impacts in our advice, procurement and operations.

Speaking up, non-retaliation and investigations

Anyone who knows of or reasonably suspects misconduct must raise the concern promptly through a manager, engagement leader, the Compliance Lead or the confidential reporting route shown on this page. Reports may be made in good faith even where the facts are not yet proven.

Concerns will be triaged promptly and handled as confidentially as practicable. Investigations will be independent, fair, evidence-based and respectful of applicable law. Everyone must preserve relevant information and cooperate honestly. Nothing in this policy prevents a protected disclosure or lawful report to a regulator, law-enforcement body or other competent authority.

Governance, training, monitoring and enforcement

Senior leadership owns the culture of integrity. The Compliance Lead coordinates policy implementation, risk assessment, advice, registers, due diligence, training, monitoring, investigations and periodic reporting.

• Bribery and corruption risks will be assessed periodically and when entering higher-risk markets, services, partnerships or transactions.
• Training and communications will be proportionate to role and exposure, with enhanced learning for higher-risk teams.
• Controls will be tested and improved using incidents, assurance results, regulatory developments and lessons learned.
• Breaches may result in removal from an engagement, disciplinary action up to termination, recovery of losses, contract termination and referral to authorities.
• No person will be penalised for declining work or losing business because they complied with this policy.

This policy is reviewed at least annually and after material legal, operational or risk changes. Exceptions are not permitted for bribery or corruption; any other policy exception must be lawful, documented, risk-assessed and authorised by designated leadership.